newcastle / gateshead lez

Development, Transport & Environment

Newcastle / Gateshead LEZ Newcastle / Gateshead Low Emission Zone Feasibility Study

September 2013

Newcastle / Gateshead LEZ May 2013

Quality Management

Quality Management

Job No CS/054827-01

Project Low Emission Zone Feasibility Study

Location Newcastle / Gateshead

Title Newcastle / Gateshead Low Emission Zone Feasibility Study

Document Ref Final Issue / Revision 2

Date September 2013

Prepared by 1 N Bryan Signature (for file)

Prepared by 2 A Key Signature (for file)

Checked by S. Clarke Signature (for file)

Authorised by S. Clarke Signature (for file)


Contents

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Contents 1. Executive Summary 1

2. Introduction 2 2.1 The Commission 2 2.2 Newcastle University Involvement 3

3. Background 5 3.1 Low Emission Zones (LEZs) 5 3.2 Air Quality - Targets 5 3.3 Air Quality - Health 6 3.4 Air Quality Management Area (AQMA) 8 3.5 Vehicle Emission Standards 11 3.6 Local Policy 15

4. Review of Best Practice 17 4.1 Effectiveness of LEZs 17 4.2 Operation of Existing LEZ’s 19 4.3 Aim of an LEZ 24 4.4 Public Acceptability 24 4.5 Consultation 26 4.6 Economic Impacts 28 4.7 Implementation 30 4.8 Monitoring 30 4.9 Enforcement 31 4.10 Costs 33

5. Modelling 36 5.1 Tyne and Wear Transport Planning Model 37 5.2 PITHEM Emissions Model 37 5.3 ADMS-Urban Air Quality Dispersion Model 37 5.4 Development of Public Transport (Bus) Model 37 5.5 Analysis 38 5.6 Modelling Limitations 44

6. Options 48 6.1 Option 1 – Newcastle/Gateshead LEZ 48 6.2 Option 2 – Direct Operator Engagement 50 6.3 Additional supporting measures 53

7. Outcomes 55 7.1 Recommendations 55 7.2 Preferred Option 55 7.3 Future LEZ 55 7.4 Future Work 55


Contents

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Appendices Appendix A - Newcastle University Modelling Report


Contents

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Glossary

ADMS Atmospheric Dispersion Modelling System

AQMA Air Quality Management Areas

AM Morning peak period

AURN Automatic Urban and Rural Network

BQC Bus Quality Contract

CERC Cambridge Environmental Research Consultants

COPERT4 MS Windows software program aiming at the calculation of air

pollutant emissions from road transport

DaSTS Delivering a sustainable Transport System

DECC Department of Energy & Climate Change

DfT Department for Transport

DEFRA Department for Environment, Food and Rural Affairs

DPF Diesel Particulate Filters - exhaust technology

DTM Digital Terrain Model

EFT Emissions Factor Toolkit

EGR Exhaust Gas Recirculation

Euro 1,2,3 … applies to Cars and LGV

Euro I, II, III, IV… applies to HGVs and buses

FCC Freight Consolidation Centre

FORS The Fleet Operator Recognition Scheme

FP Tyne & Wear Freight Partnership

GEH Global Environmental Health

GIS Geographical Information System

GRS Generic Reaction Set

HC Hydro Carbons

IGCB DEFRA Interdepartmental Group on Costs and Benefits

IP Inter Peak Period

LA Local Authority

LAQM Local Air Quality Management

LEEZEN Low Emission & Environment Zones in Europe Network

LNT Lean NOX Trap

LTP Local Transport Plan

ME2 Matrix Update Process

NAEI National Atmospheric Emissions Inventory

NAQS National Air Quality Strategy

NMHC Non-Methane Hydrocarbons

NUTS4 Nomenclature of Units for Territorial Statistics – Observatory District

and Unitary level

OS Ordnance Survey

PCN Penalty Charge Notice

PITHEM Platform for Integrated Traffic, Health and Emissions Modelling

PM Evening Peak Period

PM10 ‘Coarse fraction’ Particulate Matter

PM2.5 'Fine fraction’ Particulate Matter

PT Passenger Transport


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PTE Passenger Transport Executive

PTW Powered Two Wheelers

RGF Regional Growth Fund

RPC Reduced Pollution Certificate

SCR Selective Catalytic Reduction - exhaust technology

SI Statutory Instrument

THC Total Hydrocarbons

TOID TOpographic IDentifier

TPM Tyne and Wear Transport Planning Model

TRL Transport Research Laboratory

TWFP The Tyne and Wear Freight Partnership

UCAP NewcastleGateshead Urban Core Action Plan

VED Vehicle Excise Duty

VKM Vehicle Kilometres


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1. Executive Summary

This report is commissioned by Newcastle City Council and Gateshead Metropolitan Borough

Council to investigate the feasibility of a Low Emission Zone (LEZ) for Newcastle and

Gateshead.

Newcastle University modelled 9 different scenarios containing a Base 2010, a “Business as

Usual” 2021 Base scenario, and several Do Something 2021 scenarios. The scenarios were

based upon changes in traffic composition and modelled using the existing TPM model for

Newcastle and Gateshead.

The LEZ 2 scenario (All vehicles Euro 6/VI) resulted in the greatest decrease in emissions

followed by the LEZ 5 scenario (All buses Euro VI). The modelling results also showed the

existing NO2 exceedences necessitating the respective AQMA’s in Newcastle and Gateshead

may be resolved through “natural” vehicle replacement.

Research into existing LEZ across Europe and modelling outcomes of Newcastle University

have resulted in the recommendation to not go ahead with a Low Emission Zone for

Newcastle and Gateshead.

Enhanced air quality improvements can be achieved through a number of measures including;

the redistribution of traffic via the proposed Newcastle Urban Distributor route, promotion of

sustainable transport modes with development of their infrastructure potentially from Local

Sustainable Transport Funding (LSTF) and through direct operator engagement with Freight

Quality Partnership (FQP) and Taxi Licensing. On a voluntary level, a Bus Quality Contract

(BQC) partnership may be utilised to improve air quality within the region.


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2. Introduction

2.1 The Commission

Capita Symonds has been commissioned by Newcastle City Council to undertake a feasibility

study to determine the appropriateness of introducing a LEZ for Newcastle and Gateshead in

an area which suffers from current exceedences in local air quality standards. It is recognised

that these exceedences are resulting from vehicle borne emissions.

The commission is a collaborative study between Capita Symonds, Newcastle City Council

(NCC), Gateshead Metropolitan Borough Council (GMBC) and the University of Newcastle.

Newcastle University’s main role was providing the quantitative impacts of delivering a LEZ for

Newcastle and Gateshead. The University have utilised the Tyne & Wear TPM model from

which traffic flows for all roads in Tyne & Wear were taken and used to develop the air quality

model and associated tools.

The modelling has identified the specific extents of Newcastle and Gateshead where NO2 levels

are predicted to exceed annual mean objective levels. Through interpreting the model outputs it

has been possible to identify the traffic flow make-up based on Euro emission classification on

each link. This allowed for consideration across the board in order to identify areas of concern

in particular those with high NO2 levels.

At the outset, it was predicted that for this commission the study group would concentrate on

developing a LEZ strategy for the regulation of access by HGV’s and buses. However, this

objective has been reviewed periodically through the life of the commission to ensure any

recommendations put forward are appropriate for the air quality challenges facing Newcastle

and Gateshead within the study area.

The initial key deliverables of this commission are listed below;

1. Undertake a Desktop Review of Baseline Information

The full review was undertaken of the historical information available relating to the designation

of the current AQMA for Newcastle and Gateshead, including the reasoning for the designation

as an AQMA, the causation and the geographical extents. In additional the commission sought

to review the approach adopted by other areas in delivering a LEZ.

The findings of the desk top study will be used to develop an initial presentation to be used

within the first stakeholder focus group including Freight Quality Partnership representatives /

Freight Operators, Large Retailers, Bus Operators, Elected members with Environmental and

Transport portfolios, UTMC management and other relevant Council Officers. The aim of this

group would be to better understand the operational challenges faced with delivering a LEZ and

ultimately achieve a general consensus on the approach to delivering a LEZ within Newcastle &

Gateshead. The operational challenges to delivering a LEZ and the options to meet these

challenges were categorised into the following key themes. It was proposed that a

comprehensive review of each of the key theme would be undertaken, including how other LEZ

met these challenges and the appropriateness for adopting these approaches when delivering a

LEZ for Newcastle & Gateshead.

2. Review of Regulation Requirements


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The initial approach adopted was to consult with NCC and GMBC legal services to establish the requirements for preparing the Traffic Regulation Order for the LEZ. In addition, it was proposed to establish the mandatory infrastructure requirements associated with delivering the LEZ TRO, timescales and costs.

3. Enforcement & Compliance

There are several possible approaches to enforcement of an LEZ including, Automatic Number

Plate Recognition (ANPR), and Mobile Enforcement units. Through consultation with the

respective enforcement agencies for Newcastle & Gateshead it was proposed that Capita

Symonds provide a detailed review of which system is most appropriate for Newcastle and

Gateshead and the challenges to delivery

4. Monitoring

Capita Symonds were also asked to consider the application of a continual programme of

monitoring based on compliance (no. of fines issued) and air quality monitoring. This would

involve regularly analysing what types of vehicles frequently offend and determining why this is.

5. Option Package Appraisal & Costs

The final aspect of the commission was undertaking an appraisal of the options as a “fit” for

Newcastle and Gateshead. The intention was to provide budgetary costs for the delivery of a

LEZ in Newcastle / Gateshead which would include;

a. Design Costs

b. Capital Costs

c. Operational Costs

d. Maintenance Costs

It became clear as the commission progressed that the initial objectives of the commission

would need to be refocused to reflect the stage Newcastle and Gateshead were at in terms of

developing a strategy for implementing a LEZ. The commission was therefore refocused to

address the following challenges;

How can we define the extents of the potential LEZ for Newcastle & Gateshead?

What is the impact of future improvements to vehicle emissions going to have on the

viability of the LEZ for the current air quality issues? Will there need to be a LEZ or will

the issues change, i.e. a reduction in NOX but an increase in other pollutants such as

particulates and how will this affect the approach adopted?

How will the LEZ be incorporated into NCC and GMBC’s wider aspirations outlined in

their emerging Local Development Framework Plan?

The commission has therefore evolved to answer the key questions listed above. In addition,

comprehensive research into current LEZ’s and recommendations on the strategy which should

be adopted for delivery in Newcastle City Centre and Gateshead have been provided.

2.2 Newcastle University Involvement

Newcastle University was initially commissioned to produce the following elements towards the

overall goal of the feasibility study:


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1. A traffic emission inventory, by vehicle type and fleet age for Nitrogen Dioxide,

Particulate Matter and Carbon Dioxide, for Newcastle and Gateshead Air Quality

Management Areas (AQMAs);

2. A baseline assessment of existing air quality across the Newcastle and Gateshead

AQMAs, for Nitrogen Dioxide (NO2) and Particulate Matter (PM);

3. A baseline source apportionment analysis of emissions within the AQMA areas;

4. The remodelling of air-quality to show the effectiveness of the proposed LEZ for two

time periods (2 years and 5 years after implementation). Remodelling to include the

effects of road impacts and potential displacement of vehicles;

However, this document presents final work that differs slightly to the original outlined in the

study proposal. The primary difference being that, rather than remodelling two future time

periods of the selected LEZ option, multiple LEZ options are presented for a single, future year

period (2021). Additionally, the potential for displacement of vehicles from the LEZ areas has

not been fully addressed in the modelling work to date.

These changes were agreed with the client and primarily a result of:

issues in the initial development of the baseline assessment model; and

major changes to the emissions factors used during the study period, leading to

subsequent re-development of all original modelling;

The assessment procedure outlined above falls within the scope of the Screening and

Intermediate Assessment guidance for Emissions and Air Quality Impact Assessment outlined

in DEFRA’s ‘Local Air Quality Management Practical Guidance 2: Practical Guidance to Local

Authorities on Low Emissions Zones’.


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3. Background

3.1 Low Emission Zones (LEZs)

A Low Emission Zone or LEZ may be defined as a pollution control scheme, where certain

vehicles are forbidden to enter, or charged to enter a particular area. It aims to accelerate the

uptake of low emission vehicles which will affect both the zone itself, and the wider fleet. As the

aim of an LEZ is to reduce concentrations of air-pollutants within its boundaries, generally those

vehicles with the largest gross contribution to emissions are targeted initially.

Many early LEZ (pre-2005) were aimed solely at reducing particulate matter from heavy duty

vehicles, as this was the most cost effective way of implementation, and particulates were a

primary health concern. However, the improved availability of de-NOX technologies across all

vehicle sectors has enabled more recent proposals to cover both PM and NOX. Given that the

AQMAs in Newcastle/Gateshead are declared for NO2, the focus of this study has been on LEZ

options that aim to reduce NOX, whilst being mindful of the ‘exposure reduction’ policy for

particulate matter. Indirectly, measures introduced to combat NOX and NO2 emissions will also

have an effect on Ozone (O3) concentrations, due to complex photochemical reactions between

these pollutants.

3.2 Air Quality - Targets

Legally binding limits and exceedence values for pollutants are, presented in The Statutory Instrument (SI) ‘Environmental Protection: The Air Quality Standards Regulations SI 2010’ and set down in EU Directive 2008/50/EC for the United Kingdom.

Table 3.1 shows the current scheduled pollutants from the Air Quality Standards Regulations

associated with road transport, the limit values associated with pollutants and the averaging

periods used in assessment.

Table 3.1 Key transport-related pollutants and relevant limit values (from Environmental

Protection: The Air Quality Standards Regulations SI 2010 No. 1001, Schedule 2,

Regulation 17(1) and (2))

Pollutant Averaging Period Limit Value

Nitrogen Dioxide (NO2) 1-hour

Calendar Year

200 μg/m3 not to be exceeded more than

18 times a calendar year

40 μg/m3

Particulate Matter

(aerodynamic diameter

<10μm) (PM10)

One day

Calendar Year



40 μg/m3

Particulate Matter

(aerodynamic diameter

<2.5μm) (PM2.5)

Calendar Year 25 μg/m3 (target for 1

st January 2005.

Tolerance limit of 20% of this value

commences 11th

June 2008, and

decreases the next 1st January and every

12 months thereafter by equal annual

percentages to reach 0% by 1st January

2015)


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Carbon Monoxide (CO) Maximum 8-hour daily mean 10 mg/m3

Sulphur Dioxide (SO2) One hour 350 μg/m3 not to be exceeded more than




Benzene (C6H6) Calendar Year 5 μg/m3

Lead (Pb) Calendar Year 0.5 μg/m3

Changes in both vehicle fuel and emission control technologies have lessened the impact of

transport on local concentrations of all but three of the pollutants to within limit values. The three

pertinent pollutants are; Nitrogen Dioxide (NO2), ‘coarse fraction’ Particulate Matter (PM10) and

‘fine fraction’ Particulate Matter (PM2.5).

The ‘Environment Act’ of 1995 paved the way for the introduction of the ‘National Air Quality

Strategy’ (NAQS). This document provides an overview of UK Government policy towards

achieving the ambient air quality standards. It is recognised within the strategy that national and

international efforts are required to reduce pollution. However many local air quality issues are

caused by transport, especially road transport, and Local Authorities (LAs) have a major role to

play in their amelioration.

A statutory duty is placed on Local Authorities within England via the Environment Act to manage local air quality within their areas, through a regime of regular monitoring and assessment against the air quality objectives. Where it is considered likely that a particular objective will not be met, the LA should declare by order an ‘Air Quality Management Area’ (AQMA). The LA should subsequently proceed to develop and implement an ‘Air Quality Action Plan’ to achieve compliance in that area. Each AQMA is both defined by its geographic extent, and the pollutants for which exceedences are expected to occur. ‘Policy Measure G’, outlined within NAQS, specifically addressed the suggested implementation of low-emissions zones in London (now implemented, albeit in a different form to that originally envisaged in the NAQS) and seven other urban areas in the UK – including Newcastle.

The Local Government Association, Localism Bill has significant fines associated with it should the UK fail to meet its EU air quality limits. The Government’s localism agenda threatens to reduce the top-down governance of LAQM whilst also introducing the potential for EU fines to be passed to local authorities where limit values are exceeded.

3.3 Air Quality - Health

It is widely documented that poor air quality can have an adverse effect on human health. Air

quality is affected by numerous anthropogenic sources from point sources such as incinerators

or coal power plants to mobile sources such as road traffic or diffuse sources such as

households or smokers. Road traffic though is one of the worst offenders and is thought to be

one of the biggest contributors to CO and NOX pollutants in the air. The main concerns for

Newcastle and Gateshead are Particulate Matter and NOX and their associated health effects,

see Table 3.2.


