Liveable City Centre and Ultra Low Emission Zone Initial Feasibility Study

Date of Meeting:

19th January 2021

Report of:

Executive Director, Economy, Environment &


Contact Officer:


Andrew Renaut


01273 292477



Ward(s) affected:








1.1         This report summarises the initial work undertaken on possible options for a Liveable City Centre (previously referred to as a Car-Free City Centre) and expanded Ultra Low Emission Zone in the city, following requests made by this committee.  It outlines the technical work undertaken to arrive at conclusions for both initiatives and summarises the initial recommendations set out in a pre-feasibility technical study.


1.2         The proposals will contribute towards delivering a number of the council’s objectives set out in its strategies and plans, such as the council’s Local Transport Plan and City Plan, including supporting carbon reduction, improving health and air quality, strengthening the economy, enhancing public realm and place-making, and increasing active and sustainable transport.


2.         RECOMMENDATIONS:    


2.1         That the Committee note the analysis and outcomes of the initial feasibility work on creating a Liveable City Centre and expanded Ultra Low Emission Zone options for the city.


2.2         That the Committee agree that the options summarised in paragraphs 3.8 and 3.9 of this report (and illustrated in Chapter 3 of Appendix 1 to this report) should be developed further through more detailed, quantified assessments, which will include the development of business cases and plans for engagement and consultation to identify preferred options for each project.


2.3         That the Committee requests that reports are brought back to future meetings of this committee for approval of the further development of the business cases and plans for engagement and consultation for the Liveable City Centre and expanded Ultra Low Emission Zone projects.







3.1         In October 2019 the Committee considered a joint letter from Councillors Heley, Davis, Lloyd and West requesting a report on the powers available to the council to extend minimum emission standards to other types of vehicles and beyond the current boundary of the current Ultra Low Emission Zone [ULEZ], which covers Castle Square, North Street and Western Road.  The zone applies to buses only due to it being linked to access to the priority lanes and air quality levels.


3.2         In January 2020 the Committee considered and agreed a joint Green Group/Labour Party Notice of Motion to:

·         Explore the feasibility and costs of developing a car-free city centre by 2023

·         Detail costs and practicalities, rules for exemptions and how the council’s plans to introduce an Ultra Low Emission Zone for private vehicles in the city centre can act as a transition to a car free city centre


Qualitative Technical Study


3.3         A single study brief was developed to recognise the strategic nature of both the Liveable City Centre (LCC) and Ultra Low Emission Zone (ULEZ) schemes (note that the LCC proposal was referred to as a Car Free City Centre throughout this technical work). Transport planning consultants (Steer) were appointed to undertake an initial study of options, to also include the possible complementary measures (such as ‘mobility hubs’ including Park and Ride facilities, parking management, and enhanced active travel infrastructure) required to ensure that the outcomes of an LCC are optimised.


3.4         A comprehensive evidence base was developed to include a review of: the local to national policy context; an analysis of local socio-economic, demographic and transport data; fact finding workshops with council officers; and, national and international case studies of Low/Zero Emission and Clean Air Zones in place or planned for London, York, Oxford, Cambridge, Malmo, Oslo, and Utrecht. These were used to help inform a strengths, weaknesses, opportunities and challenges analysis to inform the development of options for the city.


3.5         The identified strategic outcomes for LCC and ULEZ options are:

·         Support carbon reduction

·         Improve health and air quality

·         Enhance public realm and place-making

·         Facilitate increased equity and access for all, especially disabled people

·         Stimulate the visitor economy

·         Strengthen active and sustainable transport connectivity

·         Increased safety for all


3.6         The following principles for an LCC or ULEZ were also identified during the study:

·         A system which is understandable to residents and visitors

·         A system that addresses the Air Quality Management Areas (AQMA) both in terms of geography, but also times of day of greatest emissions

·         Geographical scope and operating times which do not create perverse incentives which have material negative impacts

·         Accompanied by complementary measures providing affordable, accessible and sustainable transport alternatives

·         Equity of social and distributional impacts considered and mitigated where appropriate


Options tested


3.7         The joint Green Group/Labour Party Notice of Motion requested an outline of exemptions that would be required.  Within both the LCC and ULEZ options, exemptions would need to be in place for disabled people who rely on their car for access to the city centre. Consideration will need to be given to the various categories of vehicles that could potentially be exempted, which are likely to include emergency services, residents living within a zone, local businesses, deliveries and servicing, taxis and buses/coaches.  The options that have been defined and assessed are illustrated in Chapter 3 of Appendix 1 to this report.


