Memorandum submitted by the Air Quality
Management Resource Centre, University of the West of England,
Bristol (AQ07)
THE KEY
POINTS MADE
IN OUR
RESPONSE CAN
BE SUMMARISED
AS FOLLOWS:
Over the last decade, the UK's Local Air Quality
Management regime has identified a very large number of air pollution
`hotspots' that were unforeseen. In this regard the Review and
Assessment part of the LAQM process can be considered as a major
policy success.
The LAQM process has not been as successful
at controlling or mitigating air pollution problems as it has
been at identifying them. A number of key reasons lie behind this.
They include a lack of political priority and other drivers for
action at a local authority level, a tendency for policies at
a national level to focus on technical measures and not adequately
support potential measures at a local level, and a continuing
growth in road traffic on urban networks that are unable to cope
with the traffic flows (both in terms of congestion and having
characteristics that prevent the dispersion of the consequent
pollution).
Air quality has not been effectively integrated
within policies concerning transport, spatial planning or health
at either local or national levels and this has led to it failing
to be given due regard in these areas
ABOUT THE
AIR QUALITY
MANAGEMENT RESOURCE
CENTRE AT
UWE, BRISTOL
1. The AQMRC is based at the University
of the West of England, Bristol and was formed in 1998. Since
1999, it has (in partnership with Air Quality Consultants Ltd.)
held a contract with Defra (and formerly with DETR) for undertaking
management tasks in relation to the Local Air Quality Management
process. These tasks include:.
— the appraisal of local authority Review
and Assessment reports;
— the management of archives of reports
and Air Quality Management Area orders;
— the maintenance of databases to record
and track these documents and other elements and indicators of
progress within the LAQM system;
— the operation of a telephone, email and
internet based helpdesk service to help local authorities with
their work; and
— support in the writing and updating of
official guidance for Defra and the Devolved Administrations.
2. In addition to the LAQM contract with
Defra and the Devolved Administrations, AQMRC has also carried
out a wide-range of other LAQM work for UK local authorities.
This has included carrying out and providing assistance for review
and assessment work and air quality action planning, support and
facilitation for consultation and engagement exercises with the
public and other key stakeholders, and training provision to enhance
capability and capacity, specifically for LAQM but also in related
areas of air pollution, climate change, and land-use and transport
planning. AQMRC has a significant research background based on
air quality management funded by prestigious research organisations
including ESRC, NERC and EPSRC. This has generated an extensive
peer reviewed publications list, and has allowed the development
of a renowned track record in supervising and examining PhD students
in the field of LAQM. AQMRC was also instrumental in the design
and development of the Institute of Air Quality Management in
order to promote and support the increasing number of professionals
working in this field.
3. AQMRC are internationally recognised
for their leadership in the field and have been involved in a
number of major international projects. The group has also had
significant involvement in the promotion of the UK LAQM Framework
as good practice in a range of contexts, including the EU Framework
V INTEGAIRE (Integration of Environmental Governance and Air Quality
in Europe) project, the provision of support for the development
of air quality capacity in Bangkok Metropolitan Administration,
and in the development of the South African National Framework
on Air Quality (which used the UK system as a basic model).
4. The AQMRC is a part of the Institute
for Sustainability, Health and Environment (ISHE). This is an
Institute comprising a wide-range of research groups covering
key areas of research into: sustainable communities and the built
environment; public health and well-being; and environmental sustainability.
RESPONSES TO
THE SPECIFIC
ISSUES RAISED:
5. The following sections provide specific
responses to the issues raised in the call for evidence.
THE MONITORING
AND MODELLING
SYSTEMS USED
BY THE
GOVERNMENT AND
WHETHER THESE
PROVIDE AN
ADEQUATE MEASURE
OF AIR
QUALITY
6. The answer to this depends upon the spatial
scale of analysis that is used or required. National monitoring
networks and modeling efforts provide an adequate basis for determining
the general spatial and temporal variation in air pollution across
the UK. The adequacy declines when shorter timescales or smaller
spatial scales of analysis are required. Thus this question fails
to distinguish between monitoring and modelling carried out by
national and local government. Through the LAQM system, which
requires (where appropriate) modelling and monitoring to be carried
out by Local Authorities, there is a strong case for arguing that
the Government has established a system whereby LAs are its `eyes
and ears' on the ground with regard to air quality—a fact
that has allowed the Government to identify well over 500 individual
air quality hotspots in the UK—many of which would be invisible
to them were they to rely solely on the national monitoring and
modelling programmes.
7. National modelling is unable to recognise
and account for the major influence on air quality of local congestion
and street scale topography (eg street canyons, bus stops, minor
junctions, pedestrian crossings etc). These very local circumstances
now constitute the majority of problems identified and declared
as AQMAs by the LAQM process.