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Table 3.2 Pollutant’s Health Impacts

Pollutant Health Impacts

Particulate Matter (PM10) Can affect central nervous system

Can affect reproductive system

Can cause or worsen cardiovascular

diseases, heart attacks or arrhythmias

Can cause cancer

Can cause premature death

Nitrogen Oxides (NOX) Can affect the liver, lungs, spleen and

blood

Can worsen lung diseases increasing the

risk of respiratory systems and increased

susceptibility to respiratory infection

The Committee on the Medical Effects of Air Pollutants (COMEAP) estimate that on average up

to 24,000 people in the UK die prematurely every year as a result of short-term exposure to air

pollution and thousands more are hospitalised (COMEAP (2009) Long-Term Exposure to Air

Pollution: Effect on Mortality. A report by the Committee on the Medical Effects of Air

Pollutants).

It estimated that particulate matter reduces life expectancy by around seven to eight months,

averaged over the whole population of the UK. This figure is an average and for individuals who

are particularly sensitive and are exposed to the poorest air quality the reduction in life

expectancy could be as high as 9 years. The Department of Health commissioned work from

the Institute of Occupational Medicine to compare the benefits of eliminating man-made PM2.5

with the elimination of motor vehicle traffic accidents and the elimination of exposure to passive

smoking. The results are shown in Table 3.3 below.

Table 3.3 Comparison of the benefits of reducing PM2.5 by 10 µg/m3

Reduction in PM2.5

Elimination of Road Traffic Accidents

Elimination of Passive Smoking

Expected gain in life expectancy 7-8 months 1-3 months 2-3 months

These health impacts can be aided by Local Authorities who in fact have some devolved

funding to tackle health problems. Hence, air quality and its associated health problems needs

to be made more of a priority in order to tackle the issue.

Currently there are no health based quantification figures or costs for air quality in Newcastle

and Gateshead. There needs to be a better understanding of the public health impact of air

quality in the region to support the prioritisation and funding of air quality as a public health

concern. If national figures are applicable to Newcastle and Gateshead air quality may cause

similar or greater levels of mortality and morbidity as passive smoking, road traffic accidents or

obesity.


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3.4 Air Quality Management Area (AQMA)

Historically a number of AQMAs have been declared by Newcastle City Council. These have

included:

1. The City Centre,

2. Quayside, adjacent to the A1058 Jesmond Road/Cradlewell,

3. Blue House Roundabout and

4. Areas of the A189 and B1318 Gosforth High Street.

The three former, and the two latter AQMAs now currently form two larger AQMAs, both

declared for exceedence of the NO2 annual mean standard (i.e. 40 μg/m3 from Table 3.1).

Within this study, the two areas are colloquially referred to as the Newcastle City Centre and

Gosforth AQMAs.

There are two AQMAs currently declared within Gateshead; Gateshead Town Centre and an

area adjacent to services on the A1 (M) at Birtley in the south of the region. As with Newcastle,

both of these areas were declared for exceedence of the NO2 annual mean standard. Within

this study the two areas are colloquially referred to as the Gateshead and Birtley AQMAs.

In support of the declared Air Quality Management Areas, and subsequent Air Quality Action

Plans, two air quality monitoring stations are run by Newcastle City Council – one sited in the

city centre, adjacent to the council offices at Newcastle Civic Centre, and one to the east of the

city centre at Cradlewell. Both of these monitoring stations form part of the UK’s Automatic

Urban and Rural Network (AURN) for air-quality. Data from these sites has been used in

support of the modelling work undertaken.

Both councils also possess and operate a number of non-AURN monitors for various pollutants,

and undertake regular assessments of NO2. Data from non-fixed sites has been made available

to Newcastle University, by both Gateshead and Newcastle City Councils, although it has not

been used directly. Figure 3.1 below highlights the current AQMA’s in operation in Newcastle

and Gateshead.


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Figure 3.1 Declared Air Quality Management Areas (AQMAs) in Newcastle and Gateshead

with all roads and locations of Automatic and Rural Network monitoring (AURN) sites

shown

Newcastle and Gateshead Councils recognise the inter dependency of their two areas, in

particular their economic importance to the North East of England as a whole, and the present

need for sustained economic growth. A coherent and combined approach to local development

planning is given in the joint ‘NewcastleGateshead One Core Strategy’. The urban core of

NewcastleGateshead is recognised as possessing ‘high levels of accessibility and

sustainability’, focused on the ‘government, higher education, business, shopping, leisure and

tourism’ sectors. In order to focus development of the ‘One Core Strategy’ a key ‘Urban Core

Area’, encompassing both Newcastle and Gateshead’s historic centres, has been identified.

This Core Area, shown in Figure 3.2, has been adopted in the Council’s joint ‘Urban Core

Action Plan’ (UCAP), and shows a high degree of overlap with the Newcastle City Centre and

Gateshead AQMAs.


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Figure 3.2 Newcastle and Gateshead Urban Core Area

Given the overlap between the core area, and the central AQMAs, the ‘Urban Core Action Plan’

puts forward a number of Objectives and Policy Options that would potentially impact or

influence the design of any Low Emission Zone (LEZ) options. Transport-related Objectives and

Options include:

‘Objective 6’: The adoption of a general prioritised hierarchy of travel modes within the Core

Area (in order: Walking, Cycling, Public Transport (including taxis), service vehicles and general

traffic). This objective influences subsequent policy options, including;

‘Policy Option 7: Pedestrians and Cycling’, advocating the greater prioritisation of

pedestrians and cycling infrastructure at the expense of general car traffic;

‘Policy Option 8: Public Transport’ inclusive of measures:

o for buses including, freeing up road space through priority measures, utilising

Urban Traffic Management and Control (UTMC) systems to improve journey

time reliability and services generally, working with bus operators to reduce

carbon and other emissions;

o for vehicles including, rationalising movements of vehicles around Newcastle

Central Station, exploring relocation of Newcastle Coach Station to Central

Station to form a transportation hub and interchange, introducing ‘layover’


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facilities for coaches attending city centre events and improving facilities for

taxis;

‘Policy Option 9: General Traffic, Parking and Servicing’, including:

o Traffic routing improvements through use of UTMC and focusing of traffic

entering the centre onto strategic routes along the A189, A167 and A184

o Freight via introduction of ‘freight consolidation’ methods for the city centre and

prioritisation of freight traffic over general car traffic, and reducing car traffic to a

‘more sustainable level’;

o Development of a comprehensive parking strategy, including long-stay and

peak-demand, park-and-ride options out of the Core Area, accommodation of

short and medium stay parking off-street within the Core Area and a general

reduction of private, non-residential parking for commuters.

The original LEZ feasibility study brief suggests that the following, example measures are within

the general scope of a low emission strategy for Newcastle and Gateshead:

Demand management actions;

Bus priority lanes;

Bus quality partnerships;

Freight quality partnerships;

Electric vehicle charging points.

Whilst these measures are not directly covered in this document, the detailed design and

assessment of any LEZ options affecting the NewcastleGateshead Urban Core Area must be

considerate of, and complementary to, the LTP and UCAP proposals.

3.5 Vehicle Emission Standards

Within the European Union (EU), vehicle emissions are controlled at source through the

application of the ‘Euro Standards’, which proscribe set limits by pollutant on tailpipe emissions,

over a particular test ‘drive cycle’. Meeting these limits is required for type approval of new

vehicles being sold within the EU. Initially the standards covered only Carbon Monoxide (CO),

Hydrocarbons (HC), NOX and Particulate Matter, but have subsequently been expanded to

cover Total Hydrocarbons (THC), Non-Methane Hydrocarbons (NMHC), Total NOX, and

particulate number and/or smoke.

DEFRA guidance on LEZs recommends that LEZs implemented from 2010 and 2012 should

consider higher standards than Euro 3/III as a minimum. However, ‘local source apportionment’

should be used to identify target vehicles.

Whilst the implementation of the standards has been instrumental in reducing urban pollution,

there has been concern in recent years that ambient NOX and NO2 concentrations adjacent to

roads have not reduced in commensurate fashion with the NOX emissions standards, nor have

previously modelled air-quality benefits materialised. The ‘Science for Environmental Policy’

bulletin of the European Commission DG Environment, recently stated that ‘the most recent

Euro 5 standard, adopted in 2009… did not produce the desired reduction in on-road

emissions’.


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3.5.1 Present and Future NOX Emissions

The UK vehicle speed-related emissions factors for NOX were based on the findings of a series

of reports produced by the Transport Research Laboratory (TRL), on behalf of the Department

for Transport (DfT).

3.5.2 Retrofitting Vehicles

In addition to the application of emission control technologies as standard to new vehicles,

existing vehicle fleets may be ‘retrofitted’ with Diesel Particulate Filters (DPF) or Selective

Catalytic Reduction (SCR) exhaust technologies.

For LEZ modelling, there is a need to understand how such retrofitted technologies impact

emissions from older vehicles. The latest Emissions Factor Toolkit (EFT) incorporates

emissions factors that suggest better NOX performance from retrofitted Euro II, III and IV buses,

than for new Euro V SCR buses at speeds below 35km/h. Data for retrofitting of heavy vehicles

other than buses is limited, and these are not considered in the latest EFT.

Retrofitting also leads to the potential of a vehicle meeting one set of standards for a particular

pollutant, but not for others (e.g. a retrofitted DPF may mean that a bus meets Euro III or IV for

PM, but not for NOX). This has implications for LEZ design if a ‘split’ approach is taken

regarding different pollutants.

Examples of retrofitting for NOX reduction to meet LEZ criteria include Phase 5 of the London

LEZ (implementation in 2015). As of 13th February 2013, this has been amended to only apply

to TfL operated buses in 2015, rather than heavy duty vehicles, but will involve the retrofitting of

900 EURO III buses with SCR systems, replacement of another 900 EURO III buses with

EURO VI equivalents and the introduction of 600 hybrid buses by 2015 (with a further 600

introduced in 2016). It is estimated that the revised scheme will still ‘deliver 75% of the NOX

reductions of the original scheme’.

3.5.3 Emissions Standards

Euro 6 is the highest current diesel engine emission standard being targeted by the European Commission. From January 2014 all new trucks and buses must meet these stringent levels. Since 1993, when the very first 'Euro 1' legislation was introduced, the EU has regulated the amount of pollutants coming out of the tailpipe of a diesel engine. In particular, the Commission identified two key constituents within the exhaust stream – oxides of nitrogen or 'NOx', and Particulate Matter or 'PM' as being harmful, and which needed to be controlled and reduced. As a result, over the past 20 years, European engine makers have invested heavily in developing new components, which has seen the levels of NOx and PM (as well as other elements such as unburned hydrocarbons) in the exhaust of all new diesel-engine trucks and buses falling dramatically. Each step has seen a technology leap.

2001 – Euro 3

In the third phase of the emissions legislation, engines were required to meet their emission levels during actual on-road driving. A 'transient' test cycle (which in part, mimics on-road operations) was also introduced along with a split two-phase implementation process for new type approvals one year ahead of new vehicle registrations.


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2006 – Euro 4 As exhaust limit values continued to fall even lower, after-treatment systems were required for the first time. Two alternative strategies using either selective catalytic reduction (SCR) systems or cooled exhaust gas recirculation (EGR) were adopted by manufacturers. The new standards also required on-board diagnostics (OBD) to monitor the engine's emission control and alert the operator to any fault within it. In some cases the OBD could even limit power/torque if the fault was found to be due to tampering with the NOX control system.

2009 – Euro 5

Introduced just three years after Euro 4, Euro 5 imposed even further reductions in NOX and PM as well as other emissions. The preferred solution for truck and bus manufacturers was to use improved versions of the SCR or EGR systems they had adopted at Euro 4 in order to maintain fuel consumption levels while offering a cleaner exhaust.

2014 – Euro 6

The lowest levels set for emission levels yet, it is expected that most manufacturers will adopt a combination of both SCR and EGR, together with a diesel particulate filter (DPF), to meet the new EU regulations. Such has been the response of the manufacturers to the challenge of reducing exhaust emissions that the air coming out of the tailpipe of a Euro 6 diesel engine will be cleaner than ever before, with permitted NOX levels reduced by 75% compared with the current already-low Euro 5 standard. And due to changes governing the way particulates have to be measured, the reduction in PM will be closer to 99%.

3.5.4 The Challenge of Euro 6

To ensure that Euro 6 powered vehicles meet the legislation in day-to-day operation, the EU has included new features in the legislation that drive additional improvements for engine manufacturers:

With the introduction of the Euro 6 regulation, this is the first time a 'World Harmonised Test Cycle' has been used for engine certification. This move means that the engine testing is much closer to real-world vehicle operation than the previous more theoretical cycles. Ensuring the after treatment operates efficiently is more difficult under this new testing regime, with efficiency being closely linked with the heat management of the system;

The addition of particulate count measurement has driven all manufacturers to use particulate filtration in their exhaust systems. The previous measurement process is no longer capable of accurately measuring the extremely low particulate levels required by Euro 6. New measuring equipment has been specified for test cells to get to the required ultra low levels and complete the engine certification;

The EU is introducing portable emissions measurement systems for in-service vehicle testing. This is to ensure that they remain compliant under normal operating conditions during the useful life of the vehicle, which is seven years or 700,000km;

The in-service testing will be backed up by more stringent on-board diagnostic (OBD) regulations, measuring exhaust emissions during vehicle operation. A threshold on particulate emissions will be included for the first time. Tougher emissions and anti tampering limits will be introduced. There is a phasing in period of OBD limits from 2013 to 2015, which needs to be managed beyond the initial legislated date;

Manufacturers are required to issue repair and maintenance information to ensure emissions and OBD compliance is sustained throughout the vehicle life. Detailed product


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and service information needs to be published to enable the effective repair of the engine and after treatment system;

The enforcement of OBD failures is dependent on individual EU member states and how they implement it into law. This could involve roadside checks or be part of periodic inspections such as the MOT in the UK. An active malfunction indicator lamp (MIL) or long-term fault could result in failure of the periodic inspection or even fines for the operator;

The introduction of a lower ammonia emission limit – ammonia being a by-product of the selective catalytic reduction (SCR) exhaust after treatment process;

The inclusion of a crank-case emission limit if a closed system is not used. Any blow-by oil emissions are now counted in the overall emissions measurement.

Euro 6 has required significant investment in product development and methodologies for

testing vehicle emissions. The additional requirements set out by the EU should bring about

real-world improvements in air quality and will improve on the estimates of real world emission

reduction though improvements in test cycles (Public Service Review, 2013).

Table 3.4 and Table 3.5 show the introduction dates for vehicle classes and the vehicle

distribution for 2012 if we assume the same time lag between introduction of Euro 6 and 50 %

of passenger cars being Euro 6 compliant, this will be reached in 2021 the proposed

introduction of the LEZ for Newcastle/Gateshead.

Table 3.4 Euro Class Standard Introduction Dates

Euro 1 Euro 2 Euro 3 Euro 4 Euro 5 Euro 6

Passenger Cars

July 1992 Jan 1996 Jan 2000 Jan 2005 Sept 2009 Sept 2014

Light Commercial Vehicles (N1- I)

Oct 1994 Jan 1998 Jan 2000 Jan 2005 Sept 2010 Sept 2015 (diesel only)

Light Commercial Vehicles (N1-II & III)

Oct 1994 Jan 1998 Jan 2001 Jan 2006 Sept 2010 Sept 2015 (diesel only)

Trucks and Buses

1992 1995 1999 2005 2008

Motorcycles 2000 2004 2007

Mopeds 2000 2004

Table 3.5 Euro Class Vehicle Distribution

2012 Petrol Cars

Diesel Cars

Petrol LGV

Diesel LGV

Rigid HGV

Artic HV Bus

Pre-Euro 1

0% 0% 0% 0% 0% 0% 0%

Euro 1 1% 0% 1% 1% 0% 0% 1%

Euro 2 7% 2% 7% 7% 7% 3% 9%

Euro 3 (with DPF)

12% 19% (4%) 21% 21% 27% 26% 30%

Euro 4 (with

52% 33% (8%) 52% 52% 18% 19% 18%


15

DPF)

Euro 5 28% 34% 19% 19% 49% 52% 42%

Euro 6 0% 0% 0% 0% 0% 0% 0%

3.6 Local Policy

Tyne & Wear LTP contains several wider policy measures that compliment the aim to reduce emissions and improve air quality. These include:-

Policy UC8 Freight and Servicing

The Tyne & Wear LTP includes the proposal for a Freight Management Area Boundary. The Urban Core Distributor Roads forms a natural boundary and the area within it can be influenced and controlled by UTMC. As the boundary is based on the UCDR, the Freight Management Area aligns with other transport policies contained within the LTP, and the objective to enhance the pedestrian and cycling environment within the central area by reducing traffic flows and speeds. The Freight Management Area excludes major parks and residential areas. The Freight Management Area is also similar to the Newcastle City Council Extended AQMA and therefore supports the need to reduce emissions in this area. This measure supports Policy UC8 Freight and Servicing, which aims promote sustainable freight movement and minimise the impact on the environment and quality of place.

