Memorandum submitted by the Institute
of Air Quality Management (AQ02)
SUMMARY
The monitoring and modelling of air quality
in the UK is, in general, adequate.
The health and environmental risks of poor air
quality are well understood in Defra and parts of DH/HPA but less
well so elsewhere.
The delivery chain for achieving good air quality
is wholly inadequate and pitifully resourced. It is also fragmented
and the responsibility of many arms and agencies of central and
local government, not all of which are playing their proper part
in the process.
The primary means of improving air quality in
England is to address emissions from road traffic. Although improvements
in vehicle technology will play a part in this, the IAQM believes
that much needs to done to understand the science of air pollution
more fully and that the air quality objectives will only be achieved
and maintained by influencing the behaviour of individuals and
reducing the need for the use of the private car.
SUBMISSION.
1. There is an extensive programme of air
quality monitoring in the UK. In part this is the national Automated
Urban and Rural Network (AURN) and in part it is regional and
local networks operated by local authorities and other bodies.
Although there are some arguments about just how well the data
from these activities reflect the exposure of the public it is
fair to say that there is only limited scope for improvement in
this area.
2. The UK also makes considerable use of
air quality modelling to provide estimates of air quality in areas
where monitoring is not carried out. Although the absolute reliability
of such modelling has been questioned, there is no evidence to
suggest that the procedures are poorly executed.
3. The health and other environmental risks
associated with poor air quality have been clearly identified
by bodies such as the Committee on the Medical Effects of Air
Pollution (COMEAP) and these have been acknowledged in those parts
of Defra and DH/HPA with responsibilities for these matters. It
must be realised, however, that this only represents current knowledge.
Although much work has been done in this field in recent years
there are still many questions that remain to be answered. What
is clear, as the recent COMEAP report (Long-Term Exposure to Air
Pollution: Effect on Mortality) states, is that a large number
of deaths every year are advanced by the effects of air pollution
and in particular by very fine particulate matter. There is still
much debate over which specific element(s) of this are responsible
for advancing deaths but the evidence is strong that particles
are the main pollutant to address. There is also an acceptance
in these bodies that road traffic is the predominant, although
not the only, cause of air quality problems. This is especially
the case in London but it is also a major factor in most other
towns and cities in the UK.
4. It is much more questionable whether
these risks are understood in other parts of Government. One difficulty
in this is that Climate Change (CC) has dominated the "pollution
agenda" in recent years with the consequence that measures
have been introduced to address CC which have had adverse effects
on air quality. One specific measure in this respect has been
the encouragement of increased use of diesel vehicles. These do
emit lower amounts of carbon dioxide but also emit greater quantities
of particles and nitrogen dioxide, the main pollutant of concern
(see also Para 16).
5. The delivery chain for improving air
quality is, at best, fragmented and often non-existent. There
is a view held in some quarters that technological measures being
introduced, especially in the road transport field, will deliver
all the improvements that are needed. The evidence from monitoring
shows that, following an improvement in air quality in the 1990s
following the initial introduction of catalytic converters, there
has been little further improvement in spite of supposed improved
vehicle technology. It is worth noting that the largest step change
in overall air quality was in 1992 with the introduction of the
three-way catalytic converter. In particular this brought about
improvements in carbon monoxide and total oxides of nitrogen.
In contrast the effects on nitrogen dioxide concentrations were
minimal. This is usually attributed to the fact that increases
in the numbers of vehicles on the roads has swamped any benefits
that may accrue from the technological improvements.
6. A further difficulty is the need for
balancing approaches. Reference has already been made to the dominance
CC issues have gained on the pollution agenda. There is a clear
need for such global issues and, generally, local issues such
as air quality to be treated in conjunction so that measures to
address one do not have an adverse effect on the other and, where
possible, have mutually beneficial effects.
7. Another issue of balance is that between
national and local measures. National measures tend to be broad
brush and, assuming they are effective, will produce overall benefits.
There are, however, many cases where air quality problems arise
as a consequence of local problems which are not amenable to control
by national measures. Defra has recognised this in the early drafts
of its submission to the EU for an extension in meeting the Limit
Value for nitrogen dioxide by identifying areas where different
types of traffic sources are responsible for air quality problems.
