This is our response to the consultation on Brent’s Air Quality Action Plan, concluded 30 March 2017.

How do you feel about air quality in Brent?

This response is from Brent Cyclists, the local group in Brent of the London Cycling Campaign. We believe air quality in Brent is poor.

In your opinion, are there other actions the council should include in the plan?

The council should create a comprehensive network of safe cycle routes

Please tell us what you like most about Brent’s Air Quality Action plan and why?

Reducing vehicle use associated with schools (p5)

Please tell us what you least like about Brent’s Air Quality Action plan and why?

The lack of detail and basic failure to engage with the necessity of reducing the use of motor vehicles in the borough are major problems with this plan.

Air quality will not be significantly improved without reducing motor traffic. The key to doing this is to create the conditions where people feel they do not need to use cars for journeys of less than 5 miles. The only entirely non-polluting mode of transport that can fill this gap is cycling. Though the ‘Summary Document’ mentions at the beginning ‘active travel such as walking and cycling’, the plan itself, extraordinarily, makes no mention of any strategy to transfer journeys to walking and cycling. It is thus left with a huge hole.

Words like ‘weak’, ‘nondescript’, ‘noncommittal’ and ‘meaningless’ come to mind when reviewing the actions outlined in this plan. It is almost totally lacking in measurable actions and targets.

The use of the term ‘green infrastructure’ is confusing. When we talk of ‘green infrastructure’ we mean infrastructure to allow active travel. This plan uses the term to mean barriers to contain pollution, not infrastructure that will enable people to change their travel behaviour so as to reduce pollution.

We can’t really see the rationale for any part of the borough being outside the ‘Air quality management area’.

The plan is all ’promoting’, not ‘enabling’ and not ‘enforcing’. For example, one elementary start to creating better conditions for active travel would be to make the entire borough a 20mph zone, but nothing like this is mentioned. Another measure might be to exclude motor traffic from roads round schools, ending the school run by car. But there is no sign of anything meaningfully impactful like this in the plan. School travel plan schemes on the roads in the past have been trivial and ineffective, and there is no sign here of this changing.

It is not really clear what Action 13 (planning controls) means. Does the requirement for new development to be ‘air quality neutral’ include all the transport impacts? It is hard to see how any development could ever have no impact on local air pollution unless it is accompanied by major mitigating cycling, walking and public transport infrastructure, which has never (so far) occurred in Brent.

The key to getting more cycling is to provide safe infrastructure for it, and this involves, to large extent, making political choices about how road space is used that are very different from the ones currently made. The plan makes no attempt to engage with this central issue.

This plan as it is definitely will not lead to a significant improvement in air quality in Brent.

In your opinion, how can the council help residents play their part in improving air quality in Brent?

By taking practical measures to make it the obvious and attractive option to cycle journeys of less than 5 miles, as outlined above.