Consultation: Our Response to Camden’s Clean Air Action Plan 2016-18

Camden Air Action submitted the following answers to survey questions and the comments that accompany them as Camden Air Action’s response to Camden’s Clean Air Action Plan 2016-18 Consultation.

Overall: Camden Air Action largely supports Camden’s proposals for tackling the current public health emergency that air pollution levels in the borough represent. But where we consider proposals do not go far or fast enough we have told you so. And where we think more information is needed we have asked for it.

We believe the aim should be to make Camden’s air not only LEGAL (below 40μg/m³ NO2 emissions), but SAFE (below 20μg/m³ emissions) and hope comments and suggestions given in our response will be helpful for achieving this.

Once published, we would expect to find more specific information on HOW Camden plans to generate the inspiration, aspiration, understanding, regulation and resources needed to achieve the Plan’s actions and targets.

It will also need teeth if it is to succeed, and become fully integrated with Camden’s Five Year Plan; with Camden’s Environmental Sustainability Plan (Green Action for Change 2012-2020); and with the Local Plan for managing growth and development in the borough, at BOTH strategic and implementation levels.

And it will only meet its targets if adequate staffing and resources are allocated to air quality action, and to ensuring the active involvement and support of local communities.  In a time of Government imposed ‘austerity’ we recognize the pressures Camden is under, and that many necessary services are competing for scarce funding. But we also believe the health and future lives of Camden’s children are too precious to be put on hold, and urge you to make achieving clean safe air one of your foremost priorities for 2016-18.

Clean Air Action Plan 2016-18 survey 

  1. To continue to understand what air pollution levels are in Camden, we believe it is important to monitor air quality across the borough in a variety of different ways. We also plan to make our data publicly available and support those who wish to undertake their own monitoring. Do you agree with this approach?


1.1 It is vital Camden continues and extends air quality monitoring and makes this data widely available to Camden residents. The air pollution monitoring undertaken by Camden, the GLA, TfL and local community groups has revealed a public health crisis in the quality of London’s air. Camden, with its high levels of commuter and through traffic, is one of the worst affected London boroughs, where cleaning up the air we breathe should be made a major priority.

1.2 Ensure data is available at local level and to inform research studies – like ‘Up in the Air’ by Kings College and Policy Exchange in November 2015, and ‘Every Breathe We Take’ by the Royal College of Physicians in February 2016 – to support the development of understand and solutions, and tracking effectiveness of clean air measures as they are introduced.

1.3 Extend fixed point monitors to more locations, including known local ‘rat runs’ used by NS /EW through traffic from inside and outside the borough. Camden should make this an urgent priority and publish locations and figures widely through a range of media to reach all sectors of the community.

1.4 Extend monitoring of local streets by funding and supporting ‘citizen science’ monitoring by local residents and community groups, to enable air quality monitoring and alerts at sensitive locations, like nurseries, schools, health and community centres. In addition to increasing the spread of air monitoring across the borough, this will also raise awareness about air pollution at community level (especially for those who don’t check websites or visit the St Pancras Square pollution level displays). It will also provide data to assess specific air quality action measures, e.g. local projects linked to national campaigns like #DropoffSwitchoff, or #WalkIt, run in partnership with local schools and parent groups.

1.5 Harness local energy on ‘citizen science’ pollution monitoring. A fast and effective start would be to link up with the Camden Transition Network Groups and Neighbourhood Forums who are already monitoring pollution in their areas, in association with Camden Green Party. Followed vy extending to monitoring by local schools, health and community centres and RTAs, on local streets and Council estates would be a next step.