8. Automatic monitoring as carried out in
the AURN tends mainly to be focused on urban centre/background
sites rather than roadside sites where AQ problems are worst (although
this is now changing due to EU regulations). Even where monitoring
is at roadsides, it is rare that automatic monitors can actually
be sited in the narrow streets that are the worst hotspots (see
above). The fact that the national monitoring network has not
picked up these areas has allowed the national modelling to also
overlook them.
9. National modelling itself only covers
major roads (predominantly trunk roads) and these tend not to
be the ones where the problems caused by congestion and canyon
effects occur.
10. The LAQM process can be split into two
clear sections—Review and Assessment and Action Planning.
The Review and Assessment part of the process can be considered
to be a significant achievement. When the LAQM regime was established
in 1997, it was thought that there would only be the need for
the declaration of a handful of Air Quality Management Areas,
and yet 10 years later, despite a vastly cleaner transport fleet,
60% of Local Authorities have now had to declare AQMAs. Although
some information from this process is used to address the EU-orientated
work (such as the reporting to Defra of Local Authority operated
automatic monitoring sites that exceed the Limit Values), there
is little sign that national policies are significantly responsive
to the, now widespread, problems at the LA level.
THE EXTENT
TO WHICH
THE GOVERNMENT
FULLY UNDERSTANDS
AND HAS
IDENTIFIED THE
HEALTH AND
ENVIRONMENTAL RISKS
CAUSED BY
POOR AIR
QUALITY
11. Within Defra, and in the Department
of Health (eg COMEAP) there is a significant understanding of
the risks of poor air quality. However there is little evidence
that that this appreciation is shared by the departments that
are more closely related to the control of many air pollution
sources (eg DfT, DECC, BERR).
12. Government reports have identified the
health impacts of air quality in the UK as being almost twice
those of physical inactivity (£20 billion compared to £10.7
billion—Defra Air Quality Strategy 2007, Chief Medical Officers
Report 2004) yet it fails to receive quite the same level of attention
as the latter within medical and media circles. Similarly, some
studies have suggested that the cardiovascular risk of exposure
to traffic pollution "may well be similar to that played
by passive smoking" (COMEAP 2006), however at the level of
national action there seems to be little evidence of comparative
attention being given to the issue.
13. There seems to be a lack of clarity
regarding how the Government communicates the health risks of
air pollution on individuals, both in terms of differing levels
of personal exposure to pollutants and to how susceptible people
are to the effects of pollution. For example, the seven to eight
month average shortening of life cited in the Air Quality Strategy
is probably an over-estimate for the majority of people, but a
very significant under-estimate for the most sensitive individuals.
Without making health information meaningful to people, it is
not likely that air pollution will raise high enough on local
political agendas for effective action to be prioritised by local
authorities.
14. There has been very little linkage made
between air quality and other policy areas covering health and
environmental risks—the causes and effects of air pollution
are still dealt with in different departments DfT, DCLG, DoH.
The consequent lack of joined-up policy fails to emphasise the
multiple wins that would be achieved by much greater coordination
of policies. One example would be the promotion of cycling and
walking. This can help relieve congestion, reduce emissions of
`conventional' air pollutants, and see a significant increase
in average levels of physical activity (thus both reducing the
incidence of heart disease, and increasing resilience of individuals
to the impacts of air pollution). In addition to this it would
also help reduce climate change related emissions. If we turn
this round and look at what bio-fuel policies have achieved, they
may have failed even to reduce the climate impacts that they were
introduced to mitigate, but they also failed to address any of
the other negative impacts of transport (there is some evidence
to suggest that they may be slightly less harmful in terms of
`conventional' air pollution emissions but this is not well established).
15. There has been a failure to provide
suitable information to relevant stakeholders on the health effects
of air pollution. Like it or not, the main statistic that the
public and media are interested in is "How many people die
every year from air pollution?". The only authoritative figure
that has been produced for this is from the 1998 COMEAP report
(The quantification of the effects of air pollution on health
in the United Kingdom) that cited 24,000 premature deaths for
1995-96. At the time there was some concern that this might be
an over-estimate, yet by 2007 it was still the only figure that
the Royal Commission for Environmental Pollution could cite in
its report on the Urban Environment. In addition to an initial
perception that this might have been too high, there is often
an assumption made that, over time, this figure is likely to have
reduced. Contrary to this though, the science on the impacts of
air pollution on health has advanced and based on the latest evidence
(as summarised in work such as COMEAP's 2009 study "Long-term
effects of Air Pollution on Health") groups ranging between
Clean Air For London (see their submission to the EAC for further
details) and the European Environment Agency currently suggest
that this figure should be somewhere between 30,000 and 50,000.
