On 23 February 2022, the Clean Cities Campaign coalition published a report on the impact of mobility on the quality of life in selected cities with the title Pan-European City Rating and Ranking on Urban Mobility for Liveable Cities, prepared by the consulting firm Ricardo Energy & Environment.

It addresses and evaluates 36 European cities according to various criteria in the field of mobility and air quality, with a general emphasis that cities need to step up their efforts to reduce greenhouse gas emissions and air pollution from traffic.

These days, the report stimulated additional public debate on the performance of Ljubljana, which as the first Central European city included in their analysis, ranked 28th. Given all the measures we have been taking since 2007 to improve the quality of life in the city and mitigate the effects of climate change, we are surprised by the relatively poor ranking.

In some individual rankings in the report, we performed relatively well (score 8.2 for public transport affordability; score 8 for a "good" level of traffic congestion; score 6.2 for cyclist safety; score 6 for pedestrian safety and accessibility of the infrastructure for electric vehicle charging). The research head team pointed out that Ljubljana ranked 13th out of 36 cities in the field of cycling infrastructure development, even ahead of cities such as Brussels, Berlin or London, "which shows that your city is on the right track."
Although the City of Ljubljana supports the efforts of organizations that encourage further measures for a »greener« future, we find that the methodology they used is inadequate or incorrect in some calculations. Data collection is also unprofessional in some cases, as it was obtained from unverified instead of official records. This can lead to inaccurate or misinterpreted results that are not authoritative, do not reflect the accurate picture or are not comparable to some other cities. Also, the assessment was made solely based on raw, unprocessed data, which they did not come to verify, nor did they come to see the site to make sure of the measures taken and establish the actual state.
In the following, we highlight some facts and circumstances that, if they had been taken into account in the comparative analysis or calculations, would have probably affected different rankings of cities in favour of Ljubljana.

1. Incomparable starting points
   The cities in question, their parts or the wider area are not comparable as units: for example, the calculations were done only for Inner London (not the total area of the city), the whole area of the Brussels Capital Region (19 municipalities) and Greater Manchester (10 metropolitan districts), Poland's Tri-city area of three Polish cities along the Baltic coast), while most other cities in the rankings are considered as an individual whole. In some assessment categories, the obtained data was divided by the area of the considered city or by the total number of inhabitants, which is inappropriate or the results are inaccurate and unreliable based on the starting point (size and population density of the selected area). Namely, a large part of Ljubljana is comprised of uninhabited areas (e.g., forests, green areas, agricultural areas, hills…), where there is no need for the same road infrastructure as in the urban part of the city. Nevertheless, this whole area was included in the calculation as if the population was evenly dispersed, leading to erroneous conclusions.
   
   
2. Space for walking
   In Ljubljana, there are over 720 km of sidewalks along roads and categorized pedestrian paths, while in the city centre the pedestrian area already covers about 13.7 ha of land. Therefore, we were surprised that Ljubljana achieved a score of 3.5 out of 10 in the "Opportunity for walking" category. In the calculation, only physically separated footpaths and not sidewalks along roads and streets were taken into account, which in our opinion is insufficient. In the explanation, it is stated that the data of the online map OpenStreetMap was used, and here we have to point out that MOL does not provide or verify data for this tool, therefore the data there is unreliable. We are convinced that we would rank higher in this rating based on the verified data we have in the City of Ljubljana.
   
   
3. Access to public transport
   In the accessibility of public transport category, where Ljubljana landed at the bottom of the list, the number of bus stops per km2 was evaluated, taking into account the entire area of the city, including uninhabited areas, where public transport and the corresponding infrastructure are not really needed. City passenger transport bus lines (LPP) cover about 97% of the urban area of the City of Ljubljana (28 lines with a total length of 398 kilometres), which means that 97% of Ljubljana's households are less than 500 meters away from the nearest bus stop. This is relevant data that, if referred to, would contribute to a higher ranking.
   Regarding the accessibility of public transport from the financial point of view, we ranked 28th, although the score of 8.2 is relatively high. However, only the absolute price of the fare was taken into account and not the fact that 1.30 EUR, which is the cost of a city bus ride, is valid for 90 minutes and allows unlimited transfer between individual lines, or that the same price covers two bus rides and a parking fee until the end of the day on P + R parking lots. Namely, some other cities do not include this in their fare. Another fact that should not be disregarded is that transport by city buses is free-of-charge for pensioners, which was certainly not taken into account in the calculation of the household budget share needed for public transport, according to which, for instance, Copenhagen has the highest number of points (10 out of 10) ranking at the top (1.3% of the household budget) while London is in the last place (9.6%; in Ljubljana, this share is supposedly 4.2%).
   