Tyne & Wear FQP

The Tyne and Wear Freight Quality Partnership (TWFQP) has been in operation since 2005. Working with freight operators has facilitated the understanding of problems and issues related to freight movement, enabling the initialisation of a coherent strategy and mechanism to tackle the identified issues and problems. The Partnership brings together transport operators, industry representatives, local authorities, the Highways Agency and key local stakeholder groups to facilitate delivery of an action plan which is targeted at improving the efficiency, safety and sustainability of freight movement.

The TWFQP fully endorses a Fleet Operator Recognition Scheme (FORS) which is an

accredited scheme for businesses operating transport fleets of all sizes. It offers impartial,

independent advice and guidance to motivate them to improve their lawfulness and

environmental, social and economic performance. Unlike many other membership and

recognition schemes, FORS membership gives an edge when bidding for work, as it provides

evidence of performance against the many regulatory and environmental requirements facing

the industry. Incentives to join the Tyne and Wear FORS include;

Training, covering topics such as Safety, Fuel Efficiency, PCNs and Urban Diving,

most of which is CPC accredited.

Driver behaviour profiling, detailing the cost of vehicle accidents and fuel usage to

companies. In-vehicle driver profiling motivating drivers to improve and save money.

Fuel advice programme, FORS offers practical tools and advice to help cut costs,

improve fleet’s efficiency, and reduce the impact of freight transport on the

environment.

Driver licence check service, freeing up time spent by operators on checking that

drivers are on the road legally.

Penalty Charge Notice (PCN) assistance, helping reduce the number of PCNs

vehicles receive and limit the impact on freight operators.


16

Regular industry updates, FORSight newsletter and regular bulletins help operators

keep ahead of competitors by understanding new developments in the freight sector

Discounted Products are available through the buying powers of the Freight Quality

Partnership (FQP) and targeting operators collectively (TWFP, 2013)

Bus Quality Contract / Bus Voluntary Partnership

Nexus, on behalf of the Tyne and Wear Integrated Transport Authority (ITA) and the area’s five

local councils, are exploring the respective benefits of a new Voluntary Partnership Agreement

with bus companies, and a Quality Contracts Scheme, where all services would be offered

under franchise by a single public body. The ITA is keen to investigate a new model which will

increase the number of people using local buses as well as providing a better service which

delivers greater value for money and cheaper fares for younger people.

Currently the bus companies operate services commercially and therefore decide where and

when 90% of services go and what fares they charge. Some non commercial services (typically

during evenings and weekends), travel to more remote locations are supported by Nexus.

Profits are not generally used to support those remaining routes which, while more lightly used,

nevertheless provide part of a network of essential local services.

A BQC scheme would give local authorities greater powers to obligate operators to upgrade

their fleet to more environmentally efficient vehicles. Key bus corridors running through areas

sensitive to air quality could condition the type of vehicles acceptable to service them e.g.

low/zero emission. Therefore a BQC would provide local authorities with significant powers to

help mitigate emissions specifically propagated by buses. As yet no BQC scheme has been

adopted by PTE/ITA’s outside of London. However the London BQC scheme has been able to

set emissions standards for buses and influence service provision through contractual

obligations.

A Voluntary Partnership Agreement would require local authorities to negotiate with individual

operators to upgrade bus fleets and adopt the latest low emissions technologies. Upgrading bus

fleets has significant cost implications to operators and most phase the replacement/upgrading

of their fleets. From the perspective of the operators it is difficult to see a justifiable financial

return on investing in upgrading vehicles ahead of their natural life cycle for emission reasons.

In this scenario retrofitting would provide the greatest short-term (ahead of the natural vehicle

life cycle) opportunity for reducing vehicle emissions and would need to be encouraged by local

authorities. To encourage operators it is likely that local authorities would need to offer up some

sort of gain by way of bus priority on the highway network or enhancement to bus infrastructure.

This would be at a cost to the local authority and would need to be weighed up against the

quantifiable air quality benefits of reducing emissions.


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4. Review of Best Practice

4.1 Effectiveness of LEZs

There are 152 cities in nine EU countries which have implemented LEZs, with Germany being

at the forefront of their creation. The Low Emission & Environment Zones in Europe Network

(LEEZEN) website currently lists almost 350 applied LEZ controls across the EU, dating back to

2002. However, the vast majority of these controls apply to Euro 4/IV or previous vehicles, or

consider implementation for particulate matter only, with NOX/NO2 reductions viewed as an

‘added bonus’.

Likewise, whilst there is an existing body of literature that has examined the effectiveness of

LEZs, many studies have utilised pre-implementation emissions modelling, rather than post hoc

analysis of monitored air-quality data. There appears to be some evidence that earlier LEZ

feasibility studies may have been optimistic, with expected emissions benefits on paper not

necessarily materialising in concentration reductions in the real world. Many studies have tried

to examine the impacts of the London LEZ, one reported estimated PM10 emission reductions

of 6.6%, and NOX emission reductions of 7.3% by 2012, but also concluded that predicted

changes in concentrations were ‘generally small… and would be difficult to detect in actual

monitoring data’.

A Dutch study (Boogard et al), looking at roadside and sub-urban monitoring data from five

Dutch cities, from one year before and two years after policy implementation, concluded that

‘local traffic policies including LEZ were too modest to produce significant decreases in traffic-

related air pollution’. However, where multiple measures, in addition to the LEZ were

implemented, leading to a reduction in traffic intensity of over 50%, NOX and NO2 levels fell by

39.5% and 13.4% respectively. This is compared to changes across the other sites studied of

between 21.6% for NOX, and 8.4% for NO2. Changes between sites tended to diminish when

meteorological variations are taken into consideration. It is worth noting that the non-linear

relationship of NO2 and NOX concentrations do not necessarily mean that a reduction in total

NOX leads to the same relative reduction in NO2, locations with the highest NOX levels show the

smallest reduction in NO2 as NOX emissions reduce.

Regional UK LEZs formed the heart of ‘Policy Measure G3’, reported by the DEFRA

Interdepartmental Group on Costs and Benefits (IGCB) as part of the NAQS. This policy

considered the hypothetical benefits and costs associated with the introduction of an LEZ in the

central area of Newcastle (amongst seven other cities), during the year 2010, affecting HGVs,

Buses and Coaches, bringing those vehicles to at least Euro II + RCP (Reduced Pollution

Certificate) standard. The IGCB noted that LEZ policy option G3 for the regional cities would

result in ‘significantly reduced’ benefits over the London scheme due to delayed opening of the

LEZs in the regions, in turn leading to ‘less high-polluting, older vehicles relative to the

baseline’. It was also noted that there were lower benefits per tonne of emission produced in the

regional cities due to lower population densities in comparison to London. Both statements will

hold true for implementation of a theoretical LEZ in NewcastleGateshead, the longer the delay

in implementation, the closer to the baseline the LEZ fleet will become, with a commensurate

reduction in potential benefits. Likewise, the population density in the Newcastle and Gateshead

area remains far lower than for London. The DEFRA guidance on LEZs also makes the point

that setting the earliest possible compliance date yields ‘more local air quality and emissions

benefits, but usually at higher costs’.

The IGCB concluded that LEZ options would benefit roadside concentrations in central urban

areas (reducing exceedences in terms of km of urban roads by 0-33% depending on pollutant),


18

potentially reduce noise levels, and possibly have a positive social justice aspect (benefitting

deprived areas adjacent to city centres). However, it was also noted that impacts on human

health and on urban ecosystems (based on critical load assessment) were negligible or not

readily quantifiable. Additionally, LEZ options were also thought to have a ‘potential negative

impact’ on competition, with ‘possible disproportionate effects on small businesses’ (though

more detailed assessment of specific implementation options was recommended to quantify

any impacts). It was noted that LEZ options disproportionally affect fleet operators

‘predominantly or solely‘ operating in covered areas, and those operators requiring specialist

vehicles (usually having longer operating and replacement cycles than regular vehicles). LEZ

operation in turn could distort the second-hand market for vehicles by reducing re-sale values of

older vehicles, affecting operators and leasing companies.

Carslaw and Beevers (2002) note that ‘even ambitious LEZ scenarios in central London

produce concentrations of nitrogen oxides that are achieved through a do nothing scenario only

five years later’, given assumptions on the performance and turnover of Pre-Euro to Euro 3

vehicles in the capital. The DEFRA guidance states that LEZ recommendations should ‘produce

three to four years’ benefits. A similar situation is likely to exist with the introduction of Euro 5

and 6 vehicles in the context of a Newcastle/Gateshead LEZ.

Based on the four conclusions of the DEFRA guidance document, the following

recommendations may be drawn:

1. Appropriate emissions standards for the LEZ must be set to achieve objectives, bearing

in mind costs to operators. Higher standards yield bigger potential reductions. For the

case of Newcastle and Gateshead (or the rest of the UK) this will generally mean

application of either the Euro 5/V or 6/VI standards;

2. When setting a base year for implementation of an LEZ, ‘earlier is better’ in terms of

emissions and local air quality outcomes, at potential greater expense. The decision of

what base year to adopt is an open one, as given the current economic climate ‘later

rather than sooner’ may be more appropriate to allow a greater economic recovery.

3. That after initial introduction of the LEZ, subsequent, more rigorous phases be

considered, ‘otherwise the benefits of the policies will be eroded by natural vehicle

replacement rates’.

4. Emission standards and implementation year need to be balanced against costs,

including ‘the level of action required to achieve the air quality objectives of the AQMA’.

Aside from using compliance with the EURO standards to control vehicle access, an alternative

strategy is that of limiting vehicles simply by age – for example the LEZs in the Swedish cities of

Gothenburg, Helsingborg and Lund limit access to vehicles under 6-8 years old. The expected

lifespan of a fleet-operated heavy-duty vehicle is typically of this order, with DfT statistics giving

the annual number of years since first registration of HGVs in the UK as 7.35 years in 2011,

with just under 3% of annual UK HGV registrations being in the North East region. For buses

the DfT Public Vehicle Survey gives the average age of fleets in English metropolitan areas as

7.9 years in 2011. The economic situation has also lead to the current car fleet being the oldest

in 14 years, with DfT statistics giving the average age since first registration as 7.54 years. A

similar situation exists with light commercial vehicles, where the average age since first

registration is 7.57 years. However, the age of a vehicle does not necessarily give a clear

indication of vehicle emissions as there is the potential to change engines or to fit SCR filter

technology, hence altering expected emissions.

DEFRA guidance also suggests consideration of LEZs based on Vehicle Excise Duty (VED).

This would have the effect of altering the fleet profile for cars depending on engine size and

CO2 emissions, giving a trend towards smaller engines and lower emissions in the LEZ.

Consideration of the handling of alternate fuel vehicles would need to be given. For heavy


19

goods vehicles, using VED would be the equivalent of a weight restriction, again potentially

leading to lower emissions. For light goods vehicles VED is partially based on engine size or

Euro standard already, depending on the tax class of the vehicle. Unless changes to the basis

to VED are made for the car and HGV classes, it is difficult to see how NOX/NO2 issues could

be directly tackled through its use as an LEZ criterion.

4.2 Operation of Existing LEZ’s

4.2.1 Cars

Cities in Austria, Germany, Italy, Norway and Portugal have LEZs which set emission values for

cars. The details of particular schemes are discussed below.

Austria has provided a framework for implementing an LEZ affecting diesel vehicles, although to

date no city has adopted one. There will be subsidies for heavy duty vehicles with

EURO6/"Enhanced Environmentally Friendly Vehicle" standards, when in exchange the use of

an old vehicle is abandoned. Furthermore, there are subsidies for filter retrofitting amounting to

€300 per car. Also, Graz allocated €3000 per hybrid taxi between 2009 and 2010. Currently

Graz’s parking management represents approximately 26,000 parking spaces, of which 15,000

are short-term spaces.

Germany has incentivised car users by offering a grant of €330 for people to retrofit their

vehicles. Drivers in Germany are required to purchase a sticker linked to vehicle emissions and

display this on their windscreen. The stickers are applicable in all LEZ cities and proof of

emissions standards is required when purchasing the sticker. Retrofitting of vehicles is possible

under the sticker scheme as long as a government endorsed particulate trap is used and a

certificate of its installation is presented when applying for a sticker. Enforcement is basic, if no

sticker is visible on a vehicle parked in an LEZ then a penalty is issued, likewise if a vehicle

does meet the LEZ criteria.

In Rome private vehicle traffic is progressively restricted from the periphery towards the centre.

The measures to restrict traffic in the inner city centre are predominantly inspired by tourism

related urban planning. There is a mobility centre providing technical assistance, mobility

advice, and travel plans for companies. There is a car-sharing programme with 109 vehicles, 61

parking spaces and 1,879 active members.

4.2.2 LGV

Austria, Germany, Italy, Norway, Portugal and the UK have introduced LEZ measures targeting

LGVs.

In London, owners and operators of vehicles that do not meet the required standards, see Table

4.1 have a number of options available to them to ensure they comply with the scheme,

including:

Fitting a filter to the vehicle to improve the emissions: TfL recognises accredited filter

modifications from across Europe;

Purchasing a newer vehicle that meets the standards

Reorganising a fleet so that only vehicles which meet the required emissions standards

drive within the LEZ; or

Paying the daily charge.


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4.2.3 HGV

Germany has introduced a distance-based toll for all trucks of twelve tonnes gross vehicle

weight and above. The German Heavy Goods Vehicle Toll Level Ordinance (MAUT), that came

into force on 1 January 2009, assigns each vehicle one of four categories, A to D, based on its

emissions class. The new toll rates mean that trucks with the latest-generation exhaust systems

and those that have been retrofitted with particulate filters pay significantly less than high-

emission vehicles.

In Flanders, Belgium an ecological subsidy has been set up as a financial incentive for

companies investing in environmental projects, including retrofitting existing Euro I, II or III

freight trucks with diesel particulate filters (DPF). To be eligible for the subsidy, the DPF must

either be listed on the Swiss VERT list or have obtained from the Dutch RDW type approval for

wall-flow DPFs (Class A). The total cost, i.e. DPF plus installation, qualifies for the subsidy

which can represent up to 20% of the amount for small- and medium-sized companies, and up

to 10% for larger companies.

Regione Lombardia in Italy has put €10 million aside to subsidize diesel particulate filters

retrofitted on Euro 0 to Euro 2 commercial vehicles (N1, N2 and N3). A single contribution is

limited to €3000. The incentive program started on 1 December 2008 and such retrofit allows

access within the A1 Zone of the Lombardy region Low Emission Zone.

The Dutch environment ministry provides subsidies to heavy-duty vehicles owners to retrofit

them with Diesel Particulate Filters.

The Scottish Government has launched an air quality grant scheme to provide grants to local

authorities for retrofitting vehicles operated by them with emissions reduction equipment.

Sweden is in the process of introducing a national system for type approval of retrofit systems

for heavy-duty vehicles. Environmental zones for heavy-duty vehicles already exist in some

cities in Sweden, mandating operation in the zones only with reasonably new vehicles based on

Euro classes.

Studies conducted prior to the introduction of the LEZ in London found operators would be most

likely to fit exhaust modification or buy new vehicles, though a very clear message came back

that operators would use newer (compliant) vehicles in London and displace older vehicles

outside London. (LEEZEN, 2000-2005)

This may mean that operators in Newcastle and Gateshead may find it challenging and costly to

adhere to a LEZ for Newcastle and Gateshead as their newer vehicles are already in operation

in London.

4.2.4 Buses

Czech Republic, Denmark, Germany, France, Italy, Sweden, UK London, Norwich and Oxford

have introduced LEZ measure targeting buses.

In France a €1300 subsidy is granted for the retrofit of Particulate Filter on buses. It applies to

all buses put into service between 1 January 1991 and 31 December 2000 and covers filter

systems which have been evaluated by the French Environment and Energy Management

Agency (ADEME).


21

Norwich provided funding contributions of over £150,000 for retrofitting of vehicles to help

reduce NOX emissions from older buses operating in Norwich to be achieved through a bus

operator’s agreement.

To complement their LEZ, Berlin has improved public transport bus engines, invested in

compressed gas fuels, restricted car parking in the centre, changed traffic management

arrangements, improved the cycle network and invested in public transport.

Oxford will introduce LEZ for buses entering its city centre. Direct measures to reduce existing

vehicle emissions include:

improving the percentage of newer cleaner vehicles in the vehicle fleets by voluntary

partnership agreements

limiting access in central areas only to cleaner vehicles by establishing a low emission

zone (LEZ)

improving existing flows, by reducing congestion

reducing total flows and relieving congestion

Indirect measures to reduce vehicle emissions may include:

reducing on street parking

reducing travel by private vehicles

Table 4.1 below summarises the various LEZ’s in which cars are subject to

enforcement.


