Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence

Further Memorandum by the National Society for Clean Air and Environmental Protection (IT 95A)

  NSCA's argument for maintaining the current Air Quality Objective, as a firm objective, is based on the following Key points:

    (1)  The review should be of whether the current measures are sufficient to achieve the objectives and if not, what additional measures are needed. Instead, the review has attempted to adjust the objectives to fit what current measures can achieve.

    (2)  The proposed changes to the objectives are on the basis on the latest model predictions, work which was carried out primarily by NETCEN and which has not been peer reviewed. All air quality models are inherently uncertain and even slight changes in the input data can have significant effects on the model results. Given that the Strategy will be reviewed again in two years time and given that particles are of the greatest concern in terms of air quality and health effects, NSCA believe the precautionary principle should be employed.

    (3)  The current review is based solely on national policies and takes no account of the action which may be taken by local authorities to address air pollution in their areas. In fact, despite the large amount of effort being put into modelling and into Cost-Benefit analysis, there has been no assessment of what can be achieved by local measures. There is not even an assessment of the likely impact of the measure set out in the Transport White Paper even though these may have a significant impact on particle levels in urban areas.

    (4)  Predictions for typical climate conditions suggest that, for a large part of the UK, the objectives are achievable, with some additional effort. Therefore, relaxing the UK objective to the EU limit value (which was set to take account of the larger volumes of coarse particles, i.e., dust, in Southern European States) lets a large area of the UK "off the hook" in terms of local action on particles.

  The current timescale for local authority review and assessment means that it will be complete by early 2000, which means that the Government will have a much more detailed picture of which areas are likely to exceed the objective in 2005 and by how much. Where there is a problem, local authorities are under a duty to prepare an action plan, within 12 months, setting out what they intend to do to achieve the objectives. This means that the Government will also have a picture of how far local measures can go towards achieving the objectives. This will all be in time to feed into the next review of the Strategy in 2002 and so to relax the objective now is to ignore the possibility of making a more informed decision later.

  I attach an extract from NSCA's response to the strategy review and also the letter which has been sent to all local authorities from DETR which seems to suggest that the decision to relax the objective has already been taken. While it is welcome that DETR is prepared to offer advice to local authorities on the impact of the review on their activities (something which does not appear in the document), it does somewhat pre-empt the consultation process and therefore causes us some concern.

  I hope this is all of use to you and if you would like any further clarification or a draft copy of our full response, please let me know.

Tim Williamson

Policy Officer

26 March 1999

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