Sutton’s Air Quality Action Plan 2019-2023


Sutton’s new Air Quality Action Plan was launched in June 2019, following a period of consultation. Although there is much to commend the new Action Plan, one of the actions suggests that it is going to take until 2021 (i.e. two years) to investigate options for creating a No Engine Idling Zone around a school at peak times.

The draft version of the Action Plan included an action to hold Car-Free Days, but this specific reference to Car-Free Days was removed from the final version due to lack of support in the consultation. The reasons cited by respondents, who disagreed with the Car-Free Days action, would suggest that some respondents did not fully understand the concept. Two conclusions may be drawn from this. Firstly, that the draft version did not make it clear what Car-Free Days entailed and that this was a failure on the part of those responsible for the preparation of the documentation. Secondly, despite the comments received, the original wording of the Car-Free Day action could have been retained in the final version by simply including an explanation that Play Streets were part of the Car-Free Day initiative.

The Action Plan notes that the main sources of air pollution within the borough are emissions from road traffic. Therefore, to seriously address air quality, more people need to look at other options than the car for some of their shorter journeys. Nevertheless, there is no reference to traffic reduction in the Action Plan but rather references to smoothing traffic flow. When it comes to walking and cycling, it is still more about encouraging than it is about enabling.

Only 8 per cent of respondents to the consultation were under the age of 34. Whereas, 59 per cent of respondents were aged between 45 and 75.


Sutton Council launched the borough’s latest Air Quality Action Plan on 21 June 2019, Clean Air Day. The publication was announced on the council’s news stream ‘New Air Quality Action Plan launched on Clean Air Day‘. A consultation on the draft version of the new Action Plan had been held between December 2018 and February 2019. The final Action Plan revises and updates the previous version published in 2013.

To mark Clean Air Day 2019, Sustrans published a short film to remind us that at least 4.5 million children in the UK are growing up in areas with unsafe levels of particulate matter (a reference to the UNICEF report of June 2018 “Breath of Toxic Air: UK children in danger”). The producers caught up with pupils of Hitherfield Primary School in Lambeth, south London, to find out why they are worried about air pollution and to talk about what they do to show they care about the air around them. (There is hope for the future).

Suttons’ Air Quality Action Plan (AQAP) can be accessed from the council’s website through the link Air Quality Action Plan 2019-2023. It is also available from our Publications page (June 2019). The AQAP will monitor the delivery of the targets for ‘Cleaner Air’ that were set out in Sutton’s Environment Strategy 2019-2015, published just over two weeks earlier at the beginning of June 2019. Sutton’s Environment Strategy can be accessed from the council’s website through the link Sutton Environment Strategy 2019, and is also available from our Publications page (June 2019). Our brief overview of the Environment Strategy, focusing on the ‘Cleaner Air’ chapter, can be read here.

In total, the AQAP lists thirty-six actions with the priority top ten listed in the Conclusions section of the document (page 42). Twelve of the actions are categorised within the ‘Cleaner Transport’ theme (and four of these are defined as priority actions), see Figure 1.


Figure 1: Table detailing twelve actions in the ‘Cleaner Transport’ theme

The AQAP re-states the commitment to improve air quality in the borough, with an aim to make Sutton the greenest borough in London. There is recognition within the AQAP that “poor air quality has been rightly described as a public health emergency“, and that “in Sutton an estimated 7.5% of premature deaths each year are due to air pollution“.

However, some aspects of the Action Plan do not instil a great deal of confidence in the council’s aspirations. Two such examples are discussed in this review, which focusses on the ‘Cleaner Transport’ themed actions. The first example relates to the timescales set out to discourage unnecessary engine idling, and the second looks at the reasons provided for changing the wording of a proposed action that, prior to the consultation, had made reference to holding car-free days.

A few observations are also made in regard to one or two of the other ‘Cleaner Transport’ themed actions, and some background and context is provided in the caption attached to Figure 2: Map showing the Air Quality Focus Areas within London Borough of Sutton, (page 4 of the AQAP, and available from the London Datastore: London Atmospheric Emissions Inventory (LAEI) 2013 Air Quality Focus Areas).