1.6 Extend monitoring to other dangerous atmospheric pollutantsespecially PM10 and PM2.5 but also including others like CO2, Benzene, lead. Enable this by supporting projects based on static and mobile monitors capable of detecting a range of pollutants. Though some pollutants (lead, Benzene) are no longer monitored because it’s considered safe levels have been achieved, such is the scale and level of air pollution in London, we suggest a comprehensive review across all pollutants to renew the picture of what needs tackling. Again, we ask for target numbers and timescales for monitoring sites and projects to implement this

1.7 Monitor pollution rigorously at construction sites – from Camden’s own demolition of the concrete frame 1960s classroom block at Parliament Hill School through to HS2 South of Camden Town. Construction site pollution should be closely monitored BY CONTRACTORS to ensure they are working within pollution limitation regulations, and taking steps to protect neighbouring communities – with fines plus punitive costs if safe levels are breached and others have to implement these measures for them.

1.8 With high pollution levels from the HS2 project potentially over two decades, monitoring by contractors before work begins will be essential to 1) establish an air quality baseline and 2) to confirm mitigation and compensation measures the contractors will need to fund and put in place to safeguard public health.

1.9 Publicise how monitoring underpins air quality action by telling us about sources and types of pollution in our areas: on the commute to work, or the daily walk to and from school. How it highlight hotspots to avoid. And helps us assess the value of different clean air action measures.

1.10 Establish a knowledgeable and expert staff team with an adequate budget and resources to manage Camden’s clean air action.

  1. Emissions from buildings are a major source of pollution in Camden. We aim to work with businesses and residents to help them increase their fuel efficiency and save money while also reducing air pollution emissions. This also helps tackle climate change by reducing carbon dioxide emissions. Do you agree with this approach?


2.1 Camden should ensure the Clean Air Action Plan is linked to the bigger picture, where urban transport, planning, housing and development, are all connected to environmental pollution and global warming, and the damaging rise in NO2, PM10, PM2.5, CO2.

2.2 Camden needs to provide more information on HOW cutting pollution on its own estate will be implemented and achieved, within the urgent time frames required by departments responsible for Camden’s building and estates.

2.3 Camden Housing still struggles to embed CO2 emissions reduction in their work, and we are painfully aware of current failures to embed energy saving and emissions reduction in Housing Department practices. This includes both large scale maintenance and improvement programmes, and upgrading individual voids for re-letting – where measures like internal wall insulation or draught proofing (that can save up to 20% emissions on older wooden sliding sash window properties) could be simply and inexpensively achieved. How can Camden Housing routines be updated to include new policy targets? How can reducing air pollution from Camden buildings be more successfully achieved? And has reducing air pollution been fully factored into Camden’s new Better Homes programme, for upgrading post 1960s Council estates with new heating systems, double glazing and roof insulation? We are looking for answers.

2.4 More generally, but crucially, how will Camden ensure VISION for reducing pollution is converted into DAY-TO-DAY GOOD PRACTICE by departmental teams? E.g. for Housing – from upgrading voids for re-letting to parking (or not) on Council estates? For upgrading and developing new schools? For buying less polluting new vehicles? Or – at most basic level – ensuring Camden drivers don’t leave engines running when parked? We need more detail on implementation.

2.5 Now we better understand the polluting effects of CHP and biomass generation Camden should very seriously review recent experiments in neighbourhood CHP heating systems, to establish the pollution levels they involve in installation, fuel source processing and use. This should include a realistic assessment of CHP system benefits (and for whom) in terms of energy provided to homes (which some estimates give as low as 50% of the energy generated); benefits to landlords and building owners from the electricity these systems generate; potential pollution from fuel source processing (possibly to remoter communities) and in use, at local level.

2.6 Camden buildings MUST be powered by green/renewable electricity – otherwise we will just continue to stoke the fires of global warming and shift pollution to more remote communities at the point of fuel processing and energy generation (DRAX large scale biomass generation being a prime example of this). Camden should investigate potential to become part of a London-wide Renewable Energy Generation system, as proposed and discussed in the London Mayor elections.

2.7 Camden should strengthen and accelerate informing home owners/tenants about what we can all do to reduce energy consumption and pollution from buildings. Also lobby Government and the GLA to 1) replace present boiler cash back incentives with more strongly funded boiler scrappage schemes, and 2) introduce properly funded, designed and managed schemes to support emissions reduction from older buildings through insulating and draught proofing – moving us on from the ill-conceived and ineffective Green Deal.

