Response from Richmond & Twickenham Friends of the Earth to the London
Borough of Richmond-upon-Thames Air Quality Action Plan 2024-2029
This is the response to the LBRUT air quality action plan consultation on behalf of Richmond and
Twickenham Friends of the Earth (RTFoE). We are one of over 200 groups affiliated to and supported
by Friends of the Earth (FoE), and are the local FoE group covering the London Borough of Richmond.
We have around 250 members and supporters locally.
Overall
Overall, we welcome the targets in the Plan. These would result in a significant improvement in air
quality at some locations in the Borough, provided that, as intended, the targets are treated as a
minimum for all sites. As the plan document points out, poor air quality remains a significant cause of
death and ill health within the Borough. We strongly support the proposed move towards World
Health Organisation targets, and note that this is more ambitious than the national UK objectives.
It’s also good to see the clear timelines and targets in appendix A and we welcome the idea of a plan
that is continuously updated for progress.
The measure of success will be in the enactment of the plans. It is not always clear whether the actions
and aspirations of the previous 2019-2024 plan have been achieved. Some clearly haven’t, for example
discouraging through traffic. It would be helpful if the next plan (presumably 2029-2034) could include
a brief update on progress against this plan’s targets, and a commentary on successes, barriers and
challenges.
We look forward to supporting the Council in pushing forward some of the more ambitious targets,
and also to holding you to account.
We include below, more detailed comments on specific areas.
Domestic heating
Retrofitting
In order to improve air quality (as well as addressing the Borough’s climate targets) it is vital that the
Borough’s housing stock (both privately owned and social housing) moves to more eco-friendly and
lower emitting heating sources. At present, the planning requirements for households wishing to
move to heat pumps can be onerous, time–consuming and expensive, especially for the relatively high
proportion of homes in conservation areas or with listed status. Gaining planning permission for other
retrofitting measures, such as solar panels can also be difficult/impossible for these types of homes.
We urge the Council to take steps to simplify and speed the process, and to prioritise the sustainability
of the Borough’s housing stock over a desire to keep things looking nice.
Wood fires
The burning of wood (or coal) for heating can be a significant and growing source of pollutants,
especially particular matter. It has been suggested that that 37% of
Londoners use an open fire or wood burner, despite the capital being a smoke control area, and that
enforcement is practically non-existent. Whilst we welcome the proposal for increased education, we
Borough of Richmond-upon-Thames Air Quality Action Plan 2024-2029
This is the response to the LBRUT air quality action plan consultation on behalf of Richmond and
Twickenham Friends of the Earth (RTFoE). We are one of over 200 groups affiliated to and supported
by Friends of the Earth (FoE), and are the local FoE group covering the London Borough of Richmond.
We have around 250 members and supporters locally.
Overall
Overall, we welcome the targets in the Plan. These would result in a significant improvement in air
quality at some locations in the Borough, provided that, as intended, the targets are treated as a
minimum for all sites. As the plan document points out, poor air quality remains a significant cause of
death and ill health within the Borough. We strongly support the proposed move towards World
Health Organisation targets, and note that this is more ambitious than the national UK objectives.
It’s also good to see the clear timelines and targets in appendix A and we welcome the idea of a plan
that is continuously updated for progress.
The measure of success will be in the enactment of the plans. It is not always clear whether the actions
and aspirations of the previous 2019-2024 plan have been achieved. Some clearly haven’t, for example
discouraging through traffic. It would be helpful if the next plan (presumably 2029-2034) could include
a brief update on progress against this plan’s targets, and a commentary on successes, barriers and
challenges.
We look forward to supporting the Council in pushing forward some of the more ambitious targets,
and also to holding you to account.
We include below, more detailed comments on specific areas.
Domestic heating
Retrofitting
In order to improve air quality (as well as addressing the Borough’s climate targets) it is vital that the
Borough’s housing stock (both privately owned and social housing) moves to more eco-friendly and
lower emitting heating sources. At present, the planning requirements for households wishing to
move to heat pumps can be onerous, time–consuming and expensive, especially for the relatively high
proportion of homes in conservation areas or with listed status. Gaining planning permission for other
retrofitting measures, such as solar panels can also be difficult/impossible for these types of homes.
We urge the Council to take steps to simplify and speed the process, and to prioritise the sustainability
of the Borough’s housing stock over a desire to keep things looking nice.
Wood fires
The burning of wood (or coal) for heating can be a significant and growing source of pollutants,
especially particular matter. It has been suggested that that 37% of
Londoners use an open fire or wood burner, despite the capital being a smoke control area, and that
enforcement is practically non-existent. Whilst we welcome the proposal for increased education, we
would also like to see more monitoring, following up of complaints and strict enforcement where
current legal limits are breached.
Traffic
Reliance on EVs
Our main concern with the parts of the plan relating to traffic is the focus on encouraging a move to
electric vehicles (EVs). Whilst a continued shift to EVs would be beneficial to levels of NO2, it could
actually worsen the levels of particular matter (PMs). This is because PMs are often heavier than
petrol and diesel cars, and so create more PMs when braking. Whilst we accept that the Plan (p39)
suggests that this will be monitored, we believe that only a significant shift away from driving to active
travel or public transport can deliver a meaningful reduction in PMs. This is where the main
focus/emphasis should be.