Referenced documentation

Sutton’s Air Quality Action Plan 2019-2023 (LB of Sutton, June 2019)

Review of the Council’s Air Quality Action Plan (LB of Sutton, February 2019)


Figure 2: Map showing Air Quality Focus Areas within London Borough of Sutton 
In 2013, the whole of the London Borough of Sutton was declared an Air Quality Management Area (relating to pollutants NO2 and PM10). At the same time, three Air Quality Focus Areas (locations that not only exceed the EU annual mean limit value for NO2, but are also locations with high human exposure) were defined for the borough (reviewed in 2016). These areas are:
158: Sutton – A232 Cheam Road/Carshalton Road/Sutton High Street/Brighton Road;
159: Wallington – Manor Road/Stanley Park Road/Stafford Road;
160: Worcester Park – Central Road/ Cheam Common Road.
These are not the only air pollution hotspots in the borough, but they are the areas where the problem is most acute. In addition to these defined areas, the main roads where air quality is affected by transport emissions the most in the borough (AQAP, pages 6 and 7) are:
A217 between Rosehill and Belmont;
A232 between Cheam and Waddon;
A237 between Hackbridge and Woodcote;
A24 between Morden Park and North Cheam;
B2230 between Sutton town centre and Belmont;
B271 Between Wallington and Woodcote

 How difficult is it to discourage unnecessary engine idling?

Although there is recognition within the Air Quality Action Plan that “the main sources of air pollution within the London Borough of Sutton are emissions from road traffic“, the Action Plan declares that it is going to take two years “ investigate options for creating a No Engine Idling Zone(s) around a school at peak times..” (Action ID 1; pages 13 and 14), and Figure 3!

“Investigate options for creating No Engine Idling Zone(s) around a school at peak times by 2021”


Figure 3: How difficult is it to discourage unnecessary engine idling?

Two years to “investigate options” for “creating [one?] No Engine Idling Zone” outside a [one?] school! Where is the sense of urgency? And why would such a simple action, to investigate options for something as relatively straightforward as this, take two years to implement anyway? has more, including the excellent ‘Be an Idol, don’t Idle‘ flyer (Figure 4).


Figure 4: ‘Be an idol, don’t idle’ from MumsforLungs

Where are the references to school streets?

When it comes to motor vehicles around schools, however, the discussion really needs to move on to ‘School Streets’. To find out more about the what, the why, the how, and the where, officers and councillors need look no further than All the information, all in one place.

Whatever you do, do not mention car-free days (or explain what they entail)

The draft version of the Air Quality Action Plan, which went to public consultation between December 2018 and February 2019, included an action to ‘Hold Car-free Days and similar campaigns to raise awareness of benefits of not using a private motor vehicle‘.  In the final version of the AQAP, the description of this action (pages 16 and 17) has changed to ‘Support communities wishing to enact temporary road closures, encourage Play Streets and run campaigns to raise awareness of benefits of not using a private motor vehicle‘. Only a subtle difference, perhaps, but the specific reference to car-free days has been dropped. See Figure 5.


Figure 5: Car-free days – a subtle change of emphasis

So, why doesn’t the final Action Plan, unlike the draft version, include a specific reference to car-free days? The council’s interpretation of the reason for this is provided on page 46 of the Action Plan in ‘Appendix B Reasons for Not Pursuing Action Plan Measures’: “The proposal to run Car-Free Days was the only action which did not receive a positive net agreement from the public consultation. Therefore, an action has been retained but the wording has been changed to reflect the public’s concerns and ensure that the action is community led”.

In light of that response, can we understand why the proposal to run car-free days did not receive a positive net agreement from the public consultation? And do we know more about the concerns expressed by the respondents to the consultation survey? ‘Appendix A Response to Consultation’ (on page 43 of the AQAP) comments further on this, with “Lack of support for Car-Free Days so action changed to reflect concerns of people who may need access to a vehicle while still supporting communities that want to make their neighbourhood streets more suitable for playing out”.

The phrase “…concerns of people who may need access to a vehicle..” is fair enough at face value, but what does that concern have to do with a car-free day? Car-free days are not about preventing people from driving, whether they need access to a vehicle or not. Car-Free Days are about raising awareness, trying something different. Trying something different includes Play Streets (see ‘The 8 Pillars of Car Free Day: 1. Celebrate our greatest public space with 200 Play Streets’ at Given that Play Streets are part of the Car-Free Day initiative, did the decision to remove the reference to Car-Free Days in the updated action need to be made?

More importantly, why didn’t the draft version of the AQAP for consultation make it clear what Car-Free Days entail? This would possibly have prevented this action from being one that “did not receive a positive net agreement”. Would it be fair to say that the omission to describe the concept of Car-Free Days in the consultation document was a failure on the part of those responsible for its preparation?