22

4.2.5 Summary

Table 4.1 LEZ's Summary Table

LEZ Area Vehicles

Affected

Standard Scheme Type and Retrofitting Operating

Hours

Enforcement

Graz HGV’s Euro 3 - 2014 Retrofitting allowed if registered with LA. Permanent Manual (Police)

Prague HGV’s Euro 4 - 2013 Annual Sticker/Permit based system. Short

Term permits available for foreign vehicles.

Retrofitting allowed

Weekdays

08:00 – 18:00

Manual

Copenhagen HGV’s

(LGV’s

optional)

Euro 4 - 2010 Sticker based permit system applicable to

foreign vehicles also. Retrofitting allowed but

very specific criteria must be met

Permanent Manual (Police and Parking

Wardens) – Penalty fines are

in line with cost of particulate

filters, up to €10,000

Germany

(Various

Cities)

All

vehicles

Petrol Euro 1,

Diesel Euro 4

Sticker based permit system applicable to

foreign vehicles also. Government certified

retrofitting allowed only

Permanent Manual (Police) – a small fine

and penalty points are issued

Budapest HGV’s N/A Variable entry fee into the City scaled according

to Euro class. Retrofitting is not accepted.

Fee varies

based on time

of day to

encourage off-

peak deliveries

Manual

Rome All

vehicles

Petrol Cars

Euro 2, Diesel

Cars Euro 3, –

2012 HGV’s

All HGV’s banned in PM peak,

LPG/Hybrid/Electric LGV/HGV are exempt.

Retrofitting is not allowed and foreign vehicles

are enforced against

Permanent

with time

specific HGV

bans.

Manual

Amsterdam HGV

(LGV’s

optional)

Euro 4 - 2013 ANPR based system on boundary perimeter.

Retrofitting is allowed but foreign vehicles are

not enforced.

Permanent Camera

Lisbon All Euro 3 -2014 Sticker based scheme displayed on all vehicles. Mon-Sat Manual


23

vehicles Retrofitting is not allowed 08:00-20:00

Stockholm HGV’s &

Buses

Euro 3 –

current Euro 4

– 2016 Euro 5

- 2020

Retrofitting is allowed with approved government

systems. Scheme applies a scaled number of

years permissible to enter LEZ dependent on

first registration date of vehicle. Foreign vehicles

are also applicable.

Permanent Manual

London HGV’s

Buses &

LGV’s

HGV’s Euro 4

-2012, LGV’s

Euro 3 – 2012

Buses Euro 6

- 2015

All vehicles must register with TfL including

foreign vehicles. Retrofitting requires VOSA

certificate to be submitted to TfL

Permanent ANPR


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4.3 Aim of an LEZ

As the existing NO2 exceedences necessitating the respective AQMA’s in Newcastle and

Gateshead may be resolved through “natural” vehicle replacement. It would be preferable to

adopt an approach to an LEZ that establishes a framework so that sustained benefits can be

established but the thresholds could be adaptive to current air quality concerns. A stepped

approach to an LEZ would allow the acceptable Euro class threshold of a vehicle to be altered

over time in line with tightening AQMA/EU criteria.

The predicted benefits would still be subject to concerns regarding differences between stated

performance and actual exhaust emissions associated with individual vehicles. A new

complementary test procedure which reflects real-world emissions is currently being developed

with the help of European experts and is expected to be used for type approval of cars from 1

September 2017 onwards (European Comission, 2013).

A study undertaken by the Norwegian Centre for Transport Research has highlighted the

variation between stated performance and actual real world emissions recorded. From a small

sample of Euro 5 and Euro 6 vehicles comparisons between predicted and actual emissions

were undertaken and these highlighted that whilst Euro 6 vehicles achieved significant

reductions in emissions compared to Euro 5 they were not guaranteed to fulfil their Euro 6

benchmark for emissions. The research summarised that emissions of NOX from new Euro 6

light diesel vehicles may be 5-8 times higher than the limit for type approval.

4.4 Public Acceptability

The feedback that exists in Sweden indicates a fairly positive response to the scheme. The

London study explicitly undertook stakeholder surveys to elicit views on the scheme.

The study investigated the likely response to a London LEZ by freight operators. It undertook

face-to-face and telephone interviews and a questionnaire survey with hauliers/fleet operators.

This found more concerns amongst smaller operators, who often have longer replacement

cycles, and owners of vehicles with specialist bodies (e.g. cement lorries), which also have

longer replacement cycles as these vehicles are more expensive and tend to do less mileage.

Most people questioned responded that they would comply with an LEZ. The most likely

indication of what this response would be were to fit exhaust modification or buy new vehicles,

though a very clear message came back that operators would use newer (compliant) vehicles in

London and displace older vehicles outside London. There was a wide range of responses to

the potential costs of an LEZ, with a general reaction that smaller companies were more

concerned about costs, as they typically had older vehicles and less capital to modify or change

their vehicles.

Overall, the survey indicated that operators would be broadly supportive of a London LEZ.

Operators stressed the need for adequate notification (as early as possible) of any forthcoming

LEZ, so that they could take this into account in planning their vehicle replacement strategies.

The GLA (Greater London Authority transport survey of 1,007 Londoners in Oct 2004 showed a

high level of support for London wide LEZ: 67% expressed favourable opinion. Issues raised

included the significant inequality impact that targeting cars would bring to low income

households, the large socio-economic costs from even a modest scheme and the low cost

effectiveness of their inclusion. Similar acceptability issues were raised with regard to including

LGV’s in a LEZ. This was seen as potentially impacting on a large number of small businesses.


25

A number of London boroughs stated that grant availability would be critical in gaining support

from their members. The main concern raised by small businesses is the increased financial

and/or administrative burden. Cost of retrofit equipment or purchase of new compliant vehicles

and the administrative burden of certification were the main issues raised. Some small

businesses are hard to reach in terms of awareness. They cannot easily be reached through

public information or trade literature.

Larger operators (hauliers/delivery companies) highlighted that if they had to pay to comply with

the scheme, enforcement would have to be strong enough to justify their investment and

provide a decent level of encouragement for other smaller operators to comply. Respondents

also expressed a wish that foreign-registered vehicles would be included in any LEZ scheme,

so that non-UK operators would not gain an operating advantage if exempted.

In terms of how companies would deal with the cost of complying with the LEZ, 38 respondents

to a survey conducted by University of Westminster said that they would pass cost increases

onto customers, while 8 said they would absorb the cost increase. Some respondents felt that

retro-fitting is not a good option for small companies as vehicles have to be off the road while

this takes place.

Many operators foresaw greater problems if LEZ’s were also introduced in other UK urban

areas rather than just in London, as this would reduce the flexibility to move their fleets around

and also result in greater cost increases. Several respondents from firms with large fleets said

that it would cause them significant problems if LEZs were also introduced in other UK urban

areas that had difference compliance arrangements to any London scheme.

In order to overcome the obstacle of stakeholder acceptance of a LEZ a number of measures

need to be considered;

Timely engagement

o Long lead in time this gives an opportunity for the message to reach all

stakeholders and reasons to be discussed and understood.

Health imperative

o Be clear and concise when communicating the need for an LEZ as people may

view this as an effective way to generate income

o Communicate the effects of pollutants on health, and the cost of implementing

the LEZ

Consultation

o Identify key stake holders

Information and dissemination

o Media campaign, explaining the reasons why an LEZ is needed, who will be

affected and what incentives are in place to ease the transition.

Clear and well planned LEZ

o Clear geographic boundary with adequate signing so that people who do not

wish to enter the zone and face charges are able to not do so.

o Why it will apply to the vehicle type/s, who will be exempt

o Use of technology to enforce(ANPR of VED for manual enforcement)

o Mechanism of enforcement (Civil Enforcement Officers)

Although the measures discussed within this report have largely been discussed in isolation,

they are often only successful when implemented as part of a wider strategy or package of

measures. A range of 'sticks and carrots' are required to ensure that measures are successful


26

in achieving their objectives and targets. These supporting measures or policy instruments may

be in the form of additional or alternative public transport services, increases in parking

restrictions or prices, access restrictions for certain types of vehicles, introduction of other fees

and taxes, and awareness campaigns. In the London congestion charging scheme example,

extensive public transport service improvements (buses) were implemented from the first day of

scheme operation. This provided alternative means of travel for people still requiring access to

the zone.

The case studies presented highlight the need for financial incentives in the form of grant

subsidies and a long lead in time with targeted media campaign. Deloitte’s research undertaken

as part of the London LEZ, recommends that cars be excluded from LEZ proposals due to the

very large number of vehicles it would affect, and the fact that the majority of older cars are

owned by low income households and the scheme would thus affect them disproportionately.

Deprivation statistics show, Newcastle has 43 and Gateshead has 20 Super Output Areas in

the most deprived 10% in England (Communities and Local Government, 2010). Bearing in

mind the deprivation statistics, the implementation of measures to reduce and remove all

exceedences should adopt an approach which reduces the financial burden placed upon

residents within the LEZ area and incentivise the transition with grants to be able to gain wider

public support.

The case studies also emphasise the need for suitable alternatives to be available in the way of

alternative vehicular routes and increased provision of public transport to aid with public

acceptability. This is only relevant if private cars are to be included in the LEZ and bus routing

and provision is outside the direct control of LA’s unless a BQC is decided upon by Nexus.

Nevertheless the measures for specification of vehicles operating within the LEZ area can be

pursued through the BQC & FQP. As discussed earlier incentives for small operators and SMEs

would aid the acceptability of the LEZ by this group of stakeholders.

In Newcastle and Gateshead consultation with the FQP, Bus operators through BQC/BVP and

the general public would be essential to establish a workable low cost scheme appropriate for

all stakeholders. The consultation process undertaken prior the implementation of the Norwich

LEZ and London LEZ would also be appropriate for Newcastle/Gateshead.

4.5 Consultation

4.5.1 The London LEZ Consultation Process

The public and stakeholder consultation ran for 12 weeks and TfL used a variety of communication channels to maximise awareness of and participation in the consultation. As well as widely distributing a public information leaflet that was available in a range of languages and formats, the consultation was advertised through a range of channels, including radio, newspaper and outdoor advertising. In addition, consultation materials were also posted on the TfL website and publicised on the GLA website. The consultation process was supplemented by a comprehensive process of engagement with stakeholders. The purpose of this engagement was to ensure stakeholders were well-briefed on the LEZ, hear issues and concerns, answer questions and encourage responses to the consultation. Many key stakeholders, such as the Freight Transport Association (FTA), the Road Haulage Association (RHA) and the Confederation of Passenger Transport (CPT) undertook their own research and surveys of members in developing their responses to the LEZ consultation. TfL also conducted a London wide attitudinal survey of operators, businesses and residents to ascertain how representative the consultation responses were.


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Businesses, operators and the public were encouraged to take part in the consultation by completing a questionnaire that formed part of the leaflet. The questionnaire asked a number of questions about the proposal. In broad terms, the public questionnaire sought opinion on the importance of improving air quality in London; whether air quality is a problem in London, whether respondents supported the introduction of the proposed LEZ; whether the proposed standards for particulates (PM10) are appropriate; whether the standards should be extended to include oxides of nitrogen (NOX) in 2010; and which vehicles should be included in the proposed LEZ. The key stakeholders were chosen because of their importance to the governance of London and the operation of the proposed LEZ and because the proposed LEZ was expected to particularly impact on them and/or their members. It was felt that these particular groups required the opportunity to be further briefed about the proposed London LEZ.

4.5.2 The Norwich LEZ Consultation Process

The measure was implemented in stages beginning with stakeholder consultation in 2005 through to implementation in 2008. Stage 1 assessed users needs and priorities (Aug 2005 – Mar 2006) through consultation with all stakeholder groups involved (i.e. the local authorities, bus operators, emergency services, taxi operators, municipal vehicle fleet operators and local traders etc). There was also some initial direct consultation with members of the public (e.g. through focus groups) asking for their views on a Low Emission Zone. Extensive consultation with bus operators, taxi operators, businesses and the general public was undertaken to elicit views on the scheme. It was paramount that adequate notification was given to both bus and taxi operators of the implementation of a LEZ, in order for operators to take this into account in planning their vehicle replacement strategies.

The criteria for the LEZ were then developed and it was vital to determine existing bus fleet composition; this allowed Norwich to determine the number of buses which would be affected by any proposals. Following extensive consultation with both taxi and bus operators it was clear that the originally proposed Traffic Regulation Order approach to regulating the LEZ would be too rigid and onerous for the majority of bus operators to comply with. It was agreed that a Traffic Regulation Condition with a phased approach would be more achievable in the required time scale. A grant system was devised following consultation with operators Norfolk County Council whereby funding was made available (65%) towards the cost of retrofitting buses. This offer was made to all affected operators and the choice of abatement equipment was decided upon by the operators themselves. As part of the LEZ, eco-driver training (either two hour or half day courses) was also offered to all operators in Norfolk. A programme of works for the retrofitting of fire trucks and buses was devised. An evolutionary approach of introducing the Norwich Low Emission Zone has been implemented, in association with other measures for a holistic approach to air quality management. This phased approach was considered the most appropriate in order to give operators/companies adequate time to consider the options available and then take appropriate measures such as obtaining cascaded vehicles, buying new vehicles and/or devising a retrofit programme. Following advertisement of the TRC the LEZ was officially launched in July 2008. A condition of the TRC is that all affected public service vehicle operators must supply details of the emissions capability as defined by the equivalent Euro exhaust emissions standards of each vehicle within their bus fleet used on local bus services operating in Castle Meadow to Norfolk County Council.


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Evaluation and monitoring with stakeholder surveys, exhibitions, face to face and telephone interviews, as well as questionnaires were undertaken. There will be on-going monitoring and evaluation of air quality due to the fact that 100% of buses needing to comply with the LEZ criteria. This was not achieved until 2010.

4.5.3 Consultation Feedback

From Swedish examples (i.e. vehicle age-based criteria), introducing a set of emissions criteria

relating to a Euro standard in a single year leads to a ‘step change’ in the number of vehicles

allowed in the zone. This leads to a number of issues for freight operators such as potential

problems due to peaks in the demand for retrofit conversion and equipment and a surplus of

non-compliant vehicles all at once.

London LEZ conducted detailed stakeholder consultation. Feedback from operators indicated

that most large fleet operators replace their Lorries every 5-6 years, with smaller operators

replacing less frequently. Specialist vehicles (cement Lorries, refuse trucks, coaches) have

much longer replacement cycles due to cost of vehicle and reduced annual mileage.

Operators in London suggested three ways in which they would likely comply with the LEZ:

retrofitting, purchase of compliant vehicles, and by using their newer and thus compliant

vehicles within the LEZ and their others outside of it. The London LEZ research indicated

difficultly in consultation with smaller companies and owner-drivers

TfL draws attention to the effect of an LEZ on blue badge holders and modified vehicles for

disabled drivers. It may be possible to retrofit such vehicles if none compliant however, the

costs of this may have negative social impacts on disabled drivers. It may be necessary to

provide grants to or exempt such vehicles. In which case, the chosen enforcement method must

have the capability to recognise those exempt from the scheme.

Deloitte’s research on behalf of the London LEZ recommends that cars be excluded from LEZ

proposals due to the very large number of vehicles it would affect, and the fact that the majority

of older cars are owned by low income households and the scheme would thus affect them

disproportionately.

London LEZ consultation study estimates the need for a three year notice period for the

implantation of a LEZ. Vehicle operators would need as much notice as possible ahead of

launch in order to plan vehicle upgrades. This may affect the proposed NG LEZ launch of 2021

as this may not give enough time to operators to comply with the conditions of the LEZ.

4.6 Economic Impacts

The economic impacts caused by the implementation of an LEZ need serious consideration.

The public acceptability on an LEZ is strongly linked to the potential economic disbenefits

experienced by both individuals and businesses. The timing of implementation of an LEZ is also

heavily influenced by current economic conditions and the ability of local businesses to adapt

financially to incoming restrictions. The potential economic impacts caused by LEZ’s are

discussed below.

4.6.1 Vehicle Operators

The Prague environmental zone was successful in reducing heavy-vehicle traffic flow, and

managed to achieve a shift to lighter, less-polluting vehicles. However, fleet renewal can often

take time and it is therefore important that zone rules are set at an appropriate level, for


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example if the rules are too lenient, there may not be enough pressure on operators; if too

stringent, operators may be driven out of business. (European Environment Agency, 2008).

In Newcastle/Gateshead bus operators, and delivery companies would need substantial lead in

times to allow them to prepare financially should the proposed LEZ criteria compel them to

upgrade their respective fleets. During the consultation period for the London LEZ many

delivery companies stated they would seek to pass on any additional operating costs

associated with adhering to an LEZ. This may therefore have a knock on impact on other

businesses/residents located within the LEZ extents.

Should bus operators serving the City centre choose to pass on the costs of

upgrading/retrofitting their fleet this may have implications on the cost of travel. This could

cause significant financial pain to some of the more vulnerable users in the area.

