Memorandum submitted by Environmental
Protection UK (AQ05)
SUMMARY OF
OUR VIEWS
National-level monitoring and modelling has
generally been successful, but does not pick up many local air
quality hotspots caused by issues such as street canyons, bus
stops, minor junctions, pedestrian crossings, etc. These local
hotspots are the source of significant public exposure to polluted
air.
The health and other environmental risks associated
with poor air quality have been identified by bodies such as the
Committee on the Medical Effects of Air Pollution (COMEAP). However,
many Government reports and strategies currently rely on outdated
recommendations for premature death and monetised health impacts.
Outside of parts of Defra and the Department of Health the health
effects of air pollution, and indeed the fact that air pollution
is still a problem at all, seems to be only dimly understood by
government.
The delivery chain for air quality is fragmented.
Responsibility for meeting air quality objectives lies with Defra,
however delivery largely rests with other government departments
and bodies such as the Highways Agency, who often do not dedicate
adequate resources to the problem. At a local level, local authorities
often lack the national enabling actions and political will to
act decisively on air quality.
Effective delivery will need the delivery system
to be re-examined, and national enabling actions to be taken alongside
stronger obligations at regional and local levels. Greater resources
need to be provided at all levels. Tight integration on air quality
and climate change policy is currently lacking—improving
this situation will reduce the costs of achieving air quality
and climate change targets as well as reducing the risk of unintentional
policy trade-offs, as we have seen with promotion of diesel vehicles.
DETAILED COMMENTS
We have detailed our comments below in each
of the four areas requested by the Committee:
The monitoring and modelling systems used by the
Government and whether these provide an adequate measure of air
quality
1. Two separate levels of monitoring/modelling
are used in the UK:
— National-level monitoring/modelling organised
by Defra, which includes the Automated Urban and Rural Network
(AURN). National-level monitoring and modelling is used to monitor
compliance with EU Air Quality Limit Values and the UK Air Quality
Standards.
— Local monitoring/modelling carried out
by local authorities in support of their responsibilities under
the Local Air Quality Management regime.
It is important to note that whilst both levels
of monitoring/modelling may use valid techniques, they may not
necessarily produce the same results. Indeed, as the Committee's
questions suggest, monitoring and modelling will always provide
only an approximate indication of public exposure to air pollution.
2. The nationwide system of monitoring,
that includes the Automated Urban and Rural Network (AURN), has
been implemented successfully and has achieved international acclaim.
However, it is important to note that the approach taken by the
UK to comply with European monitoring requirements uses relatively
few monitoring sites, with the gaps filled in by modelling. Automatic
monitoring, as carried out in the AURN, also tends mostly to be
urban centre/background sites, rather than the roadside sites
where air quality problems are worst. Even where monitoring is
at roadside, it is rare that automatic monitors can fit in the
narrow streets that are the worst hotspots (see paragraph 3).
3. The `gaps' in the widely dispersed national
monitoring system are filled by air quality modelling. The national-level
modelling has been carried out to a high standard using the best
available techniques, however it is important to note the limitations
of the modelling process at a national level. Modelling is only
as good as the input data provided, and the models themselves
may also have limitations, for example gas-based models are often
used to model particulate (PM10) concentrations. National modelling
also fails to recognise the major influence of local congestion
and street-scale topography (eg street canyons, bus stops, minor
junctions, pedestrian crossings, etc) on air quality.
4. These local factors are now very likely
to constitute the majority of problems identified and declared
as Air Quality Management Areas (AQMAs) under the Local Air Quality
Management (LAQM) process. The fact that national-level monitoring
has not picked up these areas has allowed national modelling to
also overlook them, meaning that these problem areas are not included
in terms of reporting against the national Air Quality Standards.
This effectively devolves action on these poor air quality hotspots
to local authorities alone, which have neither the binding legal
commitment nor in many cases the effective tools to take meaningful
action and resolve the problem(s).
The extent to which the Government fully understands
and has identified the health and environmental risks caused by
poor air quality
5. 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 the Department of Health/Health Protection
Agency with responsibilities for these matters.
6. However, COMEAP's latest recommendations
for quantifying the health impacts of particulate matter are currently
failing to find their way through into official estimates of premature
deaths and monetised health impacts. The current (2007) Air Quality
Strategy used a premature death co-efficient for PM10 from COMEAP's
1998 quantification report (a far lower figure than that recommended
in their latest 2009 report). The health impact quantification
methodology used in the 2007 Air Quality Strategy has been used
in several subsequent reports, for example the recent Cabinet
Office report `The Wider Costs of Transport in English Urban Areas
in 2009', which means that health impacts continue to be widely
underestimated. The Campaign for Clean Air in London provided
a detailed explanation of these issues in a letter to Mayor Johnson
dated 20th September 2009.[1]
7. Although bodies such as COMEAP have done
much good work, there are still many questions that remain to
be answered. For example, there appears to be a lack of clarity
regarding how air pollution affects individuals, both in terms
of differing levels of personal exposure to pollutants and regarding
how susceptible different people are to the effects of pollution.