Another question that needs to be asked is why didn’t officers (and others who reviewed the responses received to the consultation) respond by saying that Play Streets were part of Car-Free Days, and therefore, despite the comments received, would retain the Car-Free Day action? After all, according to, sixteen London boroughs have (so far) made the Car-Free Day Play Street Pledge 2019. And presumably none of these sixteen boroughs are aiming to be London’s greenest or most sustainable. Or are they?

For an idea of the sort of comments received from respondents to the consultation in reaction to the idea of holding Car-Free Days (and the two other least supported Cleaner Transport proposals), we can take a look at a report that was presented to committee members at the E&N Committee meeting on 7 March 2019 as a review of the AQAP consultation and analysis of the findings (Item 39: Review of the Council’s Air Quality Action Plan > Additional Documents > Review of the Council’s Air Quality Action Plan Appendix B).

Respondents were asked if any of the Cleaner Transport proposed actions should not be included in the Air Quality Action Plan and to explain why. 44% of respondents disagreed with Action 4: Car-Free Days. For a variety of reasons, respondents felt that they would not be practical. Four of the comments associated with this action are provided in the consultation review document as follows (also see Figure 6):

“Car Free Days. Not always practical if an emergency occurs.”
“We have areas in the borough where you cannot drive car down. By having car free day will result in increase in traffic elsewhere causing added unnecessary air pollution.”
“Public transport is unreliable and expensive-as a person who has to move employment site within 20 mins, I would not be able to do this on PT.”
“What a ridiculous suggestion. I have a disabled child who needs to get to appointments and I rely on having access to a vehicle to make it possible for us to get there. This could be any day of the week.”


Figure 6: Car-free days, and concerns expressed by some respondents to the AQAP consultation

The table in Figure 7 lists each of the ‘Cleaner Transport’ actions in order of priority as a result of the consultation. Car-Free Days is bottom of the list.


Figure 7: Table listing each of the ‘Cleaner Transport’ actions in order of priority from the consultation. Extract from Review of the Council’s Air Quality Action Plan Appendix B (essentially a report on the consultation and the findings), page 9. The Support is highest for improving public transport (80% net agree), while car-free days has the lowest level of support (-5% net agree).

It is worth noting the headline demographic of the 391 respondents who responded to the survey on the draft AQAP (as provided in the review document):

59% of the respondents were aged between 45 and 74 years old.

Just 8% of the respondents were under 34 year. 

[Population Estimates for Sutton (2018) report that those aged between 45 and 74 make up 34% of the total population of the borough (and comprise 44% of those aged 18 and over); those aged between 18 and 33 represent 18% of the total borough population (or 23% of all those aged over 18). In other words, there are around twice as many people aged between 45 and 74 residing in the borough in comparison to those aged between 18 and 34. Nevertheless, even when taking this into account, it is clear that the consultation did not reach out to the younger cohort to such a degree as it did to the older age range]. Source: nomis.

What are we trying to achieve in the long run?

A final point on this ‘ditch the idea of holding a Car-Free Day nonsense’ action. It is worth noting that the change of wording in the description of the updated action has subtly changes the emphasis.

The description was: “The days / campaigns will be focused to act as precursors to larger scale highways interventions and improvement schemes”.

The description has become: “The days / campaigns will be based around needs identified by local communities and will be focused to act as precursors to larger scale highways interventions / improvement schemes”

As a result of this change of wording, the action has effectively changed from something that the council (Liberal Democrat administration) would like to happen, to one that will only happen if the community comes forward with a proposal. That would seem to a very fair and reasoned line to take. Everyone would think that the greater the community support had for an initiative, the more likely it would be to succeed. Engagement, having that conversation, is essential of course.

However, it would appear from a number of projects in some other parts of London, most notably perhaps the award-winning mini-Holland borough of Waltham Forest (see below, that ideas that have initially received a lot of opposition have gone on to be well received. So that would suggest that it can be better to focus on the outcome (based on evidence), and to retain the courage of your convictions.

In other words, rather than taking the “don’t scare the horses” approach, the “easy” approach, the “keep the status-quo” approach, the “consider the here and now” approach, where nothing changes, sometimes it can ultimately be more rewarding to take the “try it and see” approach, the “more challenging” approach, the “what do we want for the next generation” approach.