8. A major stumbling block to delivering
improved air quality is a lack of co-ordination between the various
parties involved in the process. This problem exists at both national
and local level. In the national case, as has already been stated,
Defra and DH/HPA have at least some understanding although this
may not spread across the entire Departments. On the other hand
there are other Government Departments; DfT, CLG, DECC and HMT
for example, where there appears to be at best very limited awareness
of air quality issues and, often, a total lack of understanding
that air quality is still a major problem in terms of its health
impacts and its wider environmental impacts. It is actually imperative
that these Departments are involved in the Air Quality Management
(AQM) process as each has an important part to play. Equally,
although other Government Departments may not have quite the same
direct involvement in AQM as these, they do have the potential
to assist in delivering improved air quality by managing their
own emissions.
9. DfT must be more closely engaged as traffic,
and in particular road traffic, is the main cause of air quality
problems in much of the UK. CLG has a major role in the planning
process in particular and in local government in general. DECC
must be involved to ensure a harmonisation of AQM and CC policies
and HMT has an essential role in providing funding.
10. At a local level it is essential that
similar links are established and maintained between the air quality
professionals and the transport planners, climate change officers
and development control planners. Although there are some local
authorities where such links do exist there are many where they
do not. There does not appear to be any consistent link between
whether such relationships exist or not and whether an area has
one or two tiers of administration. There are examples of good
links where the highways functions are at a county council level
and air quality is a district council function and of poor links
where both functions are exercised in unitary authorities and
vice versa.
11. There is another issue that is important
at the local level. This is the question of Local Transport Plans
(LTPs). There are a number of points that must be addressed here.
First, in the current round of LTPs (LTP2) air quality was cited
as one of the four key shared priorities with tackling congestion,
improving road safety and improving accessibility. In spite of
this research (Dotun Olowoporoku, University of the West of England,
PhD thesis in preparation) shows that in many cases air quality
has been treated as the fourth in order of priority. This is largely
due to the requirement for the preparation of Joint LTPs by groups
of local authorities of which maybe only one or two have Air Quality
Management Areas.
12. The draft guidance for the next round
of LTPs (LTP3) is likely to exacerbate this problem as air quality
has been given a lower priority than was the case in LTP2. Given
that when it was specifically listed as one of four, presumably
equal, priorities air quality was nonetheless downgraded by many
local authority Transport Planners it is unlikely that with the
proposed LTP3 guidance the same Transport Planners will accord
it the priority it needs.
13. The main problem in managing air quality
is that the resources available are wholly inadequate. There is
an apparent lack of proportion in the allocation of funds for
various initiatives. This can be best illustrated by comparing
the funding for various road safety measures and that for air
quality work and the health impacts of road accidents and air
quality. In the case of road safety there are numerous high profile
campaigns, in particular the regular drink-driving campaigns,
and many cases of extensive traffic management schemes, some of
which may result in deterioration in local air quality. These
measures are targeted at an annual death toll of approximately
3,000. In contrast, poor air quality which is believed to be responsible
for at least 24,000 deaths advanced per year only attracts general
attention when there is a major episode such as the London smog
of 1952. Episodes such as this are, fortunately, rare and no subsequent
episode has had the same impact. An episode in London in December
1991 was analysed in detail in a report for DoH (Anderson et al,
1995) which concluded that between 100 and 180 deaths during and
after the episode could be attributed to air pollution. In July
and August 2003 there were increases in deaths over and above
what would have been expected. Many of these were attributed to
the high temperatures experienced at the time but an analysis
(Stedman JR, 2004) estimated that between 423 and 769 of the 2,045
"additional" deaths between 8 and 13 August were due
to poor air quality; specifically particles and ozone. The range
in this case is due to uncertainty in the magnitude of the effects
of ozone.
14. It is, of course, necessary to strike
a balance on this issue. It is appreciated that in a reasonably
large proportion of, but not necessarily all, road traffic accidents
the number of years of life lost by individual casualties will
be greater than that lost by many individual victims of air pollution.
