Alongside developing a new Climate Strategy, Richmond Council is also currently consulting on its Draft Air Quality Action Plan. We have some suggestions below for anyone looking to complete this survey before it closes on 20th January 2025.
You might have already sent a response, but please consider resubmitting if you agree with the points we’ve made below and hadn’t included them earlier.
We’ve highlighted our suggestions in green below. Consider rephrasing them in your own words wherever possible.
This article won’t tell you how to answer every question, but it will offer some ideas for further thought and action alongside the multiple choice options available.
The Greens have already suggested significant improvements to the first draft document prior to this consultation. With your help, we can encourage the Council to go further and set specific targets for improving air quality.
Step 1: Visit the website
The online survey here takes around 10-20 minutes to complete, or even less time if you use our suggestions below.
Select “Click here to begin the questionnaire” then press the “Continue” button in the bottom right.
You’ll be asked to explain why you’re responding to the survey and to provide your postcode.
Step 2: Our plan
In this section, you can express how much you agree with the overall strategy of targeting action on the most polluted areas, and the groups who will most benefit from reducing air pollution.
Under Are there any other approaches you would like to suggest?, we’d recommend adding any of the following in the “Other” box:
While I welcome the council’s ambitions to improve air quality, I’m concerned by the onus on vulnerable people to take action to protect themselves by avoiding busy streets and smoky environments. The Council should be creating a safe, healthy public realm for all residents, not telling our most vulnerable to restrict or change their activities and avoid places that might harm them. Has this document been shared with organisations such as Asthma & Lung UK and the British Heart Foundation? If not, I suggest consulting them to get their views on appropriate action and language. I’m also concerned about the Council’s potential overreliance on nudge methods, “subtle and indirect approaches that influence people’s choices and actions”, rather than implement policy-based interventions to address the urgent social and ecological crises we face.
Under Are there any aspects of the plan you think should be prioritised?, you could add:
Assigning clearer strategic and measurable targets to all actions, especially on School Streets. There’s potential for more School Streets (and Play Streets) and to create new ones as required, but what does this mean in practice? The Council should set targets year on year and roll out a programme to assess the impacts of social inequalities on air quality, including attempts to measure traffic levels around private schools and to improve engagement with the non-state school sector in Richmond. Similarly, on school travel, the Council should aim to have all schools certified under the Travel for Life scheme and encourage participation in Clean Air Day, Beat The Street, Living Streets’ Walk to School Month and Sustrans Big Walk and Wheel. Clean Air Night also needs greater public and media attention, especially around wood burning. Are there targets for enforcement of smoke control areas and plans to engage retailers selling fuel?
Step 3: Priority locations and groups
Under If there are any additional locations you would suggest, please tell us here, you could add:
I’d like to see new cycle routes and cycle parking facilities, including conversion of car parking spaces to cycle hangars (which also allow for cargo bikes), as well as planned improvements for specific existing sites listed and detailed in this plan.
Under If there are any other actions you suggest specific to a target location, please tell us below, you could add:
Other than a general reference to “improvements”, there are no mentions of improving pedestrianisation, trialling street closures for events in our town centres, car and cycle parking policy, or car-free developments in good public transport accessibility level (PTAL) areas. While page 11 references the public realm changes in East Twickenham leading up to Richmond Bridge, i.e. tree planting and widening of pavement, have these actually reduced air pollution in the immediate area, and importantly, outside the school? Does traffic remain at the same levels as prior to these changes? The crossings on Wellington Road and Shacklegate Lane have been in place for a couple of years; is the Council referring to these or are you adding new ones? In Barnes, are there plans to extend cycle route C57 which currently ends at the Wetlands?
Under If there are any additional transport measures you wish to propose, please tell us here, you could add:
There’s very little about traffic reduction in this plan and how it will be achieved, especially reducing private car usage for short trips, increasing controlled parking zones across the borough, creating more priority bus lanes, introducing a workplace parking levy and converting current car parking space to more effective use. Understandably, it’s not possible to be specific about plans while the revisioning project is ongoing but, having recognised that a significant proportion of traffic through Richmond Town Centre is through traffic, saying that this area will be ‘improved’ means what exactly? How about trialling some closures such as George Street during the summer on Sundays and/or Bank Holidays? These attempts at reducing private car reliance need to be balanced with greater investment in the accessibility, reliability and safety of active and public transport.
Under If there are any additional groups you think should be targeted, please tell us here, you could add:
The Council should work with local organisations, sports clubs and attractions such as Kew Gardens, Hampton Court Palace, Twickenham Stadium, St Mary’s University, Ham House and Strawberry Hill House, among others, as well as organisers of the summer fairs and one-off sporting events, to ensure air quality and sustainability more generally, including provision of adequate cycle parking at minimum.
Step 4: Areas of action
Under If you have any other suggestions for areas of action, please tell us here, we’d suggest adding any of the following:
I’d like to see a specific reference to walking bus schemes, which several other councils are promoting on their websites and elsewhere. There is no mention of black cabs and private hire vehicles (PHVs). Surely the taxis that idle outside Richmond Station are a barrier to progress on air pollution, as is the number of PHVs. What action is the Council planning to take to deal with this? We could also benefit from further changes to policy towards Lime Bikes and similar electric vehicle hires, including at least one day per year when the bikes are free to use.
Step 5: Appendices
Under If you have any other suggestions for areas of action, please tell us here, we’d suggest adding any of the following:
Under Are you satisfied with the rationale and evidence presented?, we answered Yes.
Under Please give a reason for your answer, we suggest:
I’m satisfied with the rationale and evidence, but the lack of specific and measurable targets in this action plan is concerning.
Under If there is any additional evidence you would like to see, please tell us here, we’d suggest adding any of the following:
Re the traffic reduction target (page 16) of 5-10% in vehicle per km by 2041 — how does this square with the London Mayor’s Transport Strategy (page 25) to see traffic reduction of 27% by 2030 compared to 2020? Similarly, the long-term aim (though unclear ‘long-term’ means in this context) is to reduce kilometres driven in and through the borough, but there are no specific targets on how this will happen year on year.
Step 6: Further comments
Under Please use this space for any further comments about the Richmond Air Quality Action Plan, we suggest you add:
The glossary definition of NOx appears to be incorrect. NOx refers generally to air pollution relevant mono-nitrogen oxides (NO and NO₂), not “gases that can turn into NO₂”.
Step 7: About you
Finally, you can choose to complete the optional questions about your background and leave your email if you would like a copy of your response.
Once again, here’s the link to the online consultation survey. Please submit your response by 20th January 2025, and let us know what you think of the process.
Also by the 20th, please consider raising your concerns about air and noise pollution from aircraft travelling via Heathrow Airport with Hillingdon Council using this advice from the East Twickenham Heathrow Campaign.
You can keep track of Richmond Council’s progress by visiting the Council Climate Action Scorecards website, which will be reporting again later this year.