Isn’t it preferable to focus on achieving the outcome – an improvement to air quality, so reduce the risk of premature death associated with airborne pollutants – rather than worrying about some short-term inconveniences (which are generally perceived, rather than actual)? Therefore, rather than ditch the idea of holding Car-Free Days as a concept, embrace the “what’s best in the longer term?” approach.

Update: Sutton Council mentions Car Free Day in this tweet on 12 July (as does @LBSEnvironment here on the same day). So, the idea has not been completely forgotten, and great to see that Sutton is now trialling play streets!


Figure 8: Sutton Council accepting applications for Play Streets (LB of Sutton | Twitter | 14 July 2019

Waltham Forest recently received the award Clean Air in Towns and Cities from Ashden, (3 July 2019). “The London Borough of Waltham Forest has taken bold steps to clean up its air and get people moving, with its multi-million pound ‘Enjoy Waltham Forest’ scheme. Road redesigns, bike training, extra cycle storage and school workshops have made the borough a safer, nicer place to walk and cycle”.

It’s still all about “encouraging” rather than “enabling” cycling

One of the actions identified within the ‘cleaner transport’ category is titled ‘Provision of infrastructure and support to encourage a modal switch to walking and cycling‘. Very good to see, but it would be better if this was framed in terms of enabling, rather than simply encouraging, cycling. This is a point that has been made for a quite a while now, since at least the publication of Space for Cycling: Action points for Sutton in 2014. After all, cycling is enabled through the combination of the provision of infrastructure and low-traffic neighbourhoods. Cycling will then be encouraged through support (which may include training, promotion, and so on). Consequently, the word enabling more correctly reflect the action here. On the other hand, of course, it could be argued that the use of ‘encourage’ more correctly reflects lack of aspiration, lack of political will, lack of ability, and lack of funding in actually making the case and rising to the challenges. And all of that can be summed up in the phrase “all too difficult”.

The following timescales are given for the implementation of the ‘provision of infrastructure’ action:

  • Ongoing;
  • Targets from Sustainable Transport Strategy are to increase % of journeys made by walking from 24% to 30% and cycling from 1% to 2.2% by 2020. Then work towards 2025 targets of 32% and 4% respectively. [NOTE: The current Sustainable Transport Strategy, published in June 2015 with subsequent review updates provided annually (although the June 2019 update is still awaited) gave the 2.2% target date for cycling as 2017. The date was subsequently changed to 2020 in the June 2018 update, with no explanation given and no questioning from councillors as to why this had happened].
  • Pedestrian and cycle link improvements to Beddington Lane by end 2019 [see Beddington North TfL Major Scheme] and pedestrian and cycling connection improvements between Roundshaw and Wallington by 2020.
  • Implement Quietways routes (Morden – Sutton and Worcester Park – Sutton) by end 2020 [see Sutton’s proposed first Quietway: the conversation begins];
  • Review / Update of Walking & Cycling Strategies by 2023

In the draft version of the AQAP, the third bullet point above, referencing Beddington Lane, was omitted. In its place was:

In both versions of the AQAP, the ‘Further Information / Comments’ section for the ‘Provision of infrastructure…’ action contains the text :

“Most work will be carried out using existing resources or as part of the LIP programme. However, further funding streams will be sought to help deliver additional improvements”.

“Using existing resources as part of the LIP (Local Implementation Plan) programme”. Is that good? There is more about LIP, both in terms of the updated longer term plan and the annual finding settlement, in the recently published post Sutton’s Third Local Implementation Plan Receives Approval. “Further funding schemes”, which hopefully means the bigger money projects (Liveable Neighbourhoods and easily navigable Quiteways/Cycleways that feel safe and inviting), is potentially much more promising

It’s still more about smoothing traffic rather than Healthy Streets

Another action identified within the ‘cleaner transport’ category is titled ‘Implement
measures to control speeds and smooth traffic flows in residential areas where pedestrians and cyclists are to be given greater priority
‘. The description of this particular action would be greatly improved if it did not include reference to ‘smoothing traffic flow’.

The phrase ‘smoothing traffic flow’, with its connotation that the overriding priority is to ensure that motor traffic flows freely, is now outdated – especially so in residential areas. (The phrase is used a lot, unfortunately, in the Sutton Local Plan 2016-2031 (adopted February 2018, LB of Sutton), and this is discussed quite extensively in our recent post What are Sutton’s key borough traffic reduction objectives?).

