No to revoking Cogan's Air Quality Action zone.

No to revoking Cogan's Air Quality Action zone.

Anne Greagsby with Max Wallis at the
Cogan NO2 sensor

This Vale Council proposal stems from NO2 pollution levels in 2016 being below the legal limit in 2016, according to the new annual report to Cabinet on 9th October  

Barry & Vale FoE strongly oppose revoking the AQMA (Air Quality Management Area).  They argue

## the Vale excludes high readings on Cogan hill, at the shops in the old Cogan Docks station.  The problem comes mainly from queuing traffic up to Barons Court, which needs tackling.

 ## the Welsh government now says the ‘normal’ high levels of NO2 (nitrogen dioxide) in Cogan are not 'safe', including when just below the legal limit.  It means Cogan still has a problem.

Barry&FoE wrote to Cllr Geoff Cox, the Cabinet member responsible for traffic pollution, urging the Council take seriously the new Welsh policy:

We notice that the report to Cabinet does not point out the tighter policy guidance on LAQM announced in June  (Local air quality management in Wales.  Policy guidance PG(W)(17)).

This says  the national air quality objectives are not ‘safe’ levels of air pollution, though the VoG policy till now has been to accept levels within those out-dated 'objectives'.

It adds that the Welsh government encourages Local Authorities or regional groupings "putting in place a local or regional air quality strategy... to keep levels of air pollution as low as reasonably practicable". 

the Council has to consult with the local community and to demonstrate that the legal limits ("objectives") are being met and will continue to be met (Policy Guidance s.4.14).

FoE points out that the Council data shows the limiting NO2 "objective" was again exceeded at the Marine Scene monitoring point (44.4 in 2016, compared with the 40 legal limit).  This position is at shops which people pass and where shop-workers stay for extended periods, opposite approved new housing development, and on essential "active travel" routes for walking and cycling between Cogan and Penarth Haven/Pont y Werin bridge.  This stretch of road should, FoE believe, be included in the AQMA and action taken to manage the polluting traffic queues.

# Air Pollution levels in Cogan high alarmingly

Friends of the Earth’s special pollution monitoring found alarming levels of NO2 pollution on Windsor Road in Cogan in February 2017.  Preliminary results show levels (61) were 50% higher than the annual limit of 40 microgrammes per cu metre.

Roadside monitor at Cogan
 Bus-stop.  

The Cogan results were from a monitor at the town-wards bus stop, where people are exposed crossing to the bus, waiting for it and even sitting in it. The level appears rather higher than the Council results from sensors on house frontages in the same road. FoE will therefore undertake further monitoring and cross-check the results against Council data. 
The Council’s air pollution report** of August 2016 suggested that results were improving in the Cogan “Management Area” but that may have just been a fluke of the weather.

Anne Greagsby assisted with the Cogan monitoring (picture below).  She says “The Council has for too long been complacent about harmful levels of vehicle pollution.  At last, the Welsh Government tells them it’s not safe for health, so let’s see some serious action.”

Data  (lab blank subtracted)    Corrected (taking bias factor 0.88**) in µg/m³

Cogan                          68.83^a                                      60.6

Murch Cross Rd                  39.31                                                     34.6

Crossing by shops              34.34                                                     30.2

  (55 Cardiff Rd)  

Eastbrook Stn                      31.20                                                     27.5

  (149 Cardiff Rd)

** bias factor for 2016 was unusually low at 0.78, still to be explained. The bias factor from the VoG’s own continuous monitor in 2016 at Cogan was 0.70, an unexplained difference.

^a The VoG diffusion tube results were also likewise very high over January-February 

Air Pollution Survey in Penarth

Friends of the Earth Pollution survey comes to Cogan

FoE Penarth activists, Anne Greagsby and Max Wallis pointing to the pollution testing tube attached to the telegraph pole, now taken down at the end of the 4 weeks exposure.

Local FoE activists collecting the pollution tube, after its 4-weeks exposure in Cogan, at the roadside by the Windsor Rd bus stop.  Queuing cars, buses and lorries make this a pollution hotspot. Too many diesel vehicles.  

Anne Greagsby is the Plaid Cymru Candidate for St Augustines ward. Vote Plaid if you want green policies with action 

Friends of the Earth have a nationwide initiative using NO2 (nitrogen dioxide) scientific diffusion tubes, supplied by Gradco and analysed in their labs.

The Barry & Vale FoE group have put up tubes in Dinas Powys and Barry, as well as this site.  Windsor Road, Cogan is a designated AQMA, where the Council has to monitor specially and come up with an ‘action plan’.  The Council has moved its special monitor from the Andrew Road corner to a box adjacent to the pedestrian crossing (second picture), where pollution levels appeared to be lower in 2014-15**, but by law they have to choose a site where public exposure to pollution is highest.** Vale of lamorgan Council: 2016 Air Quality Progress Report

  ** Vale of Glamorgan Council: 2016 Air Quality Progress Report    and here 

The automatic pollution monitor used to be at the Andrew Road corner.  Its high readings near or exceeding the NO2 limit (40 ug/m3) led to the decision to declare the Air Quality Management Area.  This area was drawn to include all the Cogan housing on Windsor Road, a few diffusion tube monitors showing high levels up the terrace too.  

The automatic monitor has read lower than co-located diffusion tubes in both 2014 and 2015, since it was moved from Andrew Road corner.  So there must be a question, is it sampling the air properly?.  

Results vary from year to year, largely die to weather conditions; the regulations require the worst weather conditions to be covered, so finding that 2014 and 2015 were low does not allow the VoG to revoke the AQMA and abandon their (non-existent) action plan.

The shops at the old Docks station (tubes at 'Marine scene') show readings of 40 or more .from 2011-2014, generally higher than the Andrew Road corner. The VoG report declined to extend the AQMA to include the shops and the corner businesses, as they said the general public is not exposed for long.

Now, however, the Council officers are recommending approval of new housing (44 social housing units), despite the probability of unlawful pollution levels.

The Air Quality assessment predicts air pollution will be no problem, on a model that predicts substantially lower NO2 levels by 2018.  The modelling is nonsensical

1. uses winds measured at Rhoose, far stronger and different directions from at Cogan
2. uses background levels scaled from Fonmon, instead of Cardiff area urban levels
3. assumes flowing traffic, not the stopping and starting vehicles up to the Terra Firma Way and Barons Court roundabouts. 
4. models the situation as a 'street canyon', which does not explain the highest levels being measured at the'Marine Scene' shops and Andrew Rd corner.  

The VoG measured lower NO2 levels in 2014, 2015, which they attribute to changed traffic light timings at Barons Court that reduced the vehicle queuing on Windsor Road.  Expected increases in traffic will worsen the queuing so move back towards previous excessive levels. The AQ modelling ignores this likely change.

The modelling cannot be considered fit-for-purpose.  A precautionary approach has to lay weight on the closest measurement sites (Marine Scene), assume that high NO2 emissions due to cheat-devices on diesel cars will not be corrected for some years, and assume that elevated emissions due to traffic congestion will worsen.      

'Final warning' for UK over breaches of air pollution standards

# gets far too low predictions so 'adjusts' with a fudge-factor of  3