Sunday 27 September 2015

"VW cheated —so we need 30 mph!"

Someone called, entertainingly, Pointer2null , comments on one of our 20 mph posts and argues that:

Because VW cheated its customers and governments round the world, we need a 30 mph limit.

It's the pollution, you understand.

He cites two papers, so let's look at them.

An evaluation of the estimated impacts on vehicle emissions of a 20mph speed restriction in central London, City of London Study,  2013:

The opening paragraph says
Average speed models suggest that a lower speed limit in urban areas may result in higher pollutant emissions. However, the stop-start nature of traffic in central London means that such a method may not be suitable, and further investigation is required.
That's the scientific way of saying "its the acceleration from 0 mph that uses fuel, stopping wastes it —so simple models of constant speed are unlikely "may" to apply. Give us some more money and we'll tell you. Actually, the VW debacle has shown that some real-world experimentation would be the strategy. Fit a car with the sensors, drive round an area the month before a 20 mph rollout, then the month after -and see what changed. Back-to-back tests should be relatively accurate, though term-times and weather patterns are factors to consider.

Looking at both the 30 mph and 20 mph modes, they noted that in a 30 mph zone more time was spent accelerating (==higher RPM), while the cruise at 30 mph may more fuel efficient, its not there for very long. with slightly different roads in the study at 20 & 30, you could argue about whether the cruise and acceleration profiles would be the same at 20.

They then go on to conclude
  • It is concluded that it would be incorrect to assume a 20mph speed restriction would be detrimental to ambient local air quality, as the effects on vehicle emissions are mixed 
  •  The short-comings of using average speed models is highlighted, with the specific example of the potential to underestimate emissions of NOX from diesel passenger cars
Pollution metrics were taken off stated manufacturer levels, so, as we know: massively underestimating the pollution of the diesel fleet, while much more accurate for petrol. This means well have to discount one paragraph
Emissions of NOX and CO2 are seen to be higher over 20mph drive cycles for petrol cars and generally lower for diesel cars. PM10 emissions improve for smaller vehicles over 20mph drive cycles (less than 2.0 litre engine size), but are shown to increase for larger vehicles. The order of magnitude is such that future trends in fleet composition will be important.
The authors of the paper would really need to take the real-world figures for petrol and diesel and model the pollution levels based on those numbers, using the acceleration/speed profiles gained in this experiment. Perhaps a future paper is forthcoming.

20mph roads and CO2 emissions, The AA, Undated

This isn't a paper, more a press release. You can see it in the headline, Lower limits can increase fuel consumption and CO2 emissions. Scientists would be more circumspect, and use the word "may" in their work, especially for one single experiment.

The article is about an AA field test measuring fuel consumption in petrol vehicles. Like the CoL paper, it calls out stop-start driving and implicitly the acceleration profile, as the real killer:
  • Change 30 mph zone to 20 mph: increases fuel consumption by 5.85 miles per gallon, or 10.1 per cent.
  • Add speed humps to a 30 mph zone: increases fuel consumption by 27.3 miles per gallon, or 46.9 per cent.
It doesn't look at diesel, and the initial measurements are from the steady state "driving at 30 with no traffic jams". The Millbrook Proving Ground they mention does have a "city track",  hopefully that was the one used. A real paper would provide such information.

What it shows is that speed bumps are the enemy of breathable air. The fact that the Bristol rollout doesn't have them, must therefore be viewed as a good thing.

Comparing the AA press release with the CoL study, it is the CoL one which is scientifically defensible. They discuss the experiment in detail, how they cleaned up the data, the maths to reach the conclusions. And even in the conclusions they state their uncertainties. They are scientists? The AA: an organisation which came to the experiment with an expectation of what the answer would be, ran a field experiment which is unlikely to reflect an inner city, didn't describe that experiment very well —and came to a simple headline conclusion which failed to represent the uncertainties in the findings.

Were that to be be a paper submitted to the Bristol Traffic review team, it would have been rejected due to lack of scientific rigour.

PointerToNull, reads them and comes to the conclusion:
It's all over the news today - the NO2 figures for diesels has been faked. So this make the decision to force all petriol vehicle to observe a speed that INCREASES NO2 emissions by 8% even more short sighted (this is a measured increase by the study and not a claimed one by the makers). Given the state of diesel, petrol will probably be the dominent fuel and so in a single stroke of stupidity, all the gains made by better engine technology in petrol vehicles over the last decade has been wiped out. To press the point, the number of people who will die from air pollution will increase more than those who are saved by slower vehicles.
We're not going to disagree with anything here. They (he? she?) focus on the better of the two papers, and while skipping the "more data needed" bit of the conclusions (academics like that, it's how they get more money), makes the case that speed limits should be driven by what is optimal in terms of pollution profile.

This is a dangerous argument to use. Why? Because to say "we must choose our speed limit by optimal CO2/NOx levels", then you have to be pushing for the motorway limit to be 60 mph. Fuel economy drops significantly after that, and pollution levels increase.

Anyone advocating 30 mph urban for the sake of pollution levels, must also advocate a 60 mph limit, else they are picking data to suit their opinions.  If you did care, you won't drive short distances on cold days, or when pollution levels are already over the limits. 

Then there's also the painful fact that inner bristol's air pollution levels are beyond the legal limits, even before the 20 mph rollout, and includes the M32 corridor.

That is

-Bristol's NOx problem predates the 20 mph zone.
-it seems to correlate with some of the main bus routes: A38 and stapleton road
-it also covers the M32, which had a 60/70 mph limit in 2012.

Leaving the limits at 30 mph would have done nothing to address this problem. And while VW and friends were promising to everyone that all they had to do was wait for the Euro6 rollout, that's not going to cut it either. Which means we'll have to try other things.