As the level of LGV’s is high in Newcastle and Gateshead it is important to be able to offer

assistance to this group in the form of incentives. If targets are to be met without having a

detrimental effect on SME’s, support in the form of financial grants for retrofitting should be

considered. This would allow businesses to continue to operate in difficult economic

circumstances without the further burden of having to upgrade their fleet/vehicle immediately.

4.6.2 Businesses within LEZ

Retail businesses large and small residing within an LEZ may suffer from a reduction in trade

dependent on what vehicles are included under the LEZ criteria. If the LEZ enforcement is

inclusive of private cars shoppers may choose to conduct their business at out of town retail

parks rather than conform to the criteria of a city centre LEZ. This could have a double impact

on local authorities directly through a loss of parking revenue and reduced business rent rates

should firms choose to relocate outside of the LEZ extents.

Retail businesses residing within an LEZ may suffer if the LEZ is inclusive of private cars as

shoppers may choose to conduct their business outside of the zone i.e. Metro Centre. The

‘Alive after Five’ parking strategy and extended opening hours introduced in 2010 is expected to

deliver a multi-million pound boost to city centre businesses. The LEZ if applicable to private

cars would potentially be at odds with “Alive after Five” strategy.

4.6.3 Wider Economic Impacts

Both private and council operated car parks located outside the LEZ boundary would potentially

become more appealing if drivers choose to divert rather than conform to the LEZ. This could

impact parking revenue and would require a review of parking charges inside and outside of the

LEZ extents. In order to maintain/increase public acceptability of a prospective LEZ, parking

charges may need to reduce in areas within the LEZ. This would act as a supporting measure

to encourage the migration toward LEZ compliant vehicles.

It is important as with any new measures that the economic impacts are kept in mind. NCC and

GMBC are therefore focusing on promoting the economy and creating new jobs. Consequently

if air quality measures were to hinder these efforts the LA’s may consider their priority as being

the economy on reflection of current economic conditions. Current figures show that shop

vacancies nationally have increased again year on year since 2010. Furthermore, in

Newcastle/Gateshead the vacancy rate is greater than the national average, demonstrating that

at present measures are still necessary to support retail and the wider business place.


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4.7 Implementation

In the U.K. the Transport Act 2000 and Traffic Regulation Act 1984 provide several options for

implementing restrictions on the highway to enforce an LEZ from. These are summarised

below.

4.7.1 Traffic Regulation Order (TRO)

TRO’s were considered by TfL, however after consultation over the greater London LEZ, the

preferred option of a Scheme Order was chosen. Oxford also considered TRO’s and chose not

go down this route, as their scheme targets buses and any income generated through fines

would be low compared to the scheme operating costs.

TRO’s may be implemented under the pre-requisite of improving air quality. They can only be

used for specific roads and not for general areas which could make it difficult, costly and

resource intensive to implement to the AQMA.

Three types of TRO exist:

Permanent – remain in force until revoked or superseded

Temporary – may last up to 6 or 18 months

Experimental – may last up to 18 months with possible extensions

A TRO must not inhibit the waiting of vehicles in roads and street parking places of vehicles

displaying a disabled person’s badge and consideration must be given to these exemptions. A

TRO would require considerable signage and enforcement and would have a resource

implication for Newcastle and Gateshead.

4.7.2 Traffic Regulation Condition (TRC)

A TRC was implemented in Oxford as this LEZ targeted only public service vehicles. A TRC

regulates the operation of buses within a defined area. The TRC is enforced through bus

service registration rather than on street enforcement of traffic restrictions and can be applied to

bus services whose routes enter the LEZ.

4.7.3 Scheme Order/ Road User Charging Order

The system eventually adopted by TfL for the Greater London LEZ. Was a Road User Charging

Order. This can be applied to all roads within a specified area and implements a charge on

specific vehicles inside the area whilst not banning them from entering outright. Normally this is

applied when implementing congestion charging however it is also applicable to emissions

based charging and would therefore be applicable to the Newcastle Gateshead LEZ.

In order to pursue the improvement in air quality via an LEZ implementation, it is recommended

that a Scheme Order under RTA as in London be pursued. Using this approach means the

order can be applied to existing AQMA extents or a new area (Urban Core Distributor Route

boundary) rather than street by street as in a TRO.

4.8 Monitoring

Air quality can be monitored continuously through the use of standard or bespoke monitoring

systems from roadside enclosures through to larger "walk-in" cabins and even trailer and


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vehicle based mobile laboratories. Real-time gas analysers are available for the measurement

of all major organic and inorganic pollutants. Newcastle and Gateshead currently have

roadside air quality monitoring stations and mobile air quality monitoring in association with

Newcastle University. Monitoring tailpipe emissions of retrofitted vehicles is also possible but

requires the cooperation of vehicle owners. For buses this could be pursued through a BQC or

a voluntary quality partnership.

The current LEZ in operation in Norwich since 2008 has restricted access in the Castle Meadow

area of the city to buses achieving Euro III standard or better. The LEZ was implemented on a

phased-approach of retrofitting an increasing percentage year-on-year of Euro II buses

operated within the city with SCR equipment. Grants of up to 65% of retrofit costs were offered

by the council to operators. The SCR catalysts retrofitted to the Euro II buses are claimed to

deliver NOX reductions of ‘up to 64%’. Original values stated in the case for support of the LEZ

cite potential NOX reductions of 30-70% for SCR, and 40-50% for EGR.

AMEC (one of the world’s leading engineering, project management and consultancy

companies) disregarded analysis on the costs of retrofitting Exhaust Gas Recirculation (EGR) to

heavy duty vehicles on the basis that EGR retrofit requires ‘extensive engine rebuilds’ and trials

have led to ‘higher fuel consumption, increased PM emissions and a reduction in performance,

whilst in some cases failing to reach a target NOX reduction of 50%’. Likewise AMEC reported

‘no evidence for Lean NOX Trap (LNTs) applied as retrofit solutions for heavy duty engines has

been found’, and discounted analysis of the technology.

In light of the research Newcastle and Gateshead may find it difficult to specify retrofitting

technologies for vehicles when research presents conflicting results and may face resistance

from operators. In the case of buses and HGV’s these issues around appropriateness of

technology can be explored further through FP and BQC. It is worth noting that subsides may

be needed to help operators meet some of the costs in upgrading and retrofitting vehicles.

4.9 Enforcement

On review of existing LEZ’s in operation there are several options available when considering

how to enforce the scheme. The pros and cons of these approaches varies dependent on the

type of vehicles being enforced, the volume of these vehicles, and the level of capital available

to start-up the scheme.

Identification of a vehicle that complies with LEZ criteria can be via a paper permit, windscreen

sticker, by the VRM on the number plate or instead through requiring a vehicle to self-identify

itself, by use of a transponder or a proximity smart card. The permit and sticker based systems

represent a “low tech, low cost” approach with transponder and number plate based systems

requiring more sophisticated technologies to be adopted in enforcement.

Detection of a vehicle for subsequent identification of emission status could be carried out by a

variety of methods, sometimes in combination.

Manual methods, whereby enforcement personnel visually check vehicles travelling

within or parked within the scheme area for identification marks (VRM and/or a

permit/sticker). In the mainland Europe examples of LEZ the checks would tend to

focus on older looking vehicles and might use a mixture of manual recording and

possibly photography. Some post checking against a database of compliant vehicles

would then be necessary.


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Digital cameras and ANPR – all passing number plates are recorded and using Optical

Character Recognition (OCR) for matching against a database of vehicle data. A

network of cameras would be installed on the key routes into/out of the boundary of the

scheme and possibly at key junctions within the zone if it is very large. As a

supplementary, or alternative approach, mobile ANPR cameras could be used to

monitor key junctions and/or ‘hot-spots’ of possible non-compliance.

Dedicated Short Range Communication (DSRC) – tags and beacons, more suitable for

schemes with relatively few and pre-determined users which comply with the scheme

criteria. Tags or proximity smartcards are commonly issued to vehicle owners for

accessing private car parks, or can be scanned through a wind-screen, and can also be

used to trigger bollards which control access on the public highway.

The benefits of manual detection methods are lower capital costs, and some flexibility over

future operating costs if enforcement levels can be reduced. Manual enforcement is suitable for

parking based schemes, whether on or off street. A drawback of manual enforcement is the limit

on the number and speed of vehicles that can be checked by a person.

The benefits of such automated enforcement systems are that high speed and volume flows of

vehicles can be detected and recorded, and that every vehicle can be checked. Drawbacks can

include the relative inflexibility of fixed camera systems once they are installed, and the up-front

capital costs.

Automatic Number Plate Recognition cameras can provide one part of such an automated

system. They are able to capture 90%+ of passing number plates. Automatic Number Plate

Recognition cameras are used in the London Congestion Charge Scheme (CCS) and for the

London LEZ. In the London CCS, images are kept for checking of vehicles whose details are

not in a database of vehicles for which a charge has been paid (or registered as exempt). In

order to cover ‘hotspots’ of non-permitted vehicles within the LEZ, mobile (van-based)

enforcement units could be suitable.

It should be noted that it is not strictly necessary to achieve a 100% detection level for a

scheme to be effective. The level of compliance, and impact noncompliance has on emission

impacts, will impact on the value for money of any scheme. However, the aim should be to

achieve a balance with sufficient enforcement to provide an effective deterrent, in order to

achieve the scheme objectives.

If there is a large degree of pre-compliance the numbers to be enforced against will be relatively

small. If the economic impact of non-compliance is high, even a low level of detection will be

sufficient to influence operators who only enter the zone infrequently to upgrade their vehicles

or enter commercial arrangements which avoid them having to enter the zone. If pre-

compliance is low, a more rigorous detection regime will be required.

In summary, manual enforcement schemes, targeting heavy vehicles only, enable the quickest

introduction of an LEZ. ANPR offers a higher compliance rate (and thus greater air quality

benefits). Problems may arise in the detection of retrofitted vehicles; a database of such

vehicles would be required in order for them to be recognised through ANPR.

The application of ANPR is only financially viable if the number of vehicles being enforced

against is high. Should Newcastle/Gateshead choose to include private cars in the LEZ

proposals then using ANPR would be the most viable approach to enforcement.


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4.10 Costs

Potential costs that may be incurred in the implementation and operation of a LEZ include:

Administrative costs for issuing the permits;

Enforcing the permits with patrolling police;

Permit material;

Change in traffic signals and signs; and

Loss of existing business or reduced competitiveness in attracting new businesses.

Administration work and associated costs will be incurred as a result of introducing a LEZ, as

permits for vehicles to enter the zone will need to be administered. Additional permits will also

need to be administered for vehicle exemptions, such as for maintenance.

Unlike measures such as congestion charging, no significant revenue is expected from the

introduction of a LEZ apart from the revenue from fines. This revenue would be used to reduce

the ongoing operational costs.

The Feasibility study for London LEZ suggests the following costs:

Manual enforcement scheme for HGV’s: £2.8m set-up, £4m pa running costs

ANPR: £6-10m set-up, £5-7m pa running costs (£1-4m revenue generated)

Table 4.2 Costs relating to the Enforcement of LEZ

Enforcement Option Evader Captures per 24 hours

Estimated Capex per Unit

Estimated Opex per Unit (24/7

operation)

Mobile Operator 12 £28,000 £113,000 pa

Mobile Operator Supported by Camera/ANPR

12 to 18 £35,000 £117,000pa

It is worth noting that significant cost implications apply to vehicle operators, which are likely to

exceed the costs of setting up and running an LEZ.

Table 4.3 DEFRA cost estimates for Low Emission Zone scheme using fixed ANPR

Base Scheme (access control giving priority to public transport)

Scheme A. Bus

Scheme B. HDV, Coach, Bus

Scheme C. HDV, Coach, Bus, LGV, Car, Taxi

Start –up (Capital) £

Equipment 150,000 250,000 250,000 350,000

Central System 50,000 100,000 150,000 200,000

Other 70,000 100,000 200,000 250,000

Total Start-up 270,000 450,000 600,000 800,000

Operating costs (end of year 1) £

Maintenance 10,000 20,000 20,000 30,000

Central System, premises, supplies

65,000 75,000 80,000 150,000

Staff Costs 120,000 170,000 230,000 330,000


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Total Operating 195,000 265,000 330,000 510,000

Total Revenue* 60,500 82,250 102,500 158,250

*estimated based on London LEZ percentage return on annual operating costs

The ongoing operating costs detailed in Table 4.3 may reduce slightly over time as efficiencies

are made. However, if the LEZ is successful the already small amount of revenue generated will

diminish over time as vehicle conformance increases. Therefore in cost benefit terms the capital

investment warranted would need to be justified by a prolonged return in revenue from fines.

This is unlikely to ever occur with an LEZ, in fact the more successful the scheme the less

justified the ongoing monitoring and associated operational costs become.

The revenue raised should not be included in a cost-benefit analysis as it is simply a transfer of

money from users via penalty fines to offset the ongoing operational costs. It is stressed that the

London LEZ scheme is not self-financing and that what revenue is generated contributes

towards the ongoing operating costs. The average rate of return on an ANPR based scheme is

30% of the annual operating costs with a manual approach returning only 10%.

Given the low rate of return, an authority considering an LEZ would need to compare these

ongoing costs against long term reductions in respiratory problems attributable to air quality.

Ultimately these health benefits could be quantified in line with WebTAG guidance but given

that these are long term benefits their consideration is not considered appropriate over a short-

term appraisal.

However as with all other transport appraisal all the monetised benefits of the scheme must be

quantified. Whilst Newcastle University have quantified the potential volumes of Carbon

reduced/removed this has not been monetised. With this in mind it can be seen how large scale

ANPR based systems can justify such significant capital investment as the high level of

compliance delivers significant emission reductions.

If the LEZ was to focus on other vehicles and hence exclude cars then ANPR would not be

viable due to the high capital costs required to start up. The most effective methods of

managing permitted vehicles would be to use existing systems and sources of information as

far as possible. Given constraints on revenue budgets, a scheme which has low operating costs

will tend to be more attractive from a whole-life cost perspective. However, this needs to be

carefully balanced against the resulting level of compliance by users with the scheme emission

standards, or the purpose and value of the scheme is undermined. Table 4.6 below provides

indicative estimated costs for a manual enforcement approach applied to

Newcastle/Gateshead.

Table 4.6 cost estimates for manual enforcement applied to Newcastle/Gateshead

Scheme A. Bus Scheme B. HGV, Coach, Bus

Scheme C. HGV, Coach, Bus, Taxi

Start –up (Capital) £

Equipment 20,000 20,000 20,000

Vehicles 30,000 30,000 30,000

Total Start-up 50,000 50,000 50,000

Operating costs (per annum) £

Administration of penalties

20,000 22,000 25,000

Staff Costs 50,000 50,000 75,000


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Total Operating 70,000 72,000 100,000

Total Revenue* 7,000 7,200 10,000

*estimated based on London LEZ percentage return on annual operating costs

Should an LEZ be adopted there would come a point where the level of compliance is high

enough to warrant consideration to stop monitoring. The revenue generated should not be a

driver in ongoing monitoring as high compliance would infer significantly improved air quality. In

fact the authority would need to consider covering all costs irrespective of supplementary

revenue. This decision would require the full support of an authority toward tackling air quality

issues long term as there is no revenue based case for an LEZ therefore any authority

implementing an LEZ would have to do so at a significant cost.


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5. Modelling

Newcastle University undertook the technical modelling work to test the impacts of different LEZ

scenarios. A detailed technical report explaining the evolution of the modelling process,

technical issues encountered and summarising the results from the scenario testing is included

in Appendix A. The following section of this report summarises the modelling approach adopted

and analyses the outputs from the scenario testing.

Figure 5.1 Proposed Modelling Methodology for the Newcastle/Gateshead LEZ Feasibility

Study


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The key elements of the modelling methodology shown in Figure 5.1 above are summarised

below.

5.1 Tyne and Wear Transport Planning Model

The Transport Planning Model (TPM) is a large scale, strategic, multi-modal transport model,

covering all five metropolitan boroughs (Newcastle, Gateshead, Sunderland, North Tyneside

and South Tyneside) in Tyne and Wear. Jacobs Consultancy undertook initial development in

2006 with a remit to provide ‘a system capable of realistically representing and accurately

assessing most travel behavioural responses to transport policy in order to appraise future

transport scenarios and packages in Tyne and Wear’ and is ‘broadly based on the principles

and guidance included in DfT’s WebTAG’. The trip distribution, modal split and trip assignment

elements of the TPM are built around the CITILABS CUBE/TRIPS package.

5.2 PITHEM Emissions Model

The PITHEM model provides link-based emissions estimates from transport, based on a GIS-

centric approach. PITHEM takes period output from a suitable transport model, applies speed-

based, factor curves to vehicle kilometres travelled data to produce emissions estimates for

those periods. The software then scales period data to account for diurnal, weekly and annual

variation, and then outputs that data in a form that may be analysed by GIS, or used as input to

a suitable dispersion model.