3.8         Four options for an LCC were identified: the smallest zone covering The Lanes, and the largest zone covering the area inside the A23, A259, B2122/A270 (Montpelier Road to New England Road) plus the area of west Kemptown bounded by Edward Street, Upper/Lower Rock Gardens and Marine Parade. A number of operational concepts were developed for defined areas within the possible zones: managed access and other restrictions within these concepts increase from a ‘low traffic neighbourhood’ to a ‘car-free’ area. These concepts could be considered for application to different areas within the zone, in order to reflect their differing characteristics.


3.9         Five options for a ULEZ were identified: the largest covering the whole of the city to the south of the A27 and the smallest covering the area up to around 1.5km north of the seafront from Brighton Marina to the boundary with West Sussex, encompassing the majority of AQMAs in the city.


3.10      A qualitative assessment was undertaken of the options against the strategic outcomes set out above, along with feasibility and deliverability criteria including the impact on deliveries and servicing and access by local residents.  Ease of understanding, public acceptability and ease of implementation and operation were also included.


3.11      At this stage of the feasibility assessment, full scheme costs have not been developed as the specifics of the schemes and full business case will be derived during further stages.  The technical report in Appendix 1 provides an indication of the costs involved and, in the case of the ULEZ, presents some relevant quantified examples from around the UK.  It also notes that forecast revenues from these are expected to exceed capital and operating costs, in most cases.  This initial (pre-feasibility level) study has been undertaken without any traffic modelling, surveying, or other option impact testing.


Study conclusions and recommendations


3.12      The assessment indicates that, in general, the LCC options that cover a larger spatial area are likely to have a greater impact on reducing motorised traffic in the city centre, and would therefore contribute to achieving the outcomes to a greater extent. However, these are likely to come with greater challenges, particularly in terms of their deliverability. The study recommended that a phased approach is adopted, commencing with The Lanes area and expanding to the largest area set out above.  Further development work would be subject to officer capacity and financial resources, and further engagement and consultation at the outline and full business case stages.  The following was also suggested:

·         Vehicle access restrictions rather than pricing restrictions

·         Removal of pay & display on-street parking, but access to major off-street car parks retained since the council does not own these

·         24/7 operation with time periods for deliveries and servicing

·         Community engagement and further analysis to determine sequencing, zones, vehicle restrictions and exemptions

·         Delivery by 2023 at the earliest


3.13      The recommended ULEZ option is the most extensive option, which is expected to contribute the most to achieving the desired outcomes and be most equitable (since it applies to all areas of the city). The entire northern boundary of the zone is formed by the A27; this is a very clear and legible boundary, being clear to drivers and is also a suitable route (subject to discussions with Highways England) for drivers who do not need to pass through the zone. The following was also suggested:

·         Introduction of a ULEZ is most likely to follow the Liveable City Centre

·         Charge for access to zone – emissions-based and scalable pricing

·         Residents’ exemptions to late 2020s or 2030 (and possible other exemptions)


Complementary measures


3.14      It was demonstrated by the study evidence base (including the case studies) and in line with the identified principles of a LCC and an ULEZ, that these initiatives would be more successful when accompanied by a suite of complementary measures. These would serve to optimise the benefits of the interventions by supporting use of alternative forms of transport and mitigate any risks. The implications of an LCC and ULEZ would be different for various user groups and in different areas, and the range of complementary measures must be responsive to this. A number of measures are proposed, in support of the following areas:

·         Promote and facilitate the use of zero emission passenger vehicles

·         Manage demand for parking in the city

·         Increase public transport use

·         Create an accessible and integrated transport system (including maintaining blue badge holder access and increasing the accessibility of the city centre for all disabled people)

·         Develop a public realm that encourages and enables active travel

·         Promote the use of ultra-low and zero emission goods and servicing vehicles


3.15      A complementary measure which is expected to support optimisation of benefits and mitigation of risks of an LCC and ULEZ is the introduction of a number of strategic and local mobility hubs located throughout the city. Mobility hubs are points of multi-modal interchange for people and goods, to integrate and encourage more widespread uptake of public transport, bike hire, car clubs and electric vehicles. They can be developed at a range of scales, sizes and scopes of service to be tailored to the areas or people they serve. They would be designed to offer a network of hubs which could provide seamless interchange and facilitate door to door journeys of people and goods.