THE EXTENT
TO WHICH
THE DELIVERY
CHAIN FOR
AIR QUALITY
IS COHERENT,
INTEGRATED, COORDINATED
AND EFFECTIVE
AND WHETHER
THE BODIES
WITH RESPONSIBILITY
FOR MANAGING
AIR QUALITY
HAVE APPROPRIATE
INCENTIVES, UNDERSTAND
THEIR ROLE
AND RESPONSIBILITIES,
AND ARE
ADEQUATELY RESOURCED
16. With regard to nitrogen dioxide, the
Government is now at risk of failing to meet the EU Limit Value
in 2010, but a decade ago the Government established its own domestic
"Air Quality Objective" for this pollutant setting an
achievement date of 31st December 2005, confident that it would
be able to meet it. By the end of 2005 it was clear that a significant
number of Local Authorities were not meeting this objective. However,
there is little evidence that the clear and widespread failure
to meet the objective at this time resulted in a significant `ramping
up' of action at the national level. There has therefore been
nearly 5 years' notice that the expected improvements in UK air
quality have not materialised at the rate anticipated and the
failure to meet the EU Limit Values is in no way a sudden surprise.
17. The revision of the Air Quality Strategy
in 2007 provided a suitable time to tackle this, however the final
document has been widely criticised for downplaying behavioural
change measures and placing too strong a reliance upon technical
interventions (and even then not being prepared to push forward
action in many circumstances where benefits out-weighed costs).
In the light of the widespread failure to meet the 2005 NO2 objective,
one of the most significant parts of the AQS revision can be seen
to be the clear statement that the UK air quality objectives had
no legally binding status and were merely "statements of
policy intent".
18. AQ policy seems to have been forced
down two separate roads in the UK with little alignment or co-ordination
between them. These are:
— Nationally based technical end-of-pipe
fixes which, at best, are only able to produce increasingly small
incremental improvements post Euro 3/III, and in practice often
appear not to work as expected or hoped and, in any event, air
quality gains from these measures being quickly eroded by growth
in traffic.
— Local action planning, which has to exist
within the national context of more and more traffic entering
the road network and individual vehicles travelling further each
year, and struggle against a low profile for air quality at both
national and local levels, with few obvious political champions
for clean air.
19. The most that many LAs can do is to
re-route traffic from current hotspots but this has the potential
risk of creating new problems elsewhere. Although in LTP2 AQ was
a "shared priority", research we have undertaken reveals
that air quality was rarely an equal one and was often seen by
LAs as the least important area of the stated priorities.
20. There is little support from national
government in raising AQ's profile at a local level—whilst
it is a statutory obligation at the moment this is often the only
thing that means it is kept on councils' agendas—and the
statutory obligations are focused far more on assessing air quality
than on bringing about improvements. More work on supporting local
activities would go a long way—but there is little evidence
that the national policy response offers any ideas other than
technical measures. Air quality needs to be more closely integrated
with transport planning at local and national levels, and a strong
policy and implementation emphasis given to introducing healthy
urban planning. The current planning system still deals with development
in a piecemeal way. It is unable to deal with the differences
in timescale that exist between the renewal of urban infrastructure
and the growth in traffic—leaving our urban centres choked
by levels of traffic that they were never designed for. It is
also unable to adequately cope with the cumulative impacts of
new developments.
21. One of the other missing links in the
delivery chain is the role of regional government. In most regions
over half the LAs have now declared AQMAs. Despite this, regional
government offices have been given no clear tasks or roles in
trying to help relieve the problem—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 SEAs for RSSs and LDFs—LA officers seem to be tasked
with dealing with assessing the major housing provision on a development-by-development
level which is unable to cope with the likely cumulative impacts
of 1000s of new houses.
THE STEPS
THAT NEED
TO BE
TAKEN TO
ENSURE THAT
AIR QUALITY
TARGETS WILL
BE MET
IN THE
FUTURE
22. There has been recent discussion that
the costs for failure to meet the EU Limit Values will be borne
(directly or indirectly) at a LA level. This may be an entirely
inappropriate action as LAs will claim that the support and policy
steer that they have been given have always made it clear that
responsibility for achieving EU Limit Values rests with central
government not themselves. The strongest direction given was in
phrases such as "responsibility to work towards meeting the
objectives". Following the clear failure of a large number
of authorities to meet the 2005 NO2 objective, at the point where
stronger central direction would be most appropriate, the government
chose to clarify the situation by stating that there was no expectation
for either LAs or the Secretary of State to meet the objectives,
and confirming that the objectives were merely "statements
of policy intent". The time to threaten LAs with financial
costs of not meeting the objectives would have been a decade ago,
at which point it may well potentially have been a significant
driver for action. However, over the last ten years there has
been limited incentive for LAs to place air quality high on their
political agendas. As a consequence local actions have been limited
in concept, scope, implementation and have had limited effect.
23. Local action backed up by direct support
from central government remains a basic requirement particularly
in terms of an integrated offering in air quality, transport and
land-use planning policies.
10 December 2009
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