5.3 ADMS-Urban Air Quality Dispersion Model

The ADMS (Atmospheric Dispersion Modelling System) model, from Cambridge Environmental

Research Consultants (CERC) allows the calculation of pollutant concentrations at specified

receptor points in complex urban topography, using a ‘Gaussian-type’ dispersion model. It is

‘used by, or on behalf of, over 70 UK local authorities for Review and Assessment’ purposes.

The software combines a user interface to develop emissions, inventories and databases, as

well as to set up dispersion modelling runs.

5.4 Development of Public Transport (Bus) Model

Data on weekday bus flows was received from Newcastle City Council. The data had been pre-

processed by the council to link timetabled bus stop information to OS MasterMap links.

The development of a separate bus model to that already existent in TPM was considered

necessary after analysis of the pilot results. One downside of the use of a separate model to

TPM is that the bus flows are no longer related to the PT demand and mode choice elements of

TPM, and are hence ‘static’, and not easily updated to reflect PT policy decisions affecting

routing or patronage. However, this was not considered an issue in the initial development of

LEZ scenarios. It was considered of greater importance that the bus model accurately

represented on-street flows, routes and vehicle kilometres.


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5.5 Analysis

5.5.1 Base Year Model Findings

For the 2010 base year, in the Newcastle central cordon area buses appear to be the

dominant source of NOX, accounting for over 70% of emissions. In the AQMA areas the

contribution from buses appears to be around 37-45%. NOX emissions in the Newcastle

and Newcastle and Gateshead AQMAs are more dependent on the bus contribution

than for the Gosforth AQMA;

The influence of buses on NOX emissions decreases away from the urban core areas,

whilst the contribution from LGVs and HGVs increases. Around the A1/A1M HGVs

contribute towards very high (>150 µg/m3) annual NOX concentrations.

There are clearly modelled exceedences of NO2 in all of the defined AQMAs, as well as

at other locations, e.g. further along the Coast Road than the current AQMA limit,

though the use of the high NOX background should be kept in mind;

Particulate matter (either PM10 or PM2.5) does not appear to be a particular issue in

Newcastle or Gateshead, though the policy of continual exposure reduction is noted.

The modelled PM concentrations are more dependent on the choice of background

level than for NOX or NO2;

Cars play a more important role in production of PM, than for NOX, accounting for

approximately 40 – 50% of total emissions;

5.5.2 Future Year Assumptions

All of the fleets used to model the 2021 scenarios were based directly on those presented in the

NAEI fleet. The fleet data for 2021 was manipulated using Microsoft Excel (Microsoft, 2013) to

produce the LEZ fleets by elevating all vehicles of lower Euro class into the class stipulated by

the desired LEZ criteria. This potentially gives an optimistic estimate for the vehicle fleet (and

emissions changes). In reality ageing vehicles would be replaced with a mix of both second-

hand and the latest vehicles. The methodology assumes that 100% of vehicles will comply with

the LEZ criteria, whilst in reality the actual value of compliance will depend heavily on

enforcement policy. Sensitivity of LEZ effectiveness to the proportion of compliant vehicles has

not been explicitly addressed in this study.

The decision to base all scenarios off the NAEI fleets, rather than extrapolating forward from the

fleets developed from the DfT/spreadsheet model, was based on time constrains and lack of

available information on fleet turnover (new purchases versus scrappage rates). This area

should be revisited for more detailed LEZ design, based on further consultation with relevant

parties such as DfT/DVLA, DEFRA, SMMT (Society of Motor Manufacturers and Traders),

NEXUS, SMEs (Small and Medium Enterprises), local fleet operators etc.

As well as the baseline fleet, two LEZ fleets are given for Euro 5/V compliance, and Euro 6/VI

compliance. After initial pollutant concentration modelling (discussed in Section 5) using these

fleets, and discussion amongst the LEZ steering group, based on the literature presented in

Two further options were developed: ‘E6/VI Fail 2021’ and ‘E6/VIF E5 LEZ 2021’. These

represent ‘worst case’ contingency scenarios if Euro 6/VI technologies fail to deliver any benefit

over Euro 5/VI. The former being the baseline 2021 fleet, but with no Euro 6/VI vehicles

present, the latter being the same, but under Euro 5/V LEZ compliance.

It is also acknowledged that bus and fleet operators tend to purchase vehicles in cycles, and

that given an operational lifespan for a vehicle of 5 to 8 years it is possible for a particular fleet

to completely ‘skip’ a Euro class.


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A worst case scenario would be to assume the current fleet composition represents the most

recent “upgrade” and the next fleet replacement is not due until 2020. As Euro VI would be the

standard for all new buses being built, by default all the operators would upgrade and adhere to

the proposed 2021 scenario.

This scenario would lead to lower Euro 6 proportion values than suggested by the NAEI values

but has not been investigated further due to lack of time and supporting information on turnover

rates. Likewise, due to the unavailability of suitable emissions factors until late in the study,

options for retrofitting heavy duty vehicles with de- NOX equipment have not been investigated.

5.5.3 Scenarios

Based on discussions between LEZ steering group members, Newcastle University was

presented with a range of LEZ scenarios to model by Capita Symonds. These scenarios were

based on combinations of the vehicle fleet tables and are listed below:

BAU 1 (Business as Usual) Future year 2021 scenario – using the NAEI 2021 fleets for

all vehicle classes;

LEZ 1 – all vehicle classes are assumed Euro 5/V compliant;

LEZ 2 – all vehicle classes are assumed Euro 6/VI compliant;

LEZ 3 – all goods vehicles (i.e. petrol LGVs, diesel LGVs, rigid HGVs, articulated

HGVs) are assumed Euro 5 compliant;

LEZ 4 – as above, but all goods vehicles are assumed Euro 6 compliant;

LEZ 5 – all buses are assumed Euro VI compliant;

LEZ 6 – all passenger cars (petrol car, diesel car) are assumed Euro 6 compliant.

BAU 2 Future year 2021 - Euro 6 failure – all vehicles that were Euro 6/VI compliant in

scenario 1 above are assumed to be 5/V only;

LEZ 7 Future year 2021 - As BAU 2 above, but all vehicles comply with a minimum of

Euro 5/V.

Note that, given the uncertainties in modelling the proportions of light and heavy goods vehicles

on the roads the decision was made to treat these as a single category for LEZ compliance.

BAU 2 and LEZ 7 were developed to assess air quality under the possibility of Euro 6/VI failing

to deliver benefits over Euro 5/V, these are extreme, and are not anticipated to materialise in

reality. They are presented as a cautionary note on the potential impacts if technology fails to

deliver.

The results of the modelling of the above scenarios, together with 2010 base year conditions,

are presented in Figure 5.2 and Figure 5.3 below.


40

Figure 5.2 Source-apportioned NOX emissions for Newcastle City Centre AQMA, under

the various base year (2010), future year (2021) and LEZ scenarios

Figure 5.3 Source-apportioned NOX emissions for Gateshead AQMA, under the various

base year (2010), future year (2021) and LEZ scenarios

All LEZ options, assuming Euro 6/VI achieves its objectives, represent an improvement on the

baseline 2021 scenarios. As would be expected, the best option is LEZ 2, to force all vehicles to

be Euro 6/VI compliant, with total emissions only ≈25% of the 2010 baseline, and ≈60% of the

2021 future year baseline.

43.9

40.1

38.6

28.2

26.6

26.6

28.2

19.8

28.2

18.8

19.6

16.6

16.3

10.0

9.6

9.6

7.4

10.0

10.0

7.4

36.7

35.3

35.9

8.4

8.5

8.5

5.8

8.4

8.4

5.8

87.4

68.5

67.4

27.0

27.0

25.9

27.0

27.0

10.0

10.0

0 20 40 60 80 100 120 140 160 180 200

Base

BAU 2

LEZ 7

BAU 1

LEZ 3

LEZ 1

LEZ 4

LEZ 6

LEZ 5

LEZ 2

Bas

e 20

10

E6 F

ail

E6 F

ail

All

E5

Fut

2021

G

oo

ds

E5

All

E5

Go

od

s E6

C

ars

E6 B

uss

es

E6

All

E6

Total Annual NOx Emissions in Tonnes

Sce

nar

ios

Cars LGV

HGV Buses

21

20.3

19.5

14.2

14.2

13.4

14.2

10

14.2

10

9.1

8.3

8.2

5

4.8

4.8

3.7

5

5

3.7

15.7

17.5

17.6

4.2

4.2

4.2

2.9

4.2

4.2

2.9

31.6

24

23.5

9.3

9.3

8.9

9.3

9.3

3.3

3.3

0 20 40 60 80 100

Base

BAU 2

LEZ 7

BAU 1

LEZ 3

LEZ 1

LEZ 4

LEZ 6

LEZ 5

LEZ 2

Bas

e 20

10

E6 F

ail

E6 F

ail

All

E5

Fut

2021

G

oo

ds

E5

All

E5

Go

od

s E6

C

ars

E6 B

uss

es

E6

All

E6

Total Annual NOx Emissions in Tonnes

Sce

nar

ios

Cars

LGV

HGV

Buses


41

What is immediately apparent from Figure 5.2 and Figure 5.3 is the important role that the Euro

6/VI standard plays in emissions reduction, especially for the heavy duty vehicle classes. The

extreme Euro VI failure results are within ≈85% of the 2010 emissions totals, whereas even the

baseline future 2021 scenario sees emissions drop to ≈40% of the 2010 totals. The figures also

show that the relative importance of cars (i.e. especially diesel cars) to NOX emissions

increases markedly between 2010 and 2021. The LEZ 3 Scenario based on all goods Euro 5/V

appears particularly ineffective. Assumed benefits to light goods vehicle compliance are partially

cancelled out by increased emissions of NOX from SCR-equipped heavy goods vehicles.

Likewise the Euro 6 failure scenarios also show increases in heavy goods NOX emissions, even

over the 2010 baseline for the category.

Table 5.1 Percentage NOX emissions changes associated with the LEZ scenarios, based

on sum of total emissions within the three AQMA areas

Scenario LEZ Compliance Relative to 2010 base Relative to 2021

BAU

Base 2010 N/A N/A +146.6%

2021 BAU N/A -59.5% N/A

LEZ 1 2021 All Euro 5 -61.1% -4.2%

LEZ 2 2021 All Euro 6 -75.8% -40.5%

LEZ 3 2021 All Goods Euro V -59.6% -0.4%

LEZ 4 2021 All Goods Euro VI -62.2% -7.0%

LEZ 5 2021 All Buses Euro VI -67.9% -21.0%

LEZ 6 2021 All Cars Euro 6 -64.5% -12.5%

2021 BAU 2 N/A – Euro 6/VI fail -13.2% +114.0%

LEZ 7 2021 E6/VI fail, All Euro 5 -14.6% +110.5%

As modelled, the most effective LEZ option targeting a single vehicle class is that for Euro VI

applied to buses. However, note for the Gosforth area, the effectiveness of LEZ 6 (cars meet

Euro 6) and LEZ 5 (buses meet Euro VI) are reversed. Additionally, the caveats given in

Section 5, namely possible bias towards bus network coverage and use of un-validated bus

flows in the council data set must be borne in mind.

5.5.4 Primary NO2

Figure 5. presents the results of the emissions total and source apportionment analysis for

primary NO2 emissions for the Newcastle Centre AQMA. Again these results should not be

considered as anything more than illustrative, given the limitations of the primary NO2

calculation methodology in the PITHEM software (i.e. scaling NOX emissions by the COPERT4

primary NO2 factors).


42

Figure 5.4 Source-apportioned pNO2 emissions for Newcastle City Centre AQMA under


Whilst Figure 5.3 presents a similar picture to those in Figure 5., in that the general order of

effectiveness remains relatively unchanged, with the exception that an LEZ controlling

emissions from cars to Euro 6, becomes more effective than the buses meeting Euro VI option.

This reflects the general distortion of the values by late-Euro light duty engines having higher

(>25%) primary NO2 emissions than late-Euro heavy duty engines (≈10%) in the COPERT4

factors. Indeed, for all of the 2021 options, the primary NO2 contribution from HGVs is modelled

as fairly negligible compared to contributions from the other vehicle classes.

Generally, the primary NO2 emissions for all of the 2021 scenarios that assume that the Euro

6/VI standard delivers the expected on-road emissions benefits are under 50% of the 2010

total. Under the Euro 6 failure scenarios, primary NO2 emissions remain comparable to the

2010 levels.

However, the range of potential f-NO2 values (5%-70%) for light duty vehicles presented in the

COPERT4 data must be borne in mind. The blue and red elements in Figure 5. could be almost

eight times shorter, or twice as long. More measurements and discussion in the area of primary

NO2 emissions is expected in the near future in work being undertaken by King’s College

London and Newcastle University, on behalf of the London boroughs and DEFRA. Ideally,

modelling of primary NO2 in Newcastle and Gateshead AQMAs should be revisited in future

before detailed LEZ options are evaluated.

5.5.5 Particulate Matter (PM10 and PM2.5)

Figure 5.5 presents the results of the emissions total and source apportionment analysis for

PM10 emissions for the Newcastle Centre AQMA. As the focus of the Euro 6/VI regulation is on

NOX reduction, rather than on particulate matter (which was more the goal of earlier Euro

standards), the emissions reductions achieved are less impressive than for NOX or primary

NO2. Also changes in Euro class affect only tailpipe PM emissions, not those associated with

brake and tyre wear, or from abrasion of the road surface itself.

9.32

13.67

13.14

9.59

9.59

9.59

6.73

9.04

6.73

9.59

6.13

5.19

5.11

3.13

3.01

2.33

3.13

3.01

2.33

3.13

4.73

3.57

3.63

0.85

0.86

0.59

0.85

0.86

0.59

0.85

10.62

8.32

8.19

3.28

3.28

3.28

3.28

3.15

1.21

1.21

0 5 10 15 20 25 30 35

Base

BAU 2

LEZ 7

BAU 1

LEZ 3

LEZ 4

LEZ 6

LEZ 1

LEZ 2

LEZ 5 B

ase

2010

E6

Fa

il

E6

Fail

All

E5

Fut

20

21

Go

od

s E5

G

oo

ds

E6

Car

s E6

A

ll E5

All

E6 B

uss

es

E6

Total Annual pNO2 Emission in Tonnes

Sce

na

rio

s

Cars

LGV

HGV

Buses


43

Figure 5.5 Source-apportioned PM10 emissions for Newcastle City Centre AQMA under


Table 5.2 summarises the changes in PM10 and PM2.5 emissions with each scenario. Note that

the changes associated with PM2.5 are greater than those for PM10. Generally all changes for

PM10 relative to 2010 are in the order of 30%, whilst for PM2.5 changes are over 40%. The LEZ

options generally make single digit percentage improvements over the ‘BAU 1 2021. As before,

the LEZ with all vehicles Euro 6/VI compliant is the most effective option.

Table 5.2 Percentage PM10 and PM2.5 emissions changes associated with the LEZ

scenarios, based on sum of total emissions within the three AQMA areas

Scenario Name PM10

Relative to

2010

PM10

Relative to

2021

PM2.5 Relative

to 2010

PM2.5

Relative to

2021

Base 2010 Baseline N/A +41.3% N/A +72.4%

BAU 1 2021 Baseline Future 1 -29.2% N/A -41.9% N/A

LEZ 1 2021 All Euro 5 -31.8% -3.6% -46.0% -7.0%

LEZ 2 2021 All Euro 6 -33.3% -5.7% -48.0% -10.2%

LEZ 3 2021 All Goods Euro V -29.7% -0.7% -42.6% -1.0%

LEZ 4 2021 All Goods Euro VI -30.0% -1.0% -42.9% -1.6%

LEZ 5 2021 All Buses Euro VI -31.1% -2.6% -45.0% -5.3%

LEZ 6 2021 All Cars Euro 6 -30.7% -2.1% -43.9% -3.4%

BAU 2 2021 Baseline Future 2 -23.7% +7.8% -34.8% +12.4%

LEZ 7 2021 E6/VI fail, All Euro 5 -26.6% +3.8% -39.2% +4.8%

5.5.6 Carbon Dioxide

While not the primary focus of this study, Newcastle University was also asked by the LEZ

Steering group to provide some feedback on the impact of the LEZs on greenhouse gas

emissions, represented here by ultimate CO2 values. Figure 5.6 presents the CO2 results for the

Newcastle City Centre AQMA.