Encouraging active travel
In order to achieve a mode shift to walking and cycling it is important to create an environment where
people feel safe to walk and cycle, and where it is convenient to do so. Whilst not within the Council’s
direct control, we would encourage you to work closely with the local police to increase enforcement
of speed limits and to crack down on dangerous driving, by both motorists and motorcyclists.
We would also like to see more secure bike shelters provided, and a roll out of docking stations for hire
bikes and scooters so that people know where to find them and they aren’t a nuisance.
In addition, we would like to see more bike lanes and greater promotion of quieter routes, away from
busy roads, so that families can walk and cycle without exposure to the more polluted and busy roads
in the Borough. At present these quiet routes often don’t join up, with main roads and one-way streets
blocking links. We would like to see more focus on linking up routes to provide a low pollution network,
and would also encourage the production and promotion maps highlighting safe cycling routes, similar
to those that TfL used to produce.
Town Centres
Given that our town centres often have poorer than average air quality, we would like the Council to
consider pedestrianising George Street in Richmond. We would also like to see bike lanes restored/put
in where town centres can’t be avoided.
We would strongly support any measures which seek to discourage through traffic in the Borough, and
especially in our town centres.
Public transport and parking
Whilst the Borough has relatively good public transport provision, there is also scope to encourage
mode shift from private vehicles to trains and buses. We strongly support the current policy of limiting
parking provision in new build residential, but such efforts risk being undermined by the growing
practice of allowing private sites to sell parking (for example the recent granting of a development
consent order to the Richmond Athletic Ground for significant numbers of parking spaces; and the use
of land between London Welsh and Kew Gardens for parking). The provision of 30 minutes free parking
in our town centres also encourages car use for short journeys and should be revisited.
Idling
We welcome the proposed use of PSPOs to enforce anti-idling measures.
Traffic
Reliance on EVs
Our main concern with the parts of the plan relating to traffic is the focus on encouraging a move to
electric vehicles (EVs). Whilst a continued shift to EVs would be beneficial to levels of NO2, it could
actually worsen the levels of particular matter (PMs). This is because PMs are often heavier than
petrol and diesel cars, and so create more PMs when braking. Whilst we accept that the Plan (p39)
suggests that this will be monitored, we believe that only a significant shift away from driving to active
travel or public transport can deliver a meaningful reduction in PMs. This is where the main
focus/emphasis should be.
Encouraging active travel
In order to achieve a mode shift to walking and cycling it is important to create an environment where
people feel safe to walk and cycle, and where it is convenient to do so. Whilst not within the Council’s
direct control, we would encourage you to work closely with the local police to increase enforcement
of speed limits and to crack down on dangerous driving, by both motorists and motorcyclists.
We would also like to see more secure bike shelters provided, and a roll out of docking stations for hire
bikes and scooters so that people know where to find them and they aren’t a nuisance.
In addition, we would like to see more bike lanes and greater promotion of quieter routes, away from
busy roads, so that families can walk and cycle without exposure to the more polluted and busy roads
in the Borough. At present these quiet routes often don’t join up, with main roads and one-way streets
blocking links. We would like to see more focus on linking up routes to provide a low pollution network,
and would also encourage the production and promotion maps highlighting safe cycling routes, similar
to those that TfL used to produce.
Town Centres
Given that our town centres often have poorer than average air quality, we would like the Council to
consider pedestrianising George Street in Richmond. We would also like to see bike lanes restored/put
in where town centres can’t be avoided.
We would strongly support any measures which seek to discourage through traffic in the Borough, and
especially in our town centres.
Public transport and parking
Whilst the Borough has relatively good public transport provision, there is also scope to encourage
mode shift from private vehicles to trains and buses. We strongly support the current policy of limiting
parking provision in new build residential, but such efforts risk being undermined by the growing
practice of allowing private sites to sell parking (for example the recent granting of a development
consent order to the Richmond Athletic Ground for significant numbers of parking spaces; and the use
of land between London Welsh and Kew Gardens for parking). The provision of 30 minutes free parking
in our town centres also encourages car use for short journeys and should be revisited.
Idling
We welcome the proposed use of PSPOs to enforce anti-idling measures.
Hammersmith Bridge
Comments on page 39 regarding Hammersmith Bridge notes the improvement to air quality from its
closure to motor traffic, but disappointingly do not suggest that the Council would support a limited
reopening, with access only for walking, cycling and public transport. A possible future full reopening
would risk the loss of recent air quality gains in Barnes and the wider area. We would encourage you
to be braver on this issue, given that the Council must have some influence on the potential outcome.
Heathrow
We welcome the Council’s continued opposition to Heathrow expansion.
Monitoring
We would encourage the provision of monitoring results in a user-friendly format, to enable residents
to easily understand the air quality in their area and any progress in improving it.
closure to motor traffic, but disappointingly do not suggest that the Council would support a limited
reopening, with access only for walking, cycling and public transport. A possible future full reopening
would risk the loss of recent air quality gains in Barnes and the wider area. We would encourage you
to be braver on this issue, given that the Council must have some influence on the potential outcome.
Heathrow
We welcome the Council’s continued opposition to Heathrow expansion.
Monitoring
We would encourage the provision of monitoring results in a user-friendly format, to enable residents
to easily understand the air quality in their area and any progress in improving it.