2.8 Camden should lead by example with pollution mitigation planting around its housing estates, offices and public buildings. And by supporting local initiatives like ‘Lift One Paving Stone’ that encourage residents to reverse the trend of paving over front gardens to create off-street parking, by un-paving to release the Earth and plant nectar rich and oxygen emitting flowers, shrubs or trees

2.9 Ensure Camden’s own energy supply is from green renewable sources – and publish this to encourage businesses and individual households to also make the switch.

2.10 Use the planning process to encourage urban scale and domestic renewable energy generation across the borough, on roofs of schools, churches, community centre and commercial and domestic buildings, including in conservation areas. And be willing to partner with local renewable energy generation projects, like Power Up North London (PUNL) by making Camden building stock roofs available, and by being prepared to share the profits in the interests of spreading the word and creating behaviour change on home energy use.

2.11 Favour rehabilitation over polluting demolition (of concrete buildings especially) and resource hungry new build when renewing Camden’s own buildings.

2.12 Limit business and domestic car parking and encourage cycling. Apart from re-charging infrastructures for electric vehicles for essential users i.e. those with disabilities, emergency services personnel, all new developments should be car free. No more underground car parks under new apartment blocks, or paved over front gardens ( a problem especially in N and W of borough).  Instead, support cycling and walking with good cycle and baby buggy storage. On Council estates work with RTAs to convert redundant garages and sheds into cycles ‘garages’, and elsewhere with residents groups to introduce well-located bike hangars.

2.13 Camden must deal more effectively with developers – use planning regulation to prioritise rehabilitation over new build (recognising, in particular, the high levels of damaging pollution generated by concrete demolition), and to reduce pollution during construction, including from transport to/from sites. Camden should form an alliance with other local authorities, town planning institutes and legal specialists to challenge central Government’s present over-ruling of local decisions in favour of national developers

2.14 And be REALLY tough on HS2 development (18years of it!) to safeguard health and well-being of Camden communities.  ‘Assurances’ from developers that pollution will be kept to a minimum are not reliable or effective. We must have firm commitments with tough financial penalties to deter infringements, which – as a last resort – can be ploughed back into mitigating the destruction they bring to local health and quality of life.

  1. A large proportion of air pollution is caused by road transport. We plan to tackle this first by encouraging people to cycle, walk or use public transport, and then through encouraging the up-take of low emission vehicles, while also discouraging the use of diesel vehicles. Do you agree with these priorities and our approach?


3.1 Treat pollution from transport in London and other major cities as a national emergency, requiring fast united action to make the safe for residents and transport users. Nowhere in Camden achieves this at present, and the vast majority of streets are above the EU legal limit.

3.2 We strongly support policies that reduce pollution by reducing traffic volumes and congestion, and promote safe and healthy cycling and walking for local journeys and commuting, along with a zero emissions public transport network. A Camden wide zero emissions zone would reduce pollution and make cycling and walking more attractive prospects.

3.3 Give high priority to reducing present high volume of through traffic on roads in Camden, from OUTSIDE the borough, which brings both dangerously fast traffic and congestion and pollution to both major roads and local streets. In particular, aim to reduce traffic and pollution from 1) the dangerous and stressful mix of private cars, HGVs and LGVs, buses and bikes on the commute to and from work in central London; and 2) from car based ‘school runs’ converging on private schools in Hampstead, that leave local children walking to local schools along dangerous, congested and polluted streets.

3.4 Take immediate action to protect public health by securing powers to close roads or ban polluting vehicles when pollution limits are exceeded – as recommended by the Royal College of Physicians and Royal College of Paediatrics and Child Health, in their report: ‘Every Breathe We Take: the lifelong impact of air pollution’ (February 2016). Just one of our local streets illustrates the problems we face: Kentish Town Road, where ‘citizen science’ monitoring in November 2015 gave a 98 ug/m3 reading, more than double the legal limit of 40ug/m3, and way about the maximum recommended safe limit of 20ug/m3. Kentish Town Road is both a local shopping centre and a busy walking route to two local primary schools just a short distance from the main road. It is also a congested major NS transport route for traffic travelling in and out of central London, and for HGVs to the industrial and distribution centre off Regis Road. This mix of congested through traffic, store and supermarket delivery vans and HGVs with vulnerable local pedestrians is totally unacceptable, now that we more fully understand the damage to health caused by traffic emissions, and to child health and development in particular. We look to Camden to fulfil its duty of care by taking strong and immediate action to protect local communities from this toxic mix of traffic and pollution on streets like Kentish Town Road.