4.36

4.00

3.86

3.86

4.00

4.00

4.00

3.86

4.00

3.86

1.8

1.1

1.0

1.0

1.0

1.0

1.1

1.1

1.1

1.0

1.4

0.7

0.7

0.7

0.7

0.7

0.7

0.7

1.0

1.0

2.7

1.2

1.1

0.9

1.2

1.2

0.9

1.2

1.5

1.5

0.00 2.00 4.00 6.00 8.00 10.00 12.00

Base

BAU 1

LEZ 1

LEZ 2

LEZ 3

LEZ 4

LEZ 5

LEZ 6

BAU 2

LEZ 7

Bas

e 20

10

Fut

2021

A

ll E5

A

ll E6

G

oo

ds

E5

Go

od

s E6

B

uss

es

E6

Car

s E6

E6

Fail

E6 F

ail

All

E5

Total Annual PM10 Emission in Tonnes

Sce

nar

ios

Cars

LGV

HGV

Buses


44

Figure 5.6 Source-apportioned CO2 emissions for Newcastle City Centre AQMA under the

various base year (2010), future year (2021) and LEZ scenarios

All of the 2021 scenarios show an increase in CO2 emissions. The downward trend in car and

LGV emissions with improved technology is more than cancelled out over the period by the

increase in VKM travelled, compounded with the increase in fuel consumption from heavy duty

vehicles with emissions control technology fitted. The LEZ 6 ‘All vehicles Euro 6 compliant’ and

LEZ 2 ‘Cars Euro 6 compliant’ options perform best. The LEZ 3 ‘All goods Euro 5’, LEZ 4 ‘All

goods Euro 6’ and LEZ 5 ‘All buses Euro 6’ all produce results within 300 tonnes of the ‘2021

BAU 1’ case. Table 5.3 summarises the µCO2 changes from each scenario option.

Table 5.3 Percentage µCO2 changes associate with the LEZ options, based on sum of

total emissions within the three AQMA areas

Scenario Name Relative to 2010 Relative to 2021

Base 2010 Baseline N/A -7.3%

BAU 1 2021 Baseline Future Scn 1 +7.9% N/A

LEZ 1 2021 All Euro 5 +7.2% -0.6%

LEZ 2 2021 All Euro 6 +5.4% -2.2%

LEZ 3 2021 All Goods Euro V +7.9% 0%

LEZ 4 2021 All Goods Euro VI +7.9% 0%

LEZ 5 2021 All Buses Euro VI +7.9% 0%

LEZ 6 2021 All Cars Euro 6 +5.4% -2.2%

BAU 2 2021 E6/VI Fail +11.1% +3.0%

LEZ 7 2021 E6/VI Fail, All Euro 5 +10.5% +2.4%

The BAU 2 ‘Euro 6 Failure’ options increase emissions over the BAU 1 ‘Baseline Future 2021’

scenario, primarily due to the assumption of no fuel consumption improvements in cars and

LGVs over Euro 5 levels.

5.6 Modelling Limitations

The choice of DfT/spreadsheet fleet, over the NAEI base fleet, leads to an approximate 10%

increase in emissions for all pollutants, except primary NO2 from cars and LGVs.

22.60

22.80

22.50

21.80

22.80

22.80

22.80

21.80

24.00

23.80

5.0

6.7

6.7

6.7

6.7

6.7

6.7

6.7

6.7

6.7

4.6

5.4

5.4

5.4

5.4

5.4

5.4

5.4

5.4

5.4

9.8

10.0

10.0

10.0

10.0

10.0

10.0

10.0

10.0

10.0

0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00 40.00 45.00 50.00

Base

BAU 1

LEZ 1

LEZ 2

LEZ 3

LEZ 4

LEZ 5

LEZ 6

BAU 2

LEZ 7

Bas

e 20

10

Fut

2021

A

ll E5

A

ll E6

Go

od

s E5

G

oo

ds

E6

Bu

sses

E6

C

ars

E6

E6 F

ail E6

Fai

l A

ll E5

Total Annual µCO2 Emission in KiloTonnes

Sce

na

rio

s

Cars

LGV

HGV

Buses


45

Towards the edges of the network it is believed that the current framework under-predicts the

contributions from cars by up to 30%, whilst over predicting the contributions from HGVs, in all

areas, possibly by as much as 60-90%. The use of a separate model for buses also may be

slightly prejudicial. Though this effect is thought to be limited in the central areas, and the

AQMA, the values for buses in outer areas may be more heavily biased.

Whilst it is impossible to extrapolate performance of the whole modelling framework from just

two sites, the results do show that the choice of ambient background concentration makes an

enormous difference to the resulting concentrations. It is therefore recommended that the

modelling framework, as presented in this document be considered suitable for indicative

guideline purposes only, and that more detailed verification, development of correcting factors if

necessary, followed by calibration and validation is required before the framework may be

considered ‘fit for purpose’ for calculating concentrations at specific receptor locations.

5.6.1 Transport Modelling

The base year for all modelling is 2010, which is now three years ago. Whilst vehicle-

km travelled appears to be somewhat static between then and now, the fleet changes in

the period are not fully known, hence the current results are potentially limited in

application to the present situation;

The use of ME2 matrix estimation to calibrate link flows for the urban cores is not ideal,

as this distorts the original underlying OD matrices. In the case of any study relating to

transport then any uncertainties in the initial demand matrices will be propagated on to

the assignment of flows on the network. Even in a calibrated strategic transport model,

which performs well for the network as a whole, there may be large (50 %+)

discrepancies in flows on individual links, which will propagate into the emissions and

dispersion modelling. The pollution ‘picture’ as a whole may be broadly correct, but

inaccurate adjacent to specific roads;

Classified Cordon flows were checked across multiple cordons in Newcastle, but only

one cordon in Gateshead. Further validation work may be required for Gateshead;

The use of separate bus and private/fleet transport networks and models, which are

then merged with observed speed data, produces further problems and complexities in

ensuring data, is applied consistently. Further work is required to improve integration.

For example, under the current framework it is not possible to examine the effects of

changes on implementing non-car lanes, as these would generally have the same TOID

(and hence be assigned the same data) as their ‘parent’ road;

It has been assumed in the study that the bus and speed information provided by

Newcastle City Council is correct, further investigation of the accuracy, validity and

underlying assumptions of these data is warranted;

5.6.2 Emissions Modelling

For emissions modelling, using the current framework, total emissions are derived from

the number of vehicle kilometres travelled by user class. Therefore, for NOX/NO2

emissions modelling in the recent past and at present, the routes chosen by heavy duty

vehicles (or in the case of buses, the routes allocated to) are of concern, as these

vehicles at present have a disproportionate effect on emissions. For NOX/NO2

emissions in the near future, the apparent underestimation VKM for diesel cars and

LGVs becomes more important;

The use of average speed based emissions curves, and merging of speed information

with the traffic model also reduces both the spatial resolution and overall totals

produced. An alternative for detailed modelling would be the use of a traffic micro-


46

simulation model, coupled with an instantaneous emissions model, at the expense of

increased modelling resources due to the stochastic nature of these models;

The effects of motorcycles, taxis and coaches as separate vehicle classes in emissions

modelling have not been considered. This was primarily due to lack of information on

these classes in the transport model, and their assumed small presence in the overall

fleet. However it is noted that:

o Licensing of private hire vehicles may be a mechanism for LEZ compliance;

o Flows of coaches may be appreciable along key routes such as the A1;

o From the DfT data, motorcycles comprise over 2% of the registered vehicle

fleet, if not the VKM travelled.

No attempt has been made to investigate either the uncertainties in the emissions

curves themselves, or in the fleet inventories built using them, other than the brief

analysis in Section 5.

5.6.3 Dispersion Modelling

The low resolution of the output grid used makes accurate exceedence/LEZ boundary

definitions unfeasible. A broad indication of problem areas can be gained from the

concentration maps only. Presence of pollution hotspots is currently biased towards

receptor points falling on, or adjacent to roads, where other problem areas may be

missed. As a priority, increasing the grid resolution, and fixing issues with the current

networks and the ‘intelligent gridding’ option in ADMS-Urban should be investigated;

The choice of appropriate background level is critical to the calculation of

concentrations. Whilst the decision was taken to continue using the high background

level to provide conservative estimates of concentrations for the rest of the study, this

will incorporate an element of double counting of emissions, as well as an element of

the background that is insensitive to LEZ and f-NO2 changes;

For modelling historic and current concentrations the model is more sensitive to choice

of background level than to the f-NO2 levels selected for NOX to NO2 conversion. This

probably holds true for future year scenarios as well.

5.6.4 Analysis of Future Scenarios

Noting the limitations above, results from the scenarios suggest that;

General improvements in emissions across all non-transport sectors, plus the NAEI

assumptions about fleet turnover and Euro 6 effectiveness in reducing NOX emissions

lead to city centre concentrations for the 2021 ‘Business as Usual’ scenario are

modelled as averaging just over half of those in the 2010 base case, an average

reduction at AQMA receptor points of 10-15 µg/m3.

There is no evidence of NO2 air-quality problems in the AQMAs in the 2021 BAU

scenario – though given the low resolution of modelling, ‘hot-spots’ are likely to remain

near congested locations.

Against this background of overall low levels of NO2 the LEZ options may make up to a

further 2 µg/m3 reduction, if all vehicle types are considered to comply with Euro 6.

Other tested LEZ options offer smaller performance benefits. All tested LEZ options

offer improvements over the ‘2021 Business as usual’ scenario.

In each of the AQMA sub-domains the ‘order of preference’ for LEZ options in terms of

NOX emissions and concentration reductions appears to be fairly static, and is given

below (from best to worst):

o LEZ 2 - All vehicles Euro 6/VI;

o LEZ 5 - All buses Euro VI;

o LEZ 6 - All cars Euro 6;

o LEZ 2 - All goods vehicles Euro 6/VI;


47

o LEZ 1 - All vehicles Euro 5;

o LEZ 3 - All goods vehicles Euro 5/V.

The order given above may change if primary-NO2 emissions are not tackled

successfully in LGVs – with the LEZ 6 option for (cars Euro 6) possibly becoming more

attractive than LEZ 5 for buses. As above, it is noted that the PITHEM calculated f-NO2

ratios may be too high, and over emphasise LGV emissions;

Irrespective of the PITHEM pNO2 calculations, in future years, as Euro 6 HDVs become

more commonplace, NOX/NO2 air-quality issues may become more associated with

cars and LGVs;

The above benefits are highly dependent on the ability of the Euro 6/VI regulations to

deliver the expected NOX improvements at mid-to-low speeds on urban roads. If the

regulations fail to deliver, and emissions remain similar to those considered from Euro

5/V vehicles, then average NO2 concentrations may remain within 75% of 2010 levels,

and potential for exceedences of the air quality standards will remain in the central

AQMA areas;

Following from the above, given the current NAEI emissions factors, their underlying

assumptions on SCR catalyst numbers, and de-NOX performance, any LEZ based on

the Euro V standard (LEZ 1, LEZ 3 and LEZ 7) for HGVs may actually compound NOX

problems. The LEZ 3 ‘All goods Euro 5/V LEZ’ option only shows NOX improvements

due to the inclusion of LGVs into the design. Likewise, under Euro 6 failure, the LEZ 7

‘All vehicles Euro 5 LEZ’ option shows improvements due to inclusion of the other

vehicle classes;

If air quality issues do remain in the urban core areas in future, depending on the

location of problems, LEZ targeting cars or goods vehicles using the Central Motorway,

Coast Road and other radial routes would be most effective to the east of the core

areas, whilst targeting buses would be most effective within the centres themselves;

All of the tested LEZ scenarios had little impact on particulate matter within AQMAs or

the urban cores. Carbon emissions in all 2021 scenarios increase over the 2010 base

case, primarily due to the increase in vehicle kilometres by all types of vehicle, except

buses, though the impact of additional particulate trap and de- NOX technologies are

also slightly carbon negative.

5.6.5 Implications for LEZ Design

Given the scenarios as presented it is recommended that:

Any LEZ option using Euro V compliance criteria for Heavy Vehicles be examined

closely for alternatives, or even rejected, due to issues with potential ineffectiveness or

exacerbation of NOX emissions at low to medium speeds. Retrofitting of existing

vehicles may be a better option.

Ideally any LEZ (or other emissions reduction option) should target moving as many

buses as feasible towards complying with the Euro VI regulations as soon as possible.

This would reduce NO2 issues in the urban centres;

Ensuring or enabling Euro 6 compliance for cars and light goods vehicles would bring

benefits distributed across the region, not just to roads near bus-routes or primary

freight corridors. However, ‘selling’ the need for this to the public and SMEs, against the

perception (based on earlier LEZ implementations where particulate matter from heavy

duty vehicles was the primary concern), would be an issue;

As noted previously, the resolution of output from the current framework is not

considered adequate for detailed option design; it can, however, provide guidelines as

to effects of fleet changes, broad areas of potential effect, the magnitude of changes in

those areas.


48

6. Options

Following the review of best practice applied elsewhere and the findings of the air quality

modelling undertaken it is proposed that the following options are available to

Newcastle/Gateshead to improve air quality in the area.

Option 1 – Newcastle/Gateshead LEZ

Option 2 – Direct operator engagement with supporting measures

6.1 Option 1 – Newcastle/Gateshead LEZ

6.1.1 Extents

It would be difficult to apply the LEZ conditions to through traffic on strategic signed routes e.g.

A167 (M). Therefore the Urban Core Area bounded by the UCDR for Newcastle would be the

natural extents for an LEZ. This area would overlap with the existing extended Newcastle

AQMA. Due to the marginal levels of exceedence shown within the Gateshead AQMA and the

high potential for natural vehicle replacement rates to satisfactorily mitigate this, Gateshead

would not require inclusion as part of an LEZ.

6.1.2 Emission Thresholds, Monitoring, and Enforcement

Monitoring the effectiveness of the measure should be carried out via annual air quality surveys

at various “hot spots” within the LEZ extents and tailpipe emissions monitoring of willing

operators to establish if the modelled reductions are seen in ‘Real Life’. This would be in

conjunction with the existing permanent sites in Newcastle.

A “low tech – low cost” approach to enforcement is recommended given the marginal benefits

predicted from stringent Euro emission class restrictions. In conjunction with Newcastle’s UCDR

proposals there is likely to be a significant displacement of vehicles routing through the centre

of Newcastle and thus through the AQMA. The remaining traffic will consist mainly of HGV’s

servicing businesses/retailers, buses and taxis, and some private car trips to city centre car

parks.

The proposed enforcement approach would be to utilise existing City centre civil enforcement

officers supplemented by some additional inspectors patrolling the LEZ extents only. A sticker

based scheme applicable to all registered taxi’s, buses, and HGV’s entering the LEZ area would

be the most straightforward to administer.

The proposed thresholds to be applied within the LEZ would be Euro VI to buses and HGV’s

with LGV’s and cars remaining exempt. This would deliver air quality benefits ahead of the

standard replacement rate curve for several years. Implementing the low cost option

6.1.3 Recommended Consultation Approach

The Press and Media Section of Newcastle and Gateshead councils can help to devise an appropriate media campaign to raise awareness and seek business and community support. A consultation process similar to that of Norwich would be adopted due to the size of Newcastle and Gateshead’s Urban Core.

Suggested outline for consultation/implantation:


49

Start Finish Description

Year Month Year Month

0 May N/A N/A Decision made to go ahead

0 May 1 March Formalise business case, draft TRO, draft

environmental report, draft agreement

1 April 1 August Consult stakeholders and public. Followed

by a 9 month public inquiry

2 May N/A N/A Inspectors report after Inquiry

2 May 2 July Analysis of Report, Changes to TRO

3 Feb Go Live

6.1.4 Costs

The work undertaken as part of this feasibility study has not monetised the predicted reductions in emissions making it difficult to conclude if a LEZ would present value for money. The long term health benefits generated from reductions in air quality related respiratory illness could also be included in a cost benefit analysis. Either of these factors could lead to a significant swing toward a positive benefit cost ratio.

However based on the modelling outputs it can be seen that any LEZ scenario would only deliver temporary emission benefits ahead of the natural fleet replacement curve. Therefore any capital costs invested should be minimised as should operational costs through supplementing existing civil enforcement operations.

6.1.5 Risks

All emissions and concentration reductions associated with LEZ options are considerably smaller than the changes reflected through general fleet renewal and introduction of Euro 6/VI vehicles onto the roads. Almost all of the predicted air-quality benefits are due to the assumed effectiveness of the Euro 6/VI regulations in reducing NOX emissions for new vehicles. If these benefits do not materialise (along with expected improvements in other sectors) then the potential exists for the air-quality situation in the Newcastle/Gateshead region to be only marginally improved on that of today.

There are a number of concerns regarding the reliability of the modelling outputs, these include:-

The potential over-prediction of VKM travelled for heavy goods vehicles and under

prediction of VMK travelled by cars;

The issue of background concentrations from local road sources, applied through

ADMS-Urban, be investigated further – this may be done alongside extension of

framework verification and calibration against monitored concentrations;

That potentially fleet uptake rates be revised considerably, to reflect the cyclical nature

of freight and public transport operators, and that de-NOX retrofitting options are

examined;

That NOX and primary NO2 emissions from cars and light goods vehicles be examined

further, in the light of new research data, as this appears.

