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
(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carried out primarily by NETCEN and which has not been peer reviewed.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.
26 March 1999