It is, however, also necessary to consider the total loss of life
years. The current estimate on this is an average of eight months
per person per year which, based on a population of 60,000,000,
equates to 40,000,000 years of life lost per year. In contrast,
even allowing for a loss of 50 years of life per casualty in road
traffic accidents, these equate to 150,000 years of life lost
per year.
15. It is recognised that achieving improved
air quality is not going to be an easy task. Part of the difficulty
is that it is never going to be a simple task to quantify the
outcomes of proposed measures in advance of their introduction.
There is a need for more rigorous scientific research into air
pollution. Although we do know far more now than was the case
in 1952, there are still many questions that are unanswered.
16. Two major issues concern the two pollutants
of greatest concern for LAQM: nitrogen dioxide and particulate
matter. In the former case we have seen a marked reduction in
the concentrations of total oxides of nitrogen (nitrogen dioxide
+ nitric oxide) but this is almost entirely due to reduced concentrations
of nitric oxide. The Air Quality Expert Group (AQEG) produced
a report (December 2007) on this which does identify some possible
causes but also highlights a number of areas for further work.
More recent work (Carslaw, 2009) suggests that increased concentrations
of nitrogen dioxide that have been observed, particularly at roadside
sites, are due to increased emissions of primary nitrogen dioxide
from diesel-engine cars.
17. In the case of particles, there is still
uncertainty as to whether particle mass is the most important
metric and, if so, which size fraction, or whether particle numbers
or surface area are the critical issue. There are also key questions
on source attribution for particles and on whether different size
fractions may have different health impacts. One school of thought
suggests that the finer fractions may be most important in chronic
effects, and in particular with advancing mortality, whereas the
coarser particles may be responsible for acute effects such as
triggering asthmatic attacks.
18. Although, as has been stated, it is
difficult to be precise in identifying the outcomes of measures
introduced to improve air quality, the current financial situation
does present one opportunity in this respect. It is generally
accepted that the majority of air quality problems in the UK arise
from emissions from road traffic. There have been a number of
reports that road traffic has reduced due to the financial crisis
and this potentially presents us with an effective intervention
study into the outcomes of reducing the amount of road traffic
in the UK. Attempts to do so have been made in the past with short
term events such as the fuel delivery problems in 2000. These
events, however, were too short for any meaningful conclusions
to be drawn as normal variations in air pollutant concentrations
swamped any other effects.
19. Even if this opportunity does produce
evidence on the amount of reduction in road traffic necessary
to meet the EU Limit Values for air pollution there still remains
the problem of achieving those reductions in the long term. This
will require a major change in the mindset of the general population
and, in particular, amongst users of the private car. It is certain
that there will be a need for the use of innovative means of transport
and for better, more flexible public transport to meet the needs
of the travelling public. There is also the need for other measures
to reduce the need for travel. There are current examples such
as increased home working but these are often offset by the lack
of local facilities which encourage people to use their cars to
travel to out-of-town shopping centres.
20. This submission has concentrated on
those issues that are associated with the Local Air Quality Management
process in the UK. There are also air quality issues that lie
almost wholly within the remit of Her Majesty's Government, although
measures taken to improve local air quality will assist in achieving
targets in these matters. One of these of concern both in relation
to human health and to eco-systems is the steady increase in concentrations
of background, tropospheric ozone. Others are a widespread problem
with the deposition of nutrient nitrogen on sensitive habitats
and a residual problem of acid deposition.
REFERENCES
Anderson HR, Limb ES, Bland JM, de Leon AP,
Strachan DP, Bower JS, 1995. The health effects of an air pollution
episode in London December 1991. St George's Hospital Medical
School/UK Department of Health, London.
Stedman J R, Atmospheric Environment, Volume
38, Issue 8, March 2004, Pages 1087-1090.
Air Quality Expert Group reportTrends
in primary nitrogen dioxide in the UK, Defra, December 2007.
Carslaw D, Latest Evidence and Future Prospects
for Primary NO2 Emissions, Nitrogen DioxideTime for Compliance,
November 2009.
1 December 2009
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