Clearly, queuing traffic and traffic congestion is not desirable, but experience tends to suggest that whatever mechanisms are employed to minimise inappropriate levels of motor traffic, ultimately, tend to generate more. When traffic is not free-flowing, it is because there is too much traffic.

And why is there too much traffic? The borough’s Sustainable Transport Strategy (LB of Sutton, June 2015) reminds us that “over 50% of car journeys in Sutton are less than 5 km (3 miles)”, and that “a considerable proportion of car journeys could therefore potentially be replaced with more active and sustainable forms of travel”. Put simply, we tend to drive rather than travel by more active and space efficient means. Changing our behaviour (drum-roll Smarter Travel Sutton 2007-2009) requires a little more physical effort, and certainly requires the conditions to be appealing (high-quality cycling infrastructure and low traffic neighbourhoods).

The Healthy Streets Approach, published in early 2017 (see Healthy Streets for London), is all about a vision where streets are designed for people. As John Parkin succinctly notes in ‘Designing for Cycle Traffic: International principles and best practice’ (ICE Publishing, 2018), “This approach of conceiving a street in terms of healthiness comes with an extremely valuable plain-language summary describing descriptors…. The key words in the indicators are a world away from the usual words connected with street appraisal, such as ‘traffic flow’, and include such words and phrases as ‘welcoming’, ‘encouraging’, ‘reducing inequalities’, ‘experience’, ‘comfortable’, ‘ambience’, ‘human interaction’, ‘convenience’, ‘resting’, ‘meeting’, ‘shelter’, ‘relaxed’, ‘interesting’ and ‘stimulating'”.

So, move over smoothing traffic flow, and step forward Healthy Streets. Otherwise, as Sutton’s population increases (at is predicted it will), and if this population increase results in more car generated trips, the idea of sustaining traffic flow will become increasingly more difficult to realise.

It is good to see reference to Healthy Streets in one of the identified actions. This does not relate to the ‘Cleaner Transport’ theme though, but rather to ‘Emissions from developments and buildings’ (page 39): ‘Ensure that Air Quality Positive and Healthy Streets approaches are incorporated within future master-planning and redevelopment areas‘. Still, good to see, especially as the ‘Timescale for implementation’  notes “All officers involved with major schemes to have received training on Healthy Streets Check and to apply the checklist to all schemes from April 2019“.

Supporting the Mayor’s Transport Strategy

One of the priorities for the council, as detailed in the ‘Summary’ section of the AQAP, is to support the objectives and priorities within the Mayor’s Transport Strategy. “This focuses on providing healthy streets for healthy people, traffic reduction strategies and a good public transport experience. We will deliver schemes that support people being active and enhance safety including improved infrastructure for pedestrians and cyclists such as the Beddington Major Scheme programme”.

That all sounds very promising, and it is good to see recognition being given in the Air Quality Action Plan that the council has a priority to support the MTS whilst recognising the focus on traffic reduction strategies. There is some temptation, though, to look on this with a little doubt as to its sincerity. And the reason for that doubt is discussed in What are Sutton’s key borough traffic reduction objectives?.

In conclusion

We wish Sutton Council well in taking forward the new Air Quality Action Plan 2019-2023, and await the annual publication of updates on progress with interest.

It is hoped that it won’t take two years to investigate options for creating a No Engine Idling Zone(s) around a school at peak times, and that the council will become more pro-active in promoting Play Streets and School Streets. (Noting that Play Streets are being trialled in 2019).

It is also hoped that the council will continue to engage with communities, whilst being more robust in making the case for interventions that focus on achieving the desired outcomes (even though that may be challenging at times). It is very important for people to get involved, but it is equally important for the community to recognise that it has a voice but not a veto. (There is more on this in the Liveable Neighbourhoods 2019 Guide to Best Practice).

Consideration needs to be given as to how to engage the younger cohort of residents (and other under-represented sections of the community) to more readily take part in consultation responses.

Plenty of research-based evidence is now available that can provide strong support for interventions that have until quite recently would have been difficult to progress. There is evidence that supports the urgency for action, and there are case studies that demonstrate how schemes that did not initially garner support became popular and desirable once completed.

Our previously published articles relating to air quality

The Video you can’t afford to miss (October 2017)

Air pollution video – what happened next (part 1)? (April 2018)

Air pollution video – what happened next (part 2) (April 2018)

v1: 20.07.2019

Posted in Advocacy, News

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