The goal of the 20 mph zone is to get more people walking and cycling, not driving their kids to school in turbo-diesel cars. Then if we can get people in the core to not drive on short journeys, potentially increase traffic flow overall.

The future of urban cars is probably hybrid, maybe electric, though the economics and logistics are still dodgy there (expect some post on Tesla vs Google soon —TL;DR you'd have to be driving a lot for a Tesla to make sense; if you buy one you almost want to drive more to reduce that cost/mile). Certainly we don't need to be looking ahead to city centres with diesel, because dieselgate may be the trigger to accelerate restrictions or C-zone charges for them in Bristol, possibly starting with the RPZ.
"the number of people who will die from air pollution will increase more than those who are saved by slower vehicles.
This is potentially -and terrifyingly- true. But the response to NO2 problem should not be 'let's have 30 mph limits in town', because that will not address:

  1. The fact that with the average speed of cars in Bristol being ~16-18 mph at peak hours, even on the M32, the 20 mph limit is irrelevant at the time most cars are driven in the city.
  2. The fact that as fuel economy on motorways peaks at < 60 mph, if we want to address NOx pollution from motorways, the peak limit should drop from 70 to 60.
  3. The lack of data we have on what percentage of Bristol's NOx pollution comes from buses and taxis. If we knew, then from a pollution perspective, that could be an area to focus on.

To close then, we congratulate Pointer2null for digging up an interesting paper on the impact of 20 mph limits on city of london's pollution levels, and may email the authors asking for any planned recalculations.

Assuming that Pointer2null going to become the city's advocate of pollution-scient-driven-transport policy, we also hope to see any papers they can now dig up on effective speed limits for fuel economy and pollution on motorways. Now that £80M has been spent on the Managed Motorways, it would now be possible to drop the speed limit there on high-smog days. Having some insight into the effectiveness of this would be something to help shape regional transport policy.


20's Plenty for Us said...

You may be interest in our analysis of both of these reports. See :-


Diesel emissions dominate urban road pollution with about ten times the toxicity of petrol fumes. As 20mph limits reduce the most toxic diesel fumes, setting a wide 20mph limit is equivalent to removing nearly half of all petrol cars. This massive air quality and public health gain must be implemented urgently and nationally to reduce the 30,000 annual UK deaths from air pollution.


AA spreads misleading information on 20 mph and CO2 emissions

The recently publicised report from the AA claiming that 20 mph speed limits increases pollution is laughable for both it shallow basis for testing and its failing to understand the wider environmental reasons for, and benefits of lower speeds.

Pointer2null said...

Sorry - missed the reply email.

Anyhow, not got time to go through every propaganda point. But let me simply summarize:

TOTAL UK road deaths in 2014: Approx 1,800. (

Deaths due to NO2 pollution ~ thought to be approx 23,500 people a year in the UK (some estimates put this at 52,000+).
(point 9 on

A car at 20MPH produces 8% MORE NO2 than at 30MPH.

So at 20MPH you reduce the 1,800, but increase the 23,500.

Go figure.

Bristol Traffic said...


Not propaganda. A initial review of a published scientific paper. I do not know what kind of scientist or mathematician you are —your username name implies you may be a s/w developer. Those of us who are still active in science research should know how to read papers, and ideally should be aware of both confirmation bias (tendency to be less critical of things you agree with), and the opposite -the tendency to dismiss those you disagree with. I did dismiss the AA one, but mainly because they don't provide the information to analyse it. And before you accuse us of confirmation bias ourselves, notice how I didn't rush to embrace the answers, but instead say "you need to look further":

The authors of the paper would really need to take the real-world figures for petrol and diesel and model the pollution levels based on those numbers, using the acceleration/speed profiles gained in this experiment. Perhaps a future paper is forthcoming.

At some point expect some fairly harsh critique of the 20-is-plenty over-interpretation of that same paper, for confirmation bias. Specifically

* when the stop-go traffic is already < 20 mph peak speeds, you'll see no change in NOx levels at all.
* you need to consider the miles per vehicle type for the conclusion, in particular, bus, taxis and vans probably do more miles per vehicle than passenger cars.

Your statement "A car at 20MPH produces 8% MORE NO2 than at 30MPH." is based on the assumption of steady state traffic flow at 30 mph vs 20 mph. As anyone who has driven in Bristol will know, "steady state traffic flow" is something only achieved at 3am. Therefore the number is not valid for most of Bristol's journeys, hence indefensible. Sorry.

What everyone needs is some real world data on current traffic flows in Bristol, which can be done not just by instrumenting a car for NOx pollution, but perhaps by running some app in a phone which measures movement. Getting some volunteers to do it would immediately fall foul of selection bias, which is where TomTom's "our satnav's say" work is limited. There are two groups which the council could mandate instrumentation for: buses and taxis. The NYC taxi authority has instrumented their taxis; the datasets are there for you to play with. Knowing WTF first bus do would be interesting as a first step.

There is also a large organisation which is in the process of conducting a large experiment on passenger vehicle driving conditions. Their name is google, it's being done by google maps, google Waze and simply through android phones reporting in. This would be a very interesting dataset to get hold of. Not the bit of google I collaborate with in exchange for free coffee and lunches at the Googleplex, sadly.

Anyway, your numbers about pollution deaths are terrifying, but impact of a 20mph/30mph speed limit in Bristol is not something we have clear data for. What we do know is (a) diesel cars are one of the key sources of NO2 in town, (b) the most polluted street in Bristol is Rupert Street, which is bus and taxi only, and (c) stop/go traffic appears to be the strongest factor in pollution figures from both the AA and the CoL study.


(about to swap the ageing VW TDi for BMW 328i estate)