Living Streets Edinburgh Group (LSEG) welcomes the Council’s plans to move forward with introducing a Low Emissions Zone (LEZ) in Edinburgh but we are concerned that the current proposals are not sufficiently ambitious and will have a serious detrimental impact for some residents, particularly those that live outside the boundaries of the currently proposed City Centre LEZ. We strongly believe that the boundaries of the LEZ should be increased in order to benefit a larger proportion of the residents of Edinburgh.

The area of the proposed LEZ currently covers only 2.5% of the City and excludes many areas of the City with the greatest density of residents. It will also not include the designated Town Centres, which form such an important element in the development of 20-minute neighbourhoods outlined in the recently approved City Mobility Plan. In setting the boundaries of the LEZ, more consideration has been given to providing convenient diversionary routes for non-compliant vehicles than maximising the health benefits for people living in Edinburgh. Pollution levels have been considered on an absolute basis without any consideration of the number of people that will be exposed to that pollution. LSEG is particularly concerned that there is no recognition of the risks to pedestrians from vehicular emissions in areas outside of the proposed LEZ; some of which have very high levels of walking including children walking to school.

The Council report that was considered by the Transport and Environment Committee at their June 2021 meeting states non-compliant vehicles will increasingly use the roads immediately outside the LEZ resulting in increased pollution on these routes. The SEPA forecast attached to the report shows an increase in atmospheric pollution on Queen Street, London Street and Abbeyhill; all areas on the edge of the currently proposed LEZ. We note that the Council has included an objective to “minimise the impact from traffic displacement across network, related to LEZ scheme”. No detail is provided on the mitigating actions that will be taken or how achievement of this objective will be measured. Before any final decision is taken on introducing a LEZ it is critical that there are clear plans in place to limit the negative impact of displaced traffic to reassure residents living near the LEZ.

The current plans are focussed on reducing levels NOx pollution from vehicles within a small part of the City to meet current legislative limits. In our view, this goal does not go far enough. Other forms and sources of pollution need to be both more closely monitored and reduced, in particular the levels of particulate pollution and continued use of temporary diesel generators within the LEZ. We would like to see the Council setting more ambitious and wide ranging targets for reducing pollution given the accepted health benefits of such a reduction. This is the time for bold action that supports the Council’s plans to encourage walking, wheeling and cycling across the City.

Despite the title of a ‘low emission zone’, the proposals do not address the need to reduce carbon dioxide emissions. Plans that only address pollution are essentially backward looking, whereas we should be looking forward to a future where fossil-fuel vehicles are completely eliminated and levels of all motor traffic are reduced.

Finally, while we recognise that the plan includes proposals to encourage compliance with the new restrictions for vehicles entering the LEZ, it is critical that enforcement is rigorously applied. There have been too many Council transport-related initiatives (e.g. 20mph speed limits, parking and loading restrictions, prohibition of idling stationary vehicles) that have foundered due to lack of effective enforcement. In the case of idling vehicles, it would be clearly wrong to turn a blind eye to such behaviour while at the same time introducing the significant controls required by the LEZ.

Finally, we note that the enforcement regime will be based on the use of automatic number plate recognition (ANPR) cameras. From our review of Appendix 7 of the report presented to the 17 June 2021 Transport and Environment Committee meeting, we note that the recommended approach is to install these cameras on only 16 routes of the identified 48 entry points to the City centre LEZ. One mobile unit will cover the other 32 entry routes. Given that the LEZ is intended to operate 24/7, we are concerned that this approach will affect the levels of compliance required for the LEZ to achieve the intended reduction in atmospheric pollution and health benefits for those living and working within the City centre. We are further concerned that this approach will encourage the drivers of non-compliant vehicles to use the non-arterial routes to avoid detection thus increasing traffic further in the many residential streets bounding the proposed LEZ. We believe that to achieve the required compliance for the success of the LEZ, it is critical that enforcement is rigorously applied. There have been too many Council transport-related initiatives (e.g. 20mph speed limits, parking and loading restrictions, prohibition of idling stationary vehicles) that have foundered due to lack of effective enforcement. We do not believe that the currently proposed arrangements are adequate.