Average figures, for example the 7-8 month average shortening
of life cited in the UK Air Quality Strategy, can be of limited
use for determining health impacts.
8. The evidence base for the health effects
of air pollution is often not thoroughly communicated amongst
government and the general public. The health impacts of air quality
in the UK are estimated at almost twice those of physical inactivity
(Defra Air Quality Strategy 2007, Chief Medical Officer's Report
2004), yet it fails to receive quite the level of attention of
the latter. Similarly, some studies have suggested that the cardio
vascular risk of exposure to traffic pollution "may well
be similar to that played by passive smoking" (COMEAP 2006)—the
comparative level of national action, however, seems to be very
different.
9. Outside of Defra and the Department of
Health it is questionable whether these risks are fully understood.
There has been very little linkage made between air quality and
other policy areas of health and environmental risks—the
causes and effects of air pollution are still dealt with in different
departments, for example DfT, DCLG, DoH. The consequent lack of
joined up policy fails to emphasise the multiple wins that would
be achieved by co-ordinated policies. For example the promotion
of cycling and walking can help relieve congestion, reduce conventional
(air quality) emissions, and see a significant increase in average
levels of physical activity thus reducing the incidence of heart
disease and increasing resilience to the impacts of air pollution.
In addition to this, it would help reduce climate change related
emissions.
The extent to which the delivery chain for air
quality is coherent, integrated, co-ordinated and effective and
whether the bodies with responsibility for managing air quality
have appropriate incentives, understand their role and responsibilities,
and are adequately resourced
10. The delivery chain for improving air
quality is, at best, fragmented. At a national level, Defra and
the DoH/HPA have at least some understanding although this may
not spread across the whole department. On the other hand there
are other government departments, DfT, CLG, DECC and the Treasury
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
and wider environmental impacts. It is imperative that these departments
are involved in the air quality management process as each has
an important role to play. 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. The Treasury has an essential role in providing funding.
11. Harmonisation of air quality and climate
change policy is key, as both policy areas are largely aiming
to address the same combustion processes. Coordinated policy can
lead to lower overall costs, whilst un-coordinated policy can
cause unintentional trade-offs. The current departmental split
between air quality (Defra) and climate change (DECC) is therefore
unfortunate, and there is currently little evidence of the assurances
that policy would be `joined up' given at the time that DECC was
created. Win-win measures between climate change and the natural
environment (including air quality) are not being identified and
fast tracked, whilst the potential negative effects of climate
measures are not being fully identified before implementation.
Time consuming and expensive policy amendments are often later
needed; examples of this include sustainability considerations
with liquid biofuels, and the air quality impacts of biomass combustion.
12. Government agencies also have a key
role to play, in particular the industrial regulators (the Environment
Agency, SEPA and NIEA in England and Wales, Scotland and Northern
Ireland respectively) and the Highways Agency. The industrial
regulators have a legal duty to address the problem where a regulated
installation is causing a breach of an air quality limit value.
By contrast the Highways Agency are simply obliged to, in effect,
`not make air quality worse', and as a result AQMAs brought about
by roads managed by the HA often go unaddressed, which is a major
area of frustration for local authorities.
13. We have previously mentioned the disconnect
between national- and local-level monitoring (see paragraph 4).
A similar situation exists with delivery—national Government
(Defra) is the legally obligated party, and local authorities
are only required to `work towards' achieving the Air Quality
Standards, which can restrain the political will needed to tackle
the problem at a local level. This problem is especially acute
in cities such as London, where the current mayor holds many of
the powers needed to improve air quality yet fails to take ownership
of the problem, as exemplified by the content of the recently
released London Mayor's draft Air Quality Strategy.
14. Within local authorities themselves
links need to be established and maintained between the air quality
professionals, transport planners, climate change officers and
development control planners. Although there are some local authorities
where effective links exist, there are many where they do not.
Outside of unitary authorities air quality is a district-level
function, whilst transport rests with the county councils. However
there does not appear to be any consistent relationship between
the local authority structure and the existence of effective cross
department links for air quality—there are good and bad
examples under both unitary and multi-tier arrangements.
15. One of the other missing links in the
delivery chain is the role of Regional Government; in most regions
over half the local authorities will have declared AQMAs. Regional
Government has been given no clear tasks or roles in trying to
help relieve the problem, which is especially significant considering
their role in regional transport programmes and spatial planning.
