Zero Emission Zone consultation: help responding

Are you meaning to respond to the consultation on the proposed Zero Emission Zone in Oxford city centre, but find that you keep putting it off because it’s complicated? Procrastinate no longer – we have done the hard labour for you.

Here is an editable Word file with all the questions and our suggested answers, or if you prefer, just scroll down this page to see the text of the document. 

Oxford City Council and Oxfordshire County Council are proposing to introduce the world’s first Zero Emission Zone in Oxford city centre. The proposal would see diesel and petrol vehicles banned from Oxford city centre in phases, starting with some vehicle types and a few streets in 2020, and – as vehicle technology develops – moving to all vehicle types across the whole city centre in 2035.

Our main intention here is to enable LCON members to express their views while encouraging a large positive response to the consultation – bearing in mind that the worst outcome would be a negative public response that discourages the councils from proceeding. If you have very limited time, please consider just answering the mandatory questions.

There are 17 questions (copied below). Some are mandatory (marked below in bold and with an asterisk*). The format varies from making a simple choice from a spectrum of responses (e.g. agree, disagree, don’t know) through to the opportunity to set out answers and ideas within an expandable text box.

Questions 1, 2, 3, 6, 9, 14,15,16 are mandatory. None of these require comments  – all are single responses to the question.   There is the opportunity to comment in the other, non-mandatory questions.

1. How important is it to tackle poor air quality in Central Oxford? *

We suggest: Very important

2. Are the proposed ZEZ zones appropriate? *

We suggest: Either ‘Yes’, or ‘No, should be a larger area’

3. The draft proposal proposes to exclude non-zero emission cars, taxis, buses and Light    Commercial Vehicles (LCVs) in the red zone in 2020. Do you agree with this proposal? *

We suggest: Strongly support

4. The draft proposal proposes to exclude non-zero emission cars, taxis, buses and LCVs in the red zone in 2020. What issues do you think this will result in for:

  • Businesses
  • Residents and visitors
  • Public transport providers   (text box for answer)

We suggest: You could say ‘no issues’ or skip the question; or you might consider saying that the small size of this first zone risks making it hard for people to experience the benefits, or risks perpetuating the public health crisis air pollution presents. You could suggest that more monitoring should take place, particularly around the ring road, as it is not only the city centre where pollution is above legal limits. For health reasons, the monitoring should accurately include PM2.5 and PM10 particles. These will continue to be produced by electric vehicles and underline the importance of reducing traffic levels.

5. The draft proposal proposes to exclude non-zero emission cars, taxis, buses and LCVs in the red zone in 2020. What opportunities do you think this will result in for:

  • Businesses
  • Residents and visitors
  • Public transport providers   (text box for answer)

We suggest:

I/We consider air pollution in Oxford, and the UK more generally, a public health crisis. As such, compliance with legal limits should be the overriding consideration. Where areas are non-compliant with legal limits, simple cost-benefit calculations may not be appropriate.  Whatever option is taken forward, targeted measures should be put in place to ensure limits are not breached, to take effect by 2020.

The ZEZ proposed from 2020 will create an (albeit limited) experience of streets with much reduced air pollution and motor traffic, which will make visiting, shopping and working in that small part of the city healthier and much more enjoyable. It will make it easier for people to interact on a human level. It will open up opportunities for low-emission transport and delivery systems such as cargo bikes to be developed, and showcase Oxford as a place where low-carbon technology is welcome. These improvements should build capacity and encourage a positive response to the widening of the ZEZ in 2025.

6. The draft proposal proposes to exclude non-zero emission cars, taxis, buses and light commercial vehicles (LCVs) in the orange zone in 2025. Do you agree with this proposal? *

We suggest: Strongly support

7. The draft proposal proposes to exclude non-zero emission taxis, buses, LVCs and cars within the orange zone by 2025. What issues do you think this will result in for:

  • Businesses
  • Residents and visitors
  • Public transport providers?     (text box for answer)

We suggest: You could say ‘no issues’ or skip the question, or call for the orange zone implementation to be brought forward or the zone boundaries widened (especially, we suggest, to take in the Castle area). You may want to highlight the fact that HGVs will still be able to use the ZEZ.

8. The draft proposal proposes to exclude non-zero emission taxis, buses, LVCs and cars within the orange zone by 2025. What opportunities do you think this will result in for:

  • Businesses
  • Residents and visitors
  • Public transport providers?    (text box for answer)

We suggest: It will enable the low-carbon technology developed over the previous five years to be implemented across most of the main shopping area in the city centre, and make the experience of visiting, working and shopping in this area healthier and more pleasant.