3.16      A local mobility hub offers a single site for the location of neighbourhood-based services such as “click and collect”, a bus stop, BTN Bikeshare hubs, car club vehicles, electric vehicle infrastructure and local convenience shops. At a larger scale, strategic mobility hubs would be located at major road junctions or at major train stations. They would provide a “one stop shop” for a number of transport services such as a large bus interchange, BTN Bikeshare hubs, electric vehicle infrastructure, Park and Ride facilities and coach parking. The strategic location of these mobility hubs means that they could also be appropriate sites for delivery consolidation centres to reduce the impact of freight/large lorries.


Possible Timeline and Next Steps


3.17      Further scheme development could take place over the next 12 months, taking account of the recommendations of the Climate Assembly (as set out in the report at agenda item 66 for this meeting), and in support of the emerging transport vision for the fifth Local Transport Plan and the forthcoming review of the City Plan.  The further work recommended within the study is set out in Figure 6.1 (on page 77) of Appendix 1. This work would be subject to the allocation of an adequate level of funding and officer time.


3.18      The indicative programme in the technical report states that initial complementary measures could possibly be introduced during the following one to two years in readiness for the phased introduction of access restrictions in the city centre by 2023 at the earliest, and a wider ULEZ, if supported by the outcomes of engagement and consultation.


3.19      In line with the recommendations in section 2 of this report, a report on further option development work for both projects, including plans for engagement and consultation and business cases, will be brought back to committee later this year for consideration and approval.




4.1         As outlined in this report, the qualitative technical study identifies a number of possible options for assessment and puts forward a preferred option for each intervention. Completion of a business cases to help identify preferred LCC and ULEZ options would require more detailed assessments of at least two of these options for each.




5.1         The initial feasibility work was supported and influenced by early engagement with officers in Transport and those representing other service areas including City Clean, Economic Development, Equalities, Events, Planning, Private Hire Vehicle Licensing, Public Health, Sustainability, Seafront and Tourism & Venues.


5.2         The recent, first Brighton & Hove Climate Assembly focused on stepping up actions to reduce transport-related carbon emissions. In making recommendations, the Climate Assembly concluded that ‘a car free city centre’ should be a priority action. Assembly Members thought this would be dependent on improved public transport and active travel infrastructure being in place. They stressed that exceptions must be made for people who need cars (and other vehicles), e.g. blue badge holders, deliveries, and that those who can use other transport should not use cars.  A separate report on the Assembly’s outcomes is on the agenda for this meeting.


5.3         Wider engagement and public consultation (for example, at the outline and full business cases stages) with stakeholders and partners, including residents and businesses, will take place in support of the work required to further develop options and prepare business cases.  This will fully inform future considerations, recommendations and decisions.  Further details on the options that could be adopted for consultation will be reported back to this committee as part of an update on progress. As well as consultation on the specific proposals, this could also take place as part of the development of other transport-related projects such as the fifth Local Transport Plan and the Air Quality Action Plan. 


6.         CONCLUSION


6.1         This report summarises the initial work undertaken on options for a car-free city centre (LCC) and expanded Ultra Low Emission Zone (ULEZ) in the city, outlining the technical work undertaken to arrive at conclusions and summarising the recommendations set out in the pre-feasibility technical study.




Financial Implications:


7.1         The joint Notice of Motion requested an outline of the costs associated with both initiatives.  To understand the likely costs and funding mechanisms for a ULEZ, a review of proposed Clean Air Zones (of varying sizes) elsewhere in the UK was undertaken. The report notes that forecast revenues from these are expected to exceed capital and operating costs, in most cases.


7.2         To understand the range of costs for implementing an LCC, itemised costs for the elements of access restriction and control in the largest zone option were estimated, based on the precedents from other areas in the UK. The costs contained in the report exclude the implications of a loss of parking revenues and additional (and possibly significant) costs relating to other areas including changes to staff resources (particularly parking, enforcement and Traffic Control Centre teams) during scheme implementation and operation,  and administration costs for exemptions and visitor charges.  Further work will be required to calculate these.


7.3         Further quantification of the options considered for each project (in a business case) would require an appropriate level of further detailed assessment which would include surveys and modelling, in addition to stakeholder engagement and consultation. 


