The Greater Manchester Clean Air Zone (GM CAZ) has been developed as a response to the 2019 ‘Direction’ made by the Department for Environment, Food and Rural Affairs under the Environment Act 1995. This is a legally binding direction which mandates all ten Greater Manchester councils to bring forward a scheme to reduce Nitrogen Dioxide roadside pollution in line with government guidance. Prior to this Greater Manchester wide Direction, Oldham was issued with an order a year earlier.
Links to government Directions under the Environment Act 1995;
Local Conservatives are trying to muddy the water.
It is clear that local Conservative’s are trying to muddy the water, but the fact is that by law, the only body who has the power to delay or cancel the introduction of the Clean Air Zone, is the Conservative government.
And the government has failed to deliver the financial support required.
My December 2020 Submission to the Greater Manchester Clean Air Zone consultation.
My response to the 2020 consultation on the Greater Manchester Clean Air Zone is available here;
Clean Air Plan
Clean air is key to creating a healthy community, and environments where people want to live, work and study. Dirty air is linked to a number of serious health conditions, early deaths and reducing emissions by just 20% can have a massive impact on our children’s time in school and their working memory.
It will be important to demonstrate that the proposals have had a material impact on pollution rates, with regular reporting, perhaps through an annual report if that is not already planned. It will also be key to demonstrate through this process that rather than simply being about tax collection, that the revenue raised will be used exclusively to drive environmental improvements, and to address other causes of congestion, and the affordability and accessibility of public transport. While private vehicles are exempt, which I strongly support, it is a matter of fact that private vehicles are often used because of the poor public transport accessibility and affordability.
Given the way that many businesses and individuals operate in our city region, the proposed boundaries are sensible, having a single plan for the ten local authorities co-ordinated by TfGM makes sense, and is preferable to having ten individual plans with different rules and enforcement measures.
The Permanent Local Discounts for private hire vehicles licenced in one of the 10 GM Local authorities is a sensible move too, for many in our city-region private hire vehicles provide an essential public transport service.
On a similar note, funding to support bus operators retrofit or replace their vehicles is welcome, we should seek to avoid the cost of any upgrades being passed onto the public who rely on our bus network to travel around the conurbation. But I would hope that there is a clear and transparent joint investment plan agreed with bus operators which clearly reflects the public and private investment being made to contribute to the Clean Air Zone. I also hope that greater priority is given to neighbourhood bus services, where they are often serviced by older and more heavily polluting buses.
I remain concerned that the government has not yet agreed to fund the £150m of support needed to encourage local businesses to upgrade to cleaner vehicles. Without this financial support there is a real risk that the legal responsibility to deal with air pollution continues, but we may find the impact on the self-employed and small businesses is overbearing. There should be a commitment to review the implementation deadlines and charges if the grant funding isn’t in place to allow a manageable transition.
I am concerned of the impact of the daily charges this could have on the small and independent businesses in Greater Manchester. For many of these small/independent businesses, upgrading to a vehicle that meets the emissions standards is simply not an option, the temporary local exemptions are a welcome move to combat this but without funding for the Clean Commercial Vehicle Fund I am worried that some will be left worse off. Therefore, I am supportive of the proposed Hardship Fund for those assessed to be the most economically vulnerable to the Clean Air Zone’s daily charge.
Likewise there is likely to be a number of self-employed and sole traders across the city-region who have found themselves to be ineligible for government support throughout the pandemic, I would hope that this is also taken into account when the assessment criteria for the Hardship Fund is agreed.
Nationally the number of diesel vans has increased from 1.8m to 3.9m, over a two-fold increase in the last 25 years. The Covid-19 pandemic has clearly had a massive impact on the way that we interact with our town and city centres, people are working from home and shopping online more. With that comes an even greater increase in delivery vehicles, with all the major courier companies announcing a significant increase in drivers, both directly and self-employed.
Given this is an area which has boomed in the pandemic, consideration should be given to a special ‘local delivery’ or ‘courier’ category. This recognises there is a significant difference in impact between a tradesperson driving to a job once and leaving the vehicle parked up for the day, and a courier which drives all day long. Under the current proposals both would be subject to the same £10 charge. Consideration could be given to requiring that all local delivery vehicles, often referred to as ‘last mile’ are electric sooner than other commercial vehicles. Local delivery companies could also be supported to accelerate the establishment of localised distribution hubs supported by e-cargo bikes.
I am pleased that loans through a panel of providers are being proposed to assist with taxi drivers who may not be able to secure a commercial loan at a reasonable rate, for instance as a result of being on a low income and/or with a low credit score.
Thought should be given to bringing together the buying power of all public bodies in Greater Manchester for a single fleet renewal strategy. There could be an advantage to securing more favourable lease or purchase contracts. This could be extended to allow Private Hire Drivers to benefit from any discounts realised through such a scheme, recognising their role as an essential part of our public transport system.
A series of exemptions are proposed, which clearly need to be developed so that the public are clear which vehicles will fall under each category. On this basis if they are not already covered, consideration should be given to public service vehicles such as waste collection and street cleaning such as gully cleaning which are very expensive to purchase and specialist in nature, a charge would only serve to be passed on to council tax payers, who are already overstretch following central government funding cuts. Consideration should also be given to providing an exemption to older buses used by community Not for Profit groups, for instance buses used as mobile youth centres, or to transport local sports groups or dance troupes.
Consideration should be given to provide an exemption to horse boxes and motorised caravans/camper vans, rather than the proposed discount, given how they are often used sparingly. The further rationale is that both latter could adversely affect leisure and tourism visitors to the region.
It would be unreasonable to ask those diverted into the Clean Air Zone in circumstances such as road works to pay the charge, and neither should vehicles used by disabled people which are exempt from a charge. There is an exemption in place for vehicles which are required to enter the Clean Air Zone for those diverted, but not to access petrol filling stations. Consideration should be given to the impact this may have on petrol filling stations outside of official service stations, but within proximity to the motorway network. This could also affect travellers with medical conditions which are not registered, who require the use of restroom facilities for instance.
You can download the full letter HERE