3.5 Introduce support traffic schemes to improve safety and ease of travel for cyclists and pedestrians. We want to see Camden providing or supporting more child and adult cycle training, with workshops to develop bike maintenance and repair skills, and both secure street cycle parking and more cycle ‘garaging’ on Council estates and in all new housing developments.

3.6 Work with schools, parents and children to reduce pollution levels around schools to extend present initiatives to school sites across the borough. Raise awareness and encourage action through wider ‘citizen science’ monitoring involving students and parents. Fund and support parent led-projects linked to national initiatives like # DropOffSwitchOff and #Walkit, that encourage responsible car use or better walking children to school, with before and after monitoring to demonstrate effectiveness.

3.7 Camden should help develop a shared vision of what life could be like on local streets with less traffic, through ‘taster experiences’, such as regular Play Street closures and traffic free days on certain roads – including busy ones –  involving schools and communities in their organisation.

3.8 Ensure actions to reduce pollution are measurable – with target numbers and dates included in clean air/pollution reduction schemes. Regular monitoring and progress reviews should be built into their organisation. Local schemes should be linked to a London-wide Pollution Action Hub, so good practice can be shared and learned from.

3.9 Bring target dates for achieving clean air forward from the present estimate of 2025 – as the earliest that clean air can be achieved in central London – to 2020 or earlier. And ensure the necessary levels of investment and funding are available to achieve them.

3.10 Promote the switch FROM diesel to cleaner fuel vehicles. Camden should be part of a national programme to promote recognition that the switch to diesel over the past decade has been a primary cause of the present crisis in air quality, and to introduce measures to get polluting diesel vehicles off the road. Camden should lobby Government to remove diesel vehicle subsidies and introduce a diesel scrappage scheme that supports drivers, who made the switch to diesel in good faith, to switch again to less polluting vehicles. And Camden can take action itself it should do so, e.g. by introducing higher parking charges for diesel vehicles, as another incentive to switch.

3.11 Camden should lobby the EU to ensure vehicle manufacturers’ pollution tests and the MOT are rigorous, and correctly applied, with smaller margins for error than those currently permitted. That diesel cars remain as polluting as they were in the 1990s shows that car manufacturers cannot be trusted to put the health and welfare of drivers and the general public before profit. In use, passing a pollution test should be mandatory to passing the MOT, and ensure that exhaust filters (which some diesel car owners disconnect to save on cost of cleaning) ARE properly used. If a vehicle fails pollution tests they should fail the MOT and come off the road.

3.12 Camden should lead by example, with non-polluting vehicles and driving practices by Camden staff. This should include vehicles used by Camden contractors for waste removal, recycling, street cleaning and estates buildings, parks and gardens maintenance and community transport services. Measures should range from big actions like commissioning new vehicles and contractors, through ensuring vehicles are properly maintained, down to good driving practices – including not leaving engines running while parked (something that’s currently frequently observed).

3.13 On major roads where buses and taxis are the prime polluters e.g. Oxford Street, Tottenham Court Road, Marylebone/Euston Road ‘clean bus and taxi corridors’ should be enforced, allowing only zero emissions vehicles to travel on them. Set 2018 as the target date for implementing this, and 2020 for ALL central London buses being upgraded to the minimum Euro 6 standard, with this implemented London wide by 2022.

