Havering Friends of the Earth

Our response to Havering Council's 2025 Air Quality Action Plan (AQAP)

Havering Council has published an updated AQAP for 2025-30, to replace the previous version dated 2018-23. As part of their consultation process, we've submitted the comments below, which were compiled by Graeme Grieve with the help of ChatGPT. The new Plan can be viewed via the AQAP consultation page on the council's website.

Summary

The Havering Council 2025-30 AQAP appears well-organised and compliant, but it is strategically weak and operationally cautious. It is not ambitious enough, not measurable enough, and not resilient enough to deliver the step-change in air quality that Havering requires.

Most significant weaknesses

• Few measurable targets → progress cannot be assessed.
• Little new action → largely a continuation of previous work.
• Undelivered 2018-23 commitments simply rolled forward.
• Insufficient monitoring improvements.
• Weak fleet electrification.
• Overreliance on awareness campaigns.
• Funding risks not mitigated.
• Important Plans Missing.

Overall conclusion

The Plan is cautious rather than transformational. It lacks the bold, quantifiable, and strategic measures needed to meaningfully reduce NO₂ and PM2.5 exposure in a rapidly growing suburban borough with known transport emissions challenges.

Detailed criticisms of Havering Council's AQAP

1. Lack of Clear, Quantified Targets and Key Performance Indicators

   The Plan contains many actions, but very few measurable outcomes. Most actions list:

   • broad intentions (e.g. “promote”, “seek funding”, “encourage”, “support”)
   • no baseline data
   • no measurable targets
   • no expected emission reductions
   • no timeline milestones beyond “ongoing”

   Examples:

   • “Seek funding for a Low Emission Neighbourhood” (no timeline).
   • “Raise awareness of anti-idling” (number of events, but no emissions impact).
   • “Increase BEVs in the Council fleet” (no % target, no years).

   Why this is a problem

   Without KPIs, no-one can tell if the Plan is succeeding, and it does not allow benchmarking against other London boroughs or even against Havering’s own 2018–23 commitments.

   Critical verdict: The Plan is action-heavy but outcome-light. It cannot credibly demonstrate success or value for money.

2. Heavy Reliance on Actions That Are “Ongoing” or Not Time-Limited

   Many actions are listed as “ongoing” with no clear start or finish. Examples:

   • Anti-idling enforcement.
   • School engagement programmes.
   • EV charging point rollout (annual rolling programme).

   This produces a Plan that often reads like a continuation of ‘business as usual’ rather than a new strategic framework.

   Critical verdict: Too much continuity, not enough step-change. Very little is actually “new”.

3. Weak Ambition in Key High-Impact Areas
   1. Fleet Electrification

      Still exploratory, despite being identified as a top priority. No target such as:

      • % fleet BEV by 2027
      • phasing out diesel vehicles

      Critical verdict: The Plan lacks credible commitments for one of the most controllable emissions sources under Council control.

   2. Walking & Cycling Infrastructure

      The Plan states the Council will “develop and maintain” a strategy. It does not commit to any:

      • km of new cycle lanes
      • protected corridors
      • junction improvements
      • funding
      • modal shift targets

      Critical verdict: No delivery commitments—only planning commitments. This is a missed opportunity.

   3. School Streets Expansion

      The Plan proposes “rolling delivery of six School Streets per year”. But starting from a low base (3 currently operating), this is unambitious compared with:

      • boroughs implementing 30 - 100+ School Streets
      • high local car dependency and known hotspots

      Critical verdict: Too modest relative to borough size, population, and risk profile.

4. Important Plans Missing

   The Plan should include the following actions:

   1. Toxic Air Pollution from Landfill

      The council should provide regular information text updates, should facilitate speedy remedial action with landowners if land is privately owned, and provide refuges for vulnerable residents to avoid health impacts when the fires occur.

   2. Particulate Air Pollution Mitigation Measures for Nurseries, Schools and Care Homes

      The council, as a matter of urgency, should address the impacts of air pollution where nurseries, schools and care homes are in areas where static traffic abuts the premises. The council should advise on mitigation measures. Indoor air pollution of nurseries, schools and care homes should be assessed and mitigating measures instigated.

5. Continued Reliance on External Funding With No Contingency Paths

   Havering frames many actions as “subject to funding availability”, but presents:

   • no match-funding pipeline
   • no prioritisation methodology
   • no fallback plans
   • no phased/low-cost alternatives

   This is particularly clear in references to low emission neighbourhoods, fleet electrification, and infrastructure schemes.

   Critical verdict: Financial risk is acknowledged but not mitigated. Delivery appears fragile.

6. Planning & Development Measures Remain Underdeveloped
   1. Air Quality Supplementary Planning Document (SPD)

      The Plan acknowledges that the SPD was drafted in 2018-23 but not adopted. It again promises to take it forward.

      Critical verdict: After 5 years, the Plan still does not commit to a firm adoption date. This is a strategic failure.

      Critical verdict: Enforcement ambition is low and unquantified.

   2. No Explicit Commitment to AQ-Positive Housing or Spatial Planning

      There is no mention of:

      • traffic reduction zones within development areas
      • car-free housing
      • developer-funded monitoring
      • air quality mitigation S106 standards

      Critical verdict: Development control remains procedural, not strategic.

7. Monitoring Network Improvements Are Too Modest

   The Plan highlights the existing network but commits to:

   • no major expansion of continuous monitoring
   • no expansion of PM2.5 monitors beyond one
   • no target for improving data coverage in hotspots

   Critical verdict: In a borough with heavy reliance on modelled data and several identified hotspots, monitoring expansion is inadequate.

8. Overemphasis on Awareness-Raising Instead of Emissions Reduction

   A disproportionate number of actions relate to:

   • school programmes
   • anti-idling campaigns
   • promotional/educational materials
   • social media messaging

   These are low-impact compared to structural measures.

   Critical verdict: The Plan leans too heavily on education as a substitute for infrastructure and regulation.

9. Weak Integration of Health Outcomes

   Despite strong public health framing, the Plan contains:

   • no health-based targets
   • no vulnerable-population analysis (beyond general statements)
   • no plan to measure health impact changes

   Critical verdict: Health impacts are acknowledged but not operationalised.

10. Governance and Resourcing Risks Acknowledged But Not Solved

    The Plan explicitly states that:

    • the previous AQAP was delayed
    • resourcing issues affected delivery
    • specialist environmental health staff had been lost

    But:

    • no staffing plan
    • no resourcing plan
    • no skills-development plan
    • no governance restructure

    Critical verdict: Past failures are acknowledged but not remedied. Delivery risks remain high.