9. The draft proposal proposes to exclude non-zero emission cars, taxis, buses and Light Commercial Vehicles (LCVs) in the Green Zone by 2030. Do you agree with this proposal? *

We suggest: Strongly support

10. The draft proposal proposes to exclude non-zero emission taxis, buses, LCVs and cars within the Green Zone by 2030. What issues do you think this will result in for:

  • Businesses
  • Residents and visitors
  • Public transport providers   (text box for answer)

We suggest: You could say ‘no issues’ or skip the question, or call for the green zone implementation to be brought forward or the zone boundaries widened (we suggest it should take in a much broader area approaching the ring road). You may want to highlight the fact that HGVs will still be able to use the ZEZ.

11. The draft proposal proposes to exclude non-zero emission taxis, buses, LCVs and cars within the Green Zone by 2030. What opportunities do you think this will result in for:

  • Businesses
  • Residents and visitors
  • Public transport providers   (text box for answer)

We suggest: Extending the ZEZ to the green zone extends it beyond the shopping area and protects the health of those who live and work in the city centre. This will enable people to experience the benefits of healthier air not just for short periods but for the whole day.

12. The draft proposals intend to exclude all non-zero emission vehicles within the Green Zone by 2035. What issues do you think this will result in for:

  • Businesses
  • Residents and visitors
  • Public transport providers
  • All other vehicles including Heavy Goods Vehicles  (text box for answer)

We suggest: You could say ‘no issues’ or skip the question, or call for the green zone implementation for all non-zero-emissions vehicles to be brought forward or the zone boundaries widened.

13. The draft proposals intend to exclude all non-zero emission vehicles within the Green Zone by 2035. What opportunities do you think this will result in for:

  • Businesses
  • Residents and visitors
  • Public transport providers
  • All other vehicles including Heavy Goods Vehicles?    (text box for answer)

We suggest: You could welcome the fact that HGVs will now be excluded.

14. Do you think that the ZEZ should be extended beyond the Green Zone in the future? *

We suggest: Strongly support

15. Do you think that historic vehicles should exempt from the ZEZ? *

We suggest: Strongly oppose

16. Do you think mopeds/motorcycles should be exempt from the ZEZ? *

We suggest: Strongly oppose

17. What supporting measures do you think should be implemented to assist the introduction of a Zero Emission Zone? (text box)

We suggest:

You could choose from any or all of our ideas below.

I/We strongly support the introduction of support measures and incentives proposed by the consultation.  Support measures and incentives should also look at pedelecs for urban cargo delivery , alongside the freight consolidation centre (p9).

There should be encouragement for EVs in the short term while public transport vehicles are upgraded, for example by providing free parking in the ZEZ as proposed – but the overall aim should be to reduce individual car use and greatly increase healthy modes of transport alongside public transport.

The charging points for electric vehicles should all be powered by green electricity, otherwise our pollution will just be replaced with pollution elsewhere in the country.

The limited impact on PM emissions suggests priority should also be given to encouraging modal shift, particularly to cycling and walking.

  • A significant increase in fully segregated cycle lanes would encourage more people to cycle as they would feel safer. The provision along Marston Ferry Road is an exemplar of the standard required.
  • The city centre will have a more pleasant and healthy environment, so this should encourage more people to both walk and cycle, particularly if good access to public transport is also provided.
  • A reduction in central Oxford car parking places, and a significant increase in bicycle parking, would encourage a modal shift.
  • Park and Ride arrangements should be made simpler, more consistent and priced to encourage use

It may be worth considering further trade-offs and nuances within options that could increase health and environmental benefits whilst limiting costs. For example, it is conceivable that a choice could be made between:

  • Requiring bus fleets to upgrade earlier, with costs ultimately being passed on to residents and / or local businesses (e.g. through parking charges or other taxes or rates). Whilst this would create more costs for residents on one hand, on the other hand they would benefit from reduced costs by not having to replace vehicles at the earlier date.  OR
  • Requiring earlier car upgrades, but allowing a longer timetable for bus upgrades, with added support measures and incentives e.g. free parking for EV vehicles. In this context we believe it is worth investigating the assumptions used about modal shifts (p.41 Feasibility and Implementation Report), as we believe the limited geographical scope of all boundaries could well encourage more modal shift to offset the costs of earlier car upgrades.

Further, the potential for the ZEZ to operate only at certain times of the day is mentioned (p6) but not explored further in costing the options.  Whilst data availability may make it difficult to calculate the impact of timing restrictions, it seems obvious this could aid the balance between public health benefits and business requirements in the short term.

 

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