3.14 Lobby to speed up getting older polluting taxis off the road by reducing maximum taxi permitted age from 15 to 10 years, with financial support for converting viable older taxis to LPG fuel.  But, with the aim of reducing overall traffic, limit the number of private hire vehicles permitted in central London when buses offer a viable alternative, e.g. by restricting the number of private hire vehicles licenced to trade in central London between 7am – 9pm.

3.15 With HGVs and LGVs making up 40% of road traffic emissions Camden should continue participation in the London Boroughs Consolidation Centre, where supplies are decanted from large HGVs to smaller vehicles for distribution at local level. And encourage take up of this and other ‘smart freight’ measures by large companies and retailers. Support banning large HGVs from central London, and from highstreets and local roads of inner London boroughs like Camden.

3.16 Clean up pollution from the increasing number of LVGs. We understand diesel LGVs (small tradesmen’s ‘white vans’ and parcel delivery services) are a growing element in traffic travelling in and out of London each day (and through inner London boroughs like Camden), with some small traders vehicles poorly maintained and heavily polluting. Include them in ‘smart freight’ schemes and limit times they can travel on roads near schools and other sensitive sites, so their journeys don’t coincide with the ‘walk to school’ – as so often happens today. And use new technology ‘pollution cameras’ to identify and issue fines to polluting vehicles, as speed cameras do on speed.

3.17 Electric vehicles will be PART of the solution, within the overall aim of traffic reduction, BUT only if powered by green renewable electricity at home and street side recharging points – otherwise we simply continuing to stoke the fires of global warming and shift pollution to more remote communities at the point of fuel processing and energy generation (DRAX large scale biomass generation being an example of this).

3.18 Within the overall aim of support a switch to walking, cycling and public transport in inner cities, Camden should have clear targets for supporting vehicles powered by green renewable energy, with an emphasis on car and van hire clubs, and use of electric cars by essential users.

3.19 To support the development of vehicles powered by CLEAN renewable electricity, Camden should link up with other London boroughs and the GLA to provide consistent London wide service provision for home based, on street and town centre recharging points. Also for schemes that enable vehicles to be dropped off at journey end points, as well as being returned to the same hire point. Camden should publish targets numbers and dates for implementation – being aware that the GLA has so far fallen far short of commitments made on this.

3.19. Create a forum for sharing stories about innovative local solutions for moving local loads – like the bike trailers used by local Transition groups to move event and growing materials. Or by the Kentish Town Veg Box Scheme, where bike trailers drop off 100 bags of vegetables every Wednesday to customer pick up points across Kentish Town and Dartmouth Park; supplemented now by an hour’s Zip Van hire to deliver to new pick points in Highgate and Tufnell Park. Or Camden Green Gym’s custom built heavy duty bike trailer, that transports gardening tools and other essentials to their sessions, saving pounds in van hire fees. And for those whose cycling days are over, how supermarket deliveries by electric vehicles offer a greener and easier way to get the groceries in. And why it’s time shopping trollies got an image makeover!

  1. Raising awareness of air pollution is an important part of our work, as it enables people to take action to reduce air pollution, and also helps them to minimise their exposure to harmful pollutants, especially when air pollution is particularly poor. In particular, this Plan emphasises the importance of working with health professionals to improve awareness of air quality. Do you agree with this approach?


4.1 Raising public awareness is vital to cleaning up London’s air within the time frames public health protection requires. Public support will be essential to making the major changes needed to reduce air pollution, in the ways we travel round our city, and heat and maintain our homes. And local communities have a right to know where and how to protect themselves and their families from dangerously polluted air.

4.2 Camden MUST ensure an adequate budget and well-managed public education programme to get air quality information across, giving it at least as high a profile in poster campaigns as those we see in bus shelters, local papers, health centres and in the Camden magazine, for issues like domestic and elder abuse, illegal sub-letting, drink awareness and healthy living. Even in a time of ‘austerity’, resources MUST be found. Our children’s health is too important to be put on hold

4.3 Provide information through a variety of media and awareness raising projects designed reach all sectors of the community. Work through hospitals and health centres, and community centres and local schools, TRAs, Neighbourhood Forums, community activists and Transition network groups to spread the word. Organise well publicised ‘wake up’ events, like the previous Green Summits, that bring people together and begin to build networks.

