An extract from NSCA's draft response
to the Review of the National Air Quality Strategy:
NSCA fully understands the difficulties faced
by the Government in achieving the current UK objective for particles.
It also fully understands the obligation placed on the Government
to transpose the Air Quality Daughter Directive limit values for
Particles into UK Law. However, NSCA does not support the conversion
of the current UK objective into an indicative level, or the introduction
of the Stage 2 Daughter Directive limits for 2009 as indicative
NSCA welcomes the production of the APEG report
Source Apportionment of Airborne Particulate Matter in the
United Kingdom and the greater understanding of the nature
and sources of particles which it represents. Using the findings
of this report, the review has concluded that the original particulate
objective was overly ambitious and is therefore not achievable
in the current time frame. However, as it is the pollutant which
is currently of greatest concern in terms of health effects, the
Government's commitment to reduce particulate levels beyond the
Daughter Directive Stage 1 limit value is welcomed by the NSCA.
In view of this, and in view of the fact that
the National Air Quality Strategy will be reviewed again at least
once prior to 2005, NSCA believe that the Government should maintain
the current objective for particles as a firm objective. This
would send the clearest possible signal of the Government's intentions
and provide the direct impetus for action on the causes of poor
air quality. Much has been made, at the launch of the review and
subsequently, of the contribution of secondary particulate originating
from continental Europe in exceedances of the UK objective levels.
Certainly in exceptional years, this contribution is substantial
and beyond the direct control of UK Government. While the NSCA
welcomes the Government's commitment to raise the issues with
its European partners, we feel that the UK should be planning
for typical years and not the atypical years such as 1996.
Under typical meteorological conditions, approximately
half of the UK particle load is made up of largely naturally occurring
coarse particles and secondary particulate of European origin.
This means that the other half is of manmade origin, sourced within
the UK and therefore subject to the influence of UK Government
policies. Therefore, while action at the European level is vital
to achieve long-term improvements in air quality, as the EU Auto-Oil
programme has shown, there is a substantial amount of work which
may be done unilaterally in the UK. In addition to improving the
health of UK citizens and saving the National Health Service substantial
sums of money, this would put the UK in a stronger bargaining
position within Europe.
NSCA would urge the Government to adopt the
Daughter Directive Stage 2 values as firm objectives, again in
order to secure necessary health improvements and to send clear
signals of intent both within and outside the UK."