TRO approach may require loading bays to ban use in Peak periods impacting vans


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As discussed in the previous section the existing NO2 exceedences necessitating the respective AQMA’s in Newcastle and Gateshead may be resolved through “natural” vehicle replacement. Changes in vehicle flow have a significantly greater impact at reducing/removing exceedences from within an AQMA than even the most rigorous LEZ criteria. The Newcastle Urban Core Distributor Road proposals will take traffic away from the centre and redistribute it around the edge of the urban core of Newcastle. Combined with the Regional Growth Fund scheme at the Central Station this will significantly reduce potential for exceedences in this AQMA area. Neither of these schemes has been considered in the modelling exercise.

There are concerns regarding both the potential underperformance of Euro VI vehicles in “real world” conditions and the potential for a change of focus on AQMA’s from NOX to PM. Therefore there may still be the need to adopt an LEZ based approach to tackling air quality in the future, in particular if private cars and LGV’s require action.

6.2 Option 2 – Direct Operator Engagement

Adopting a direct approach to engaging and working together with those vehicle classes most

responsible for exceedences within the AQMA’s according to the source apportionment would

not necessarily be limited to a set geographic extent. The source apportionment identified that

bus operators and hauliers could be targeted via an LEZ based approach to improve air quality

ahead of the curve. However it would not be necessary to enforce this through the creation of

an LEZ as existing partnerships exist.

6.2.1 Tyne & Wear Freight Partnership

This partnership between major north east hauliers and the Tyne & Wear authorities represents

the best opportunity to engage operators regarding vehicle emissions. The partnership already

encourages benchmarking to increase efficiency and enhance fuel economy and members

appear receptive.

Whilst any agreements on benchmarking vehicle emission levels would not be contractual,

encouraging efficiency savings that provide financial rewards has the potential to be successful.

Operators delivering to key retailers/industries within the Newcastle/Gateshead AQMA’s could

be encouraged to utilise their best (lowest emission) vehicles to perform these deliveries. This

would build upon the success of the FORS (Fleet Operator Recognition Scheme) which

provides a competitive advantage when bidding for work.

The FP offers the best opportunity for engagement and encouragement to improve rather than

an LEZ mandate which could also alienate and penalise local businesses. Through continued

encouragement and potential incentivising Tyne & Wear could help steer operators towards

vehicle technologies that deliver significant emission benefits above those associated with the

Euro VI class. Diesel hybrid vehicles could deliver up to 40% reductions in CO2 compared to a

Euro V diesel with SCR.

There is also the potential for a Tyne & Wear Freight Consolidation Centre (FCC) which would

significantly reduce the number of HGV journeys travelling through the AQMA’s. This option

requires significant buy-in from both local and national hauliers and the LA’s but in the future

could deliver associated air quality benefits above and beyond vehicle upgrading. It can provide

a number of key benefits for the Tyne and Wear region including; reduction in lorry miles within

the city centre, contribution to reduction in carbon and noise, as well as freeing up road space

for public transport. On top of this there are benefits for the retail sector itself with the


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introduction of a FCC such as a reduced need for onsite storage and the potential to carry out

pre-retail activities before goods reach the stores.

NCC/GMBC needs to be seen to support existing business whilst attracting new business. An LEZ may be seen as a deterrent to this and so it would be preferable to use softer measures as part of the planning process to mitigate this instead. For new developments mitigation on a site by site basis should consider Section 106 requirements including the contribution toward/condition the use of a Freight Consolidation Centre.

6.2.2 Bus Quality Contract (pending)

Nexus are currently considering a proposal for adopting a Bus Quality Contract for Tyne & Wear

which would see operators become more uniform in fares, upgrade vehicles, and an investment

by Nexus / LA’s in Real Time Information and bus infrastructure.

As part of the Quality Contracts scheme operators would agree to upgrade existing fleets in

terms of cleanliness, security, and crucially efficiency. It is envisaged that specific vehicle

emissions requirements will be agreed with all operators with the rolling replacement of the

current fleets within set timescales. This gives the LA’s the opportunity to encourage and

influence the operators’ decisions and push for low emission vehicles to operate on set

corridors or within AQMA’s.

There is however another alternative in the form of Bus Quality Partnerships if the Bus Quality

Contract was to not go ahead. The Bus Quality Partnership is predominantly a commitment

between a local authority and travel company to deliver an improved bus service for a particular

region; this is based entirely on a voluntary joint working partnership. The scheme is reliant on

a full commitment from all the parties involved. In order to aid this, a clear purpose, set of

objectives and necessary duties are required to be set out before the partnership begins.

However, unlike the contract, enforcement can be an issue as the scheme is on a voluntary

basis. It is therefore important that it is clear from the start, the necessary expectations of each

party to ensure the smooth running of the partnership.

The proposed Urban Core Distributer Road would also contribute to reduced emissions as bus

journey times would be reduced/more reliable due to less traffic in the city centre. If a Euro VI

specification for buses is enforced then the second favourable Scenario LEZ 5 would be met

and achieve removal of exceedences in the urban core area. There are also conditions for

operators to meet bus DDA requirements, now superseded by the EA act of 2010, which may

also require vehicles to be replaced. Should these vehicles be replaced with new buses they

are likely to be powered by an engine in line with the most current Euro class.

The Department for Transport (DfT) is inviting local authorities in England to apply for Clean

Bus Technology grants of a maximum of £1,000,000 towards reducing oxides of nitrogen (NOX)

emissions from local buses. Newcastle and Gateshead are intending to submit a bid for these

grants which if successful would provide funds for retrofitting the least efficient buses operating

within the existing AQMA’s.

6.2.3 Taxi Licensing

The Taxis operating in Newcastle and Gateshead could be easily engaged and

encouraged/mandated to adhere to emissions standards over and above standard vehicles.

This could be done as a condition of issuing the licenses for Hackney Carriage and Private Hire

vehicles operating in Newcastle and Gateshead. Currently Hackney Carriages are stipulated to


52

use vehicles no more than 5 years old, however private hire vehicles do not currently have to

fulfil this requirement. As these vehicles are likely to make multiple trips daily within the urban

core area and AQMA’s of Newcastle and Gateshead it makes sense that they should be

targeted and engaged.

The existing licensing policy has the mechanism to enforce more stringently against emission

levels of vehicles. Given the age based condition imposed on Hackney Carriage vehicles these

vehicles are most likely to operate at acceptable levels of emissions. Private Hire companies

will need to be engaged and support from the LA’s by way of retrofitting grants is

recommended. Ideally if larger private hire firms are engaged they should be encouraged to set

a benchmark for a percentage of their fleet that is dual fuelled/hybrid/LPG.

The inclusion and monitoring of taxis may be enabled by the frequency of MOT’s as specified

by the local authority. Unlike heavy vehicles, it is extremely difficult to enforce emission

standards for taxis, as there is no reduced pollution certificate equivalent. Instead a maximum

vehicle age limit is suggested, with older vehicles required to demonstrate lower emissions

through use of approved technologies, such as alternative fuels.

Gateshead currently has an 8-year age limit on all Private Hire and Hackney Cabs licensed in

the borough, with new licences only available for vehicles less than 3 years old. There is

currently no taxi emission standard for taxis or private hire vehicles operating in Newcastle.

When Newcastle City Council revise their taxi emission policy consideration will be given to

applying a minimum emission standard of Euro 4. This standard would then be reviewed

regularly with the policy. A Taxi emission threshold should be set in accordance with Euro

standards and more detailed review of the existing private hire fleets would be required before

setting this.

6.2.4 Emission Thresholds, Monitoring, and Enforcement

Monitoring the effectiveness of the measure should be carried out via annual air quality surveys

at various “hot spots” within the LEZ extents and tailpipe emissions monitoring of willing

operators to establish if the modelled reductions are seen in ‘Real Life’. This would be in

conjunction with the existing permanent sites in Newcastle and Gateshead. The existing ANPR

network would be used where possible to reduce initial start up costs and the ongoing

monitoring would also utilise existing CEO’s.

The proposed thresholds to be applied would initially be Euro VI for buses and HGV’s in line

with those highlighted in Option 1. Taxis would need to have an alternative threshold agreed but

this would likely be Euro 5 unless significant economic hardship on self employed drivers was

identified. This would deliver air quality benefits ahead of the standard replacement rate curve

for several years.

Enforcement would be through voluntary agreement as is established in Norwich and Oxford.

However this would need to be reviewed and other legal frameworks pursued if emissions

reductions cannot be secured through voluntary means. Monitoring of HGV’s and Bus fleets

would need to occur periodically with evidence provided from operators regarding fleet Euro

class breakdowns and associated replacement plans.

6.2.5 Risks

As with Option 1 there is a risk that the predicted improvements in air quality associated with

each Euro class are not achievable in “real world” conditions. Furthermore whilst an LEZ


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approach would be legislative with consistent penalties for non-compliance this may not be

possible through direct operator engagement. Individual agreements would need to be reached

with the Freight Partnership member operators and ultimately the LA’s would not hold any

powers to enforce against non-compliance.

With regards to taxis and buses the operators can be penalised but not necessarily financially

for non-compliance. For example non-compliant taxis could be taken off the road until they can

demonstrate satisfactory emission standards. Through the Bus Quality Contracts scheme it may

be possible to set agreed financial penalties for non-compliance.

6.3 Additional supporting measures

In addition to implementing either of the previously discussed options there are several existing

frameworks from which air quality exceedences can be complementarily addressed.

6.3.1 LTP/ LAQM Action Plan

Local Air Quality Action Plans were produced for Newcastle and Gateshead centres in 2005

and 2007 respectively. The action plans described the processes that were in place and set out

the measures that were considered at the time necessary to deliver improvements in air quality.

As road transport has the greatest impact on air quality in Newcastle and Gateshead, the action

plans have now been incorporated into the Tyne & Wear Local Transport Plan (LTP3).

Measures included in the action plan to tackle air quality include:-

Parking Strategy to reduce attractiveness of car

Improve Public Transport Infrastructure to promote alternative travel modes

Pedestrian Priority measures

Cycle network improvements

ITS (Intelligent Transport Solutions) – reduction in journey time and delays

Park & Ride from site outside urban core area

Travel Planning to promote alternatives and reduce car use

6.3.2 LSTF Measures

Tyne & Wear were recently awarded DfT Local Sustainable Transport Funding to help relieve

congestion on the A1 Western Bypass and Newcastle City Centre. The money is being used to

invest in measures to promote sustainable transport across Tyne & Wear, and in particular

around the A1 Western Bypass. The measures will be achieved through the delivery of four

scheme packages:-

Improved Infrastructure – bus priority, cycle and pedestrian route enhancement, and

cycle parking at interchanges

Improved Travel Information – real time passenger information and marketing

Behaviour Change Measures – direct engagement with businesses and smarter

choices initiatives

Travel Support – for jobseekers

These activities are concentrated in four main employment areas – Newcastle city centre and

Baltic Quays, Team Valley, Metrocentre and areas of Washington, where it is anticipated that

an increase in the uptake of sustainable travel to work will reduce the number of short-distance,

work-related trips along the A1 that are the primary cause of congestion and delay.

The LSTF measures specifically target peak period journey to work trips in line with when air

quality issues are most prominent. Specific measures aimed at reducing traffic on the SRN in


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Gateshead associated with both the Metro Centre and Team Valley employment sites will

directly contribute to improving the air quality on the A1. Newcastle and Gateshead centre also

have specific measures aimed at achieving significant modal shift away from single car

occupancy.

As highlighted in the modelling section of the report, the key area beyond the urban core where

air quality exceedence is highest is along the A1 corridor in Gateshead. Whilst the A1 is beyond

the direct control of the LA’s the LSTF measures demonstrate that air quality mitigations can

still be implemented upon it.

6.3.3 Travel Planning / NPPF

Newcastle and Gateshead LA’s can support modal shift in all new developments through robust

travel plan targets. Primarily these will be most effective with residential and employment

planning applications and should aim to minimise journey to work trips by car. LA’s in Tyne &

Wear have begun to require a bond to be paid and held until developers can demonstrate that a

site is meeting its Travel Plan targets. This encourages developers to be far more pro-active in

reducing private vehicle trips and implementing supporting measures to encourage modal shift.

LA’s can establish a developer contribution model using section 106 contributions based upon a

tariff. The tariff would need to be linked directly to development impacts in existing AQMA’s.

Retail developments can be conditioned to achieve specific air quality targets for delivery and

servicing vehicles. This approach can be applied to any planning proposal generating vehicle

trips in an AQMA. In accordance with LTP Policy UC8 Freight and Servicing major new

developments located in the designated Freight Management Area will be required to provide a

Delivery Service Plan.

6.3.4 UTMC

Urban Traffic Management and Control (UTMC) is a central electronic database which

integrates the current systems of traffic management and information in a more efficient

manner. This helps to better manage traffic flow and congestion whilst making best use of any

existing highway assets. This can provided a number of benefits including, a capacity to store

air quality data on a common database. This provides an ability to utilise such information to

inform interventions in terms of air quality, therefore, providing better management of incidents

affecting the transport network.

6.3.5 Plugged in Places

Plugged in Places began in 2010 in the North East backed by funding to install recharging

infrastructure. To date over 1100 charging points have be installed across the North East. This

means that the North East is one of the most equipped regions for electric vehicles. This means

there is an increased potential to convert current conventional vehicle drivers to electric vehicles

as there is already a large network of infrastructure already available. This could be further

increased by enforcing new developers to add to the electric vehicle network as a condition of

planning.


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7. Outcomes

7.1 Recommendations

The work undertaken as a part of this study suggests that there is currently little justification for

a LEZ for Newcastle or Gateshead. This recommendation is based on the modelling outcomes

and analysis of the potential application to Newcastle and Gateshead which show;

The existing NO2 exceedences necessitating the respective AQMA’s in Newcastle

and Gateshead may be resolved through “natural” vehicle replacement.

An LEZ needs significant ongoing investment from both LA’s as revenue will be

significantly lower than operating costs. Implementation would need to use existing

ANPR and CEO’s within NCC/GMBC control to minimise ongoing costs.

Avoidance of the LEZ rather than conformity could cause traffic redistribution leading

to increased congestion on non LEZ mandated through routes.

Alive after five policies would be fundamentally at odds with LEZ and retail revenue

vs. air quality argument would be created.

7.2 Preferred Option

It is therefore recommended that Option 2 is progressed to reduce emissions through direct

dialogue with local organisations including the Tyne & Wear Freight Partnership, the proposed

Bus Quality Contract, and via Taxi Licensing.

This option combined with the natural replacement of private vehicles will reduce exceedences

within the existing AQMA’s and urban core area. There would be no start up costs associated

with this option and very low ongoing monitoring and enforcement costs as these would be

picked up by existing LA officers or be self monitored. The thresholds applied to buses, HGV’s,

and Taxi’s could be reviewed and adjusted following re-consulting with the relevant operators.

7.3 Future LEZ

Should vehicle emissions standards improve further in the future (Euro VII) or AQMA criteria

tolerances tighten, Newcastle and Gateshead would be well prepared to re-assess and

determine if an LEZ became viable.

7.4 Future Work

Following the work undertaken as part of this feasibility study there were several areas where

additional follow up work could/should be undertaken. These include:-

Undertake a review of background emissions applied as these may include some

double counting of emissions

The bus drive cycle applied in the modelling is based on work done by TfL. The bus

drive cycle in London is not based on having gradients on roads so there is uncertainty

on whether the emission profiles are transferable outside of London.

Concern was raised by Newcastle University on the impact that SCR abatement

technology will have on fuel consumption and carbon emissions. There is an apparent

conflict between climate change and air quality.


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There is uncertainty as to whether Euro 6 emission vehicles driving in an urban

environment will deliver the promised air quality improvements.

Health costs/benefits have not been considered within the remit of this study when

looking at the economic benefit of an LEZ.

There is a variation between the Tyne and Wear HGV/Bus fleet age profile and the

national profile applied in the study.

Regionally there needs to be a better understanding of the cost of poor air quality as at the

moment this information is simply not known. The local Strategic Health Authority (SHA) should

be consulted regarding the impact of air quality and its significance in terms of being a key

priority in terms of preventable deaths. Consideration should be given to ask the local SHA to

fund/research the linkage between ill health and air quality as this would help increase the

prioritisation of air quality.

Further work will need to be undertaken to assess the effectiveness of the LSTF projects

delivering air quality improvements alongside the modal shift. The LSTF projects include an

element of post implementation monitoring and the results from this will help inform if further

supplementary measures are required to improve air quality.

A significant number of diesel/hybrid buses introduced into Newcastle/Gateshead. It would

therefore be useful to investigate if the introduction of these cleaner emission vehicles has

improved air quality.


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Appendix A

Newcastle University Modelling Report

Capita Symonds Ltd

Quadrant

The SIlverlink North

Cobalt Business Park

Tyne and Wear

NE27 0BY

Tel +44 (0)191 643 4808

www.capitasymonds.com

newcastle / gateshead lez

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