7.4         It is proposed that the further development of these workstreams could initially take place using funding from within the council’s future revenue budget or Local Transport Plan capital programme, subject to approval, or via opportunities for bidding for funding from Government grant initiatives.       


            Finance Officer Consulted: Jill Fisher                                           Date: 08/12/2020


Legal Implications:


7.5         Legal implications associated with the implementation of an LCC and ULEZ will need to be identified and addressed as development work on possible options and a business case are brought forward, taking into account the experience from the existing ULEZ and that of other authorities with similar schemes.


            Lawyer Consulted: Elizabeth Culbert                                           Date: 08/12/2020


Equalities Implications:


7.6         The strategic outcomes for the LCC and ULEZ include facilitating increased equity and access for all.  The following related points should be noted:

·         The measures seek to improve travel options for residents and visitors without access to a car, who are more likely to be lone parents, on low incomes, from disadvantaged communities, from Black, Asian and Minority Ethnic [BAME] groups, and / or have a disability

·         Walking, cycling and public transport are options for the majority of residents and visitors, unlike private vehicle journeys

·         Residents living in deprived communities are also more likely to suffer more from poor air quality in the city

·         An LCC would improve accessibility for disabled people and those with other protected characteristics: retaining and/or relocating Blue Badge holder parking bays and maintaining disabled access would be a priority

·         Equality Impact Assessments (EqIAs) would be required in further option development, including considerations of access and affordability


            Sustainability Implications:


7.7         The strategic outcomes for the LCC and ULEZ include supporting carbon reduction, improving health and air quality, enhancing public realm and place-making, and strengthening active and sustainable transport connectivity. Alongside the recommended complementary measures, the two projects would improve sustainable travel options, including opportunities to create space in busy areas of the city centre to enable more walking and cycling. This, along with the greater use of cleaner low emission vehicles, will help the city to become carbon neutral by 2030.


Brexit Implications:


7.8         No Brexit implications have been identified to date; this will be kept under review in line with the emergence of government strategy and related guidance.






Any Other Significant Implications


            Crime & Disorder Implications:


7.9         There are no direct implications arising from the projects. However, the elements of these would contribute to improving road safety and personal security and, wherever possible, they would seek to support the aims and priorities of the council’s Community Safety and Crime Reduction Strategy, especially in helping to deliver measures that improve the physical environment, ensure communities are stronger, and help people feel safer. Improvements are expected to include measures that improve public spaces and streets so that people feel safer, while discouraging crime and anti-social behaviour.


            Risk and Opportunity Management Implications:


7.10      Risks and opportunities will be considered as part of further development of options. These may relate to public understanding of restrictions, impacts on traffic distribution and deliveries and servicing, commercial aspects (costs and revenues), and overall public acceptability.


            Public Health Implications:


7.11      Transport and travel are critical to delivering the city’s public health objectives as they contribute significantly to some of today‘s greatest challenges to public health, including road traffic injuries, physical inactivity, the adverse effect of traffic on social cohesiveness and the impact on outdoor air and noise pollution. One of the key principles of both projects is to improve health and air quality; the elements of these (including wider complementary measures) will help address the challenges through encouraging and enabling an increase in levels of active travel and the use of cleaner vehicles. The plan will help to improve air quality by reducing harmful emissions if people and deliveries switch from motorised transport or to cleaner vehicles. This will help deliver the objectives and actions set out in the council’s Air Quality Action Plan, such as enabling greater use of alternatives to the car for some journeys. Creating less dangerous and more attractive environments, through for example public realm schemes, will improve individual and community health and quality of life, and contribute to the wider objectives of the Joint (council/NHS) Health and Wellbeing Strategy.


            Corporate / Citywide Implications:


7.12      The projects would help support the city’s planned economic growth, visitor economy, social development and environmental enhancement. They will support in delivering the council’s 2030 Carbon Neutral Programme, along with the Corporate Plan, the City Plan, and the Visitor Economic Strategy. The projects would also support the five-year strategic priorities and GB10 pledges of the Greater Brighton City Region.











1.         Brighton and Hove Car Free City Centre and Ultra Low Emissions Zone: Initial Options Study, Final Report, October 2020


Background Documents


1.     Brighton and Hove Car Free City Centre and Ultra Low Emissions Zone: Initial Options Study, Evidence Base - October 2020

2.     Joint Notice of Motion to ETS Committee (agenda item 59) – January 2020

3.     Letter to ETS Committee (agenda item 28(c) iii) – October 2019