4.4 Establish real time meters with large display screens at pollution hotspots across the borough, visible to both pedestrians and motorists

4.5. Introduce ‘trickle down’ air quality action training for Camden staff across all departments – on the lines of the attitude and behaviour changing Equal Opportunities Staff Training introduced by major employers in the late 1990s.

4.6 Invest in communication and conflict resolution training for staff and individuals involved in community pollution projects. The reaction to the Swiss Cottage Cycling Super Highway, and lack of care and downright antagonism between different transport mode users, suggests this will provide necessary and beneficial skills and safeguards.

4.5 Camden should set targets and timelines for assessing success in attitude/behaviour change.

  1. Air pollution is a shared problem, where control over many of the sources and potential solutions of air pollution is not under Camden’s direct control. We aim to work with other organisations to jointly improve air quality, while also not being afraid to challenge and lobby others to do more where we think it would benefit Camden. Do you agree with this approach?


5.1 Its vital Camden plays its part in reducing air pollution across the borough and in London, using the powers it has to do so, and lobbying where others (GLA, TfL, central Government, car manufacturers, developers and building and transport contractors) are responsible. Camden has some of the worst air among European capital cities, and our children’s health is too precious to hang about waiting for central Government, business and vested interests to do something.

5.2 Think BIG by assembling powerful allies – but also act LOCAL by developing community partners. Both will be needed to make the changes we need.

5.3 Extend Camden’s influence and access to the expertise and funding needed to achieve clean air through alliances with like-minded partners, like the Royal College of Physicians (”Every Breath We Take” report on air pollution & Climate Change’ Feb. 2016), or academic and research institutes (like Kings College and Policy Exchange air pollution units and others) and UCL and the Building Centre, teaching hospitals, local health care networks, London-wide NGOs and community groups.

5.4 Do not forget that local Camden communities are partners too, not simply consumers of Camden services. Raising awareness among local people and involving them in spreading the word, will be a vital part of gathering support for the changes needed to reduce air pollution in the borough.

5.5 Partnership will be essential to reducing the toxic cocktail absorbed on the journey to work,  (of diesel particulates, NO2 and other pollutants) from the three major railway stations (Euston, St Pancras and Kings Cross) in close proximity along one the most polluted sections of the Euston / Marylebone Roads. Rail, road, bus and tube travel are all involved, and partnering with TfL, National Rail and individual rail companies will be needed to resolve it. See BBC news report on monitoring pollution on a journey to work – including diesel particulates from trains – using a mobile backpack mobile monitor.

5.6 Work with London wide partners to achieve a wide and rigorously managed ULEZ, where polluting vehicles are BANNED, not just allowed to travel around if they can afford to pay more.

5.7 Build community partners by funding small scale grass roots community air quality projects with schools, RTAs, community and health centre user groups, and greener living networks, to raise awareness and develop local pollution solutions. Consider using/adapting the model of Camden Communities Green Fund Grants seed funding (then for improved energy use and recycling, and building green and resilient communities) to develop clean air projects that help cut local pollution levels and protect local communities. Develop a strategy for rolling this out and for developing a network of community clean air activists and social enterprises across Camden.

  1. Do you have any other comments about the Plan or air pollution in Camden? Please write your comments in the space below

Please see our introductory comments at the beginning of our response

  1. Do you have any ideas or suggestions for actions that could be taken to improve air quality in Camden? Please write your comments in the space below.

Please see the points we have made in our responses to questions 1-5.  We would welcome the opportunity to discuss these with you to support the development and implementation of a clean air action plan in Camden.

Clean Air Action Plan 2016-18 survey

Submitted by Pamela Edwards on behalf of Camden Air Action: a convergence of local Transition Network Groups in Kentish Town, Camden Town, Dartmouth Park, Highgate, Belsize Park and Primrose Hill, with Camden Green Party and others, for raising awareness & taking constructive actions on air quality in Camden.