There also seems to be a significant lack of air quality assessments
for future developments coming through the channel of Strategic
Environmental Assessments for Regional Spatial Strategies and
Local Development Frameworks—this is extremely important
as it is very difficult to deal with the air quality impacts of
thousands of new homes when they are presented to air quality
officers piecemeal at a development control level.
16. Much can be learnt from overseas examples
of air quality management. For example in the Unites States clear
roles and responsibilities under their Clean Air Act are assigned
to the Environmental Protection Agency (federal level), and states,
tribes, and other local agencies.[2]
The steps that need to be taken to ensure that
air quality targets will be met in the future
17. Policy measures tend to fall into two
distinct groups. The first is nationally-based technical `end-of-pipe'
fixes for vehicle emissions, which previously seemed to offer
the solution to the air quality issue. However, evidence from
monitoring shows that, after a marked improvement in air quality
during the 1990s following the initial introduction of catalytic
converters, there has been little further improvement in spite
of supposed improved vehicle technology. 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. This is not to undermine the importance of further
improving vehicle emission standards, but is an acknowledgement
that `end of pipe' measures have suffered from diminishing returns,
and cannot be solely relied upon to deliver compliance with air
quality objectives.
18. The second group of measures are those
concerning local action planning. These are delivered in the main
by local authorities, and have to exist within the national context
of more and more traffic being forced on to the roads. The most
many local authorities can do is to re-route traffic from current
hotspots, potentially at the risk of creating new ones. Although
in Local Transport Plan 2 air quality was a `shared priority',
it was rarely an equal one. There seems to be little support from
national government in raising the profile of air quality at a
local level—whilst it is a statutory obligation, at the
moment this is often the only reason it is kept on councils' agendas.
19. An effective way forward will need a
tight balance 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. Enabling actions taken
at a national level will allow for a more tailored approach to
be taken at a local level.
20. One example of where the national—local
approach can be taken is with Low Emission Zones (LEZs)—designated
areas where only vehicles meeting certain emission standards are
allowed to enter. The main LEZ in the UK encompasses almost the
entirety of Greater London, and at present applies to larger vehicles
only, however there are simpler, cheaper more flexible way of
implementing LEZs.[3]
Whilst LEZs are an effective tool for addressing areas of poor
air quality very few local authorities have implemented one. The
main reason for this is the lack of a national framework for local
LEZs to operate within, and the lack of a national testing and
certification scheme for retrofit emissions abatement equipment
(one exists for PM10, but not NOx). Without these, local authorities
find it very difficult to establish a LEZ and, if they do, national
vehicle operators may potentially have to comply with several
different LEZs with different standards and criteria.
21. We have detailed the fragmented nature
of the delivery system in paragraphs 10 to 12 above, and it is
clear that delivery needs to be rethought, and obligations to
act to improve air quality imposed on a number of key delivery
bodies. One of these is the Highways Agency, who need a stronger
obligation to actively improve air quality rather than simply
`not make air quality worse'. Local authorities also need a stronger
obligation than simply `working towards' the Air Quality Standards,
as they are required to under the LAQM regime. We note that, at
the time of writing, Defra is undertaking a review of the LAQM
regime, and we look forward to seeing the outcomes.
22. At both national and local level, work
on air quality is under resourced. 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
UK death toll of approximately 3,000. In contrast poor air quality,
which is believed to be responsible for at the very least 24,000
deaths advanced per year in the UK, only rarely attracts public
attention.
23. It is generally accepted that in the
medium- to long-term improvements in air quality will be secured
via measures taken to tackle climate change, for example the greater
use of electrically propelled vehicles would do a great deal to
improve air quality. However, at the current time there is very
little integration between air quality and climate change policy,
with the result being some adverse effects from well intentioned
measures. One specific example here has been action to lower vehicle
CO2 emissions through tax measures and public information; this
has encouraged diesel vehicles which normally emit lower amounts
of carbon dioxide than petrol equivalents, but greater quantities
of particles and nitrogen dioxide. The Government's vehicle labelling
and `Act on CO2' schemes both largely ignore air quality, despite
their US equivalents including both a CO2 and air quality metric.[4]
24. Both air quality and climate change
policy need to be integrated with transport, policy and a strong
push put forward towards introducing widespread notions of healthy
urban planning. Infrastructure we build now will last 50 to 100
years, and over the last 50 years we have seen an 800% increase
in road traffic. A long-term vision for transport is needed now—the
alternative is that we micro-manage the ever-increasing amount
of traffic on the roads, which will significantly hamper work
to both improve air quality and reduce emissions of greenhouse
gases.
9 December 2009
1 See-www.cleanairinlondon.org/blog/_archives/2009/9/20/4327468.html Back
2
This is explained at www.epa.gov/air/caa/peg/understand.html Back
3
Many European examples are shown at www.lowemissionzones.eu Back
4
http://www.epa.gov/greenvehicles Back
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