   
4. Restricted access to motor vehicles
   In the assessment of restricting access to motor vehicles which are the biggest polluters of the environment (especially diesel and petrol) and giving priority to cleaner propulsion, vehicle sharing and the introduction of (low)emission zones, Ljubljana received a score of 6.5, ranking it in the bottom. The justification states that Ljubljana does not have an area where the so-called congestion charge or entry fee to the city or city centre based on vehicle propulsion is applied. However, they did not include more than 13 ha of pedestrian areas in Ljubljana's city centre and additional areas in the vicinity (e.g., the central part of the street Slovenska cesta), where access to personal motor vehicles (regardless of the type of propulsion) is already restricted, or locations in the centre, which only residents can access by car. In addition, the public bicycle rental system is an important piece of information that could be identified as significant in the category of shared mobility. BicikeLJ is – now counting already 81 stations and 810 bikes – one of the most successful systems of its kind in the world, as on average, each bike is used as many as eight times a day.
   
   
5. Safety of pedestrians and cyclists
   Although the research head team pointed out that Ljubljana is successful in ensuring the safety of pedestrians and cyclists, we cannot agree with the score of 6, as we have been effectively ensuring traffic safety for a long time with various measures. This is also confirmed by the data of the Police, which, for example, state an average of one fatal traffic accident per year, in which pedestrians and /or cyclists were involved.
   
   
6. Air quality
   Ljubljana received a relatively low score (2.4) for current air quality; a three-year average (2017–2019) of concentrations (µg / m3) of NO2, PM10 and PM2.5 was measured. The improvement in the air quality trend (annual improvement rate) is evaluated at 4.5. The data was taken from the European Environment Agency (EEA), but we believe that if we used data from the measuring points of the Environmental Agency of the Republic of Slovenia and the City of Ljubljana, the data should show a better picture. Because exactly these measurement results confirm the fact that air quality has been improving from year to year. In the last 15 years, the trend of decreasing the values of individual parameters has been clearly visible at all measuring points.

Given the above, we cannot agree even with the comments on the report made by some non-governmental organizations, which state that Ljubljana has had a severe problem with polluted air for a long time and that it must also adopt sustainable alternatives and measures such as no emission zones and a good parking policy. This reflects their poor knowledge of measures that we have been implementing since 2007 following the Ljubljana Vision 2025 and strategic documents such as the Environmental Protection Program, Sustainable Urban Strategy and Integrated Transport Strategy of the City of Ljubljana and the Ljubljana Urban Region.

Annex: Air quality in Ljubljana

Air quality in Ljubljana is monitored at three measuring points with accredited meters, with one measuring point managed by the City of Ljubljana and two measuring points managed by the Environmental Agency of the Republic of Slovenia (ARSO). The results of the measurements confirm the fact that air quality has been improving from year to year.
In the last 15 years, the trend of decreasing the values of individual parameters has been clearly visible at all measuring points. While at the most overwhelmed measuring station at the busiest intersection in the city centre the number of days with exceeded PM10 155 was 155 in 2006, there were only 36 such days in 2020. At the ARSO station in Bežigrad, which is the most representative measuring station for the general condition of air quality in Ljubljana, the number of days with exceeded PM10 value was 51 in 2006, and just 21 in 2020. All of this data is public and shows a declining trend. The trend of decreasing concentrations is also evident in nitrogen oxides.

But it is a fact that in the winter heating season (especially in December and January), we record individual exceedances of the limit values of particles, which are mainly contributed by individual fireplaces on the outskirts of the city and in suburban municipalities. But it is worth mentioning that the district heating system coverage in Ljubljana is very high, already over 80% of households. Air quality depends on local emissions, the ventilation of the area, and the pollution of the hinterland air in the broader environment.

The hinterland of Ljubljana is the entire Ljubljana basin, which also includes suburban municipalities. The basin has poor ventilation conditions, especially during periods of prolonged inversions typical of the winter months.
Through numerous measures in the field of sustainable mobility and sustainable energy, we have significantly improved air quality, and in the future, it will be necessary to improve the situation concerning individual fireplaces on the outskirts of the city and neighbouring municipalities.