Memorandum submitted by the Chartered
Institution of Water and Environmental Management (AQ11)
INTRODUCTION
The Chartered Institution of Water and Environmental
Management (CIWEM) is the leading professional body for the people
who plan, protect and care for the environment and its resources,
providing educational opportunities, independent information to
the public and advice to government. Members in 98 countries include
scientists, engineers, ecologists and students. This response
has been prepared by CIWEM's Air Panel which comprises academics
and practitioners working in the air quality field.
1. SUMMARY
1.1 The UK has a long history of managing
air quality going back to when coal was first used as a fuel.
Since the Clean Air Act of 1956 the winter smogs[8]
caused by burning coal gradually disappeared, such that by the
late 1970s this type of smog was a thing of the past. Since then
the dominant source of poor air quality has been, in most areas,
traffic emissions. Emissions from motor vehicles have been controlled
for nearly 40 years, yet we fall short of ambient air quality
objectives, continue to exceed EU limit values, and pay no regard
to the WHO guidelines set for the protection of human health.
People continue to be adversely affected by poor air quality.
1.2 UK air quality policy relies on computer
modelling that does not properly account for congested traffic.
This modelling has consistently forecast improvements since the
early 1990s, yet the reality in many locations has been that air
quality over the last decade or so has remained the same or deteriorated.
1.3 Local Air Quality Management (LAQM)
has been implemented since 1997, yet new air quality management
areas (AQMAs) continue to declared, as monitoring programmes have
been extended and non-compliance with the objectives identified.
Few have been revoked.
1.4 We now know more about air quality than
at any time in history, yet air quality management, nationally
and locally, has failed to deliver clean air.
1.5 We believe that there are significant
gaps in our knowledge and approach to managing air quality in
this country.
1.6 Our concerns can be summarised by five
key inter-related issues that need addressing:
(a) Lack of leadership and responsibility.
(b) Climate change diverting political interest
away from air quality.
(c) Inadequate research funding.
(d) Over reliance on modelling.
(e) Lack of local authority priority.
2. LACK OF
LEADERSHIP AND
RESPONSIBILITY
2.1 We believe that air quality management
at both the national and local levels has delivered little because
of the lack of high-level leadership.
2.2 This is illustrated by the fact that
it is rare for a member of the Cabinet nationally or locally to
publically speak about air quality. While to a certain extent
this reflects society's change in focus to climate change, it
does not reflect the severity of the issue.
2.3 Information campaigns, at public expense,
are undertaken to reduce road traffic injuries and death, yet
no similar campaigns are undertaken to educate the public on the
impacts of traffic on air quality and subsequently their health.
2.4 We believe that without political leadership
air quality management will continue to be marginalised and ineffective,
and the health of many people will continue to be adversely affected,
with an associated reduction in their quality and length of life.
2.5 There is a public perception that the
air quality issues have been solved, when this is clearly not
the case.
2.6 There is a lack of co-ordination between
the departments that should be involved in the management of air
quality. It affects and is affected by transport, planning, local
government structure and funding mechanisms.
2.7 At the national level Defra, Department
of Health (DH), Department for Transport (DfT), Department of
Communities and Local Government (CLG), Department for Energy
and Climate Change (DECC) and Her Majesty's Treasury (HMT) all
have an important role to play, so it is encouraging that the
Cabinet Office Strategy unit has included air pollution in its
approach to the wider costs of transport in English urban areas
(http://www.cabinetoffice.gov.uk/media/307739/wider-costs-transport.pdf).
2.8 Air Quality Management Areas (AQMAs)
are often declared due to emissions from roads that come under
the responsibility of the Highways Agency (HA). Although the HA
has responsibility for air quality on paper there is little evidence
of measures being implemented that have had a significant impact
on air quality along HA roads. Often the HA's contribution is
limited to giving directions to local planning authorities where
new development is predicted to increase traffic. Whilst it is
recognised that it is difficult to reduce emissions from HA roads
without a very significant reduction in emissions / traffic the
agency has been reluctant to even consider measures that might
improve the situation, such as implementing lower speed limits.
Where lower speeds have been introduced the primary objective
has been to relieve congestion, not improve air quality.
2.9 It is the same at the local level. For
those areas outside London where there is a two-tier local government
structure, there can be conflict. If only one or two Districts
have an AQMA, for most of the County it is not a priority.
2.10 However, even within unitary authorities,
the environmental protection department tends to have a lower
status, and hence power, than the transport department, and air
quality management is often marginalised.
2.10 The guidance and shared responsibilities
for the second round of Local Transport Plans (LTPs) encouraged
the inclusion of the Air Quality Action Plan (AQAP) within the
second local transport plan (LTP2). Some transport authorities
successfully achieved this, but for most, if included at all,
it was simply an add-on, not fully integrated into the plan.
2.11 DfT is giving more responsibility during
the third local transport plan (LTP3) process to local authorities
to determine their own priorities. This `downgrading' of air quality
will result in even less consideration being given to the full
integration of air quality issues within local transport planning.
2.12 The monitoring and management of air
quality is undertaken by Environment Departments (Defra/Environmental
Protection), whereas the main cause, road traffic, is the responsibility
of transport/traffic departments (DfT/Transport) which have historically
been more concerned with traffic congestion and infrastructure
provision than environmental protection.
3. CLIMATE CHANGE
3.1 Climate change dominates the political
air pollution agenda, to such an extent that some measures are
being taken that have a detrimental impact on air quality and
funding for air quality management and research has been reduced
too much.
3.2 At first sight it would appear that
the mitigation of greenhouse gas emissions and the improvement
of air quality have a common goal, and indeed for measures that
reduce energy demand this is the case. However, there are some
technologies that have lower carbon dioxide emissions but higher
emissions of nitrogen oxides (NOx),[9]
nitrogen dioxide (NO2), and particles (PM10/PM2.5) to the detriment
of local air quality.
3.3 Whilst climate change will have very
significant impacts on our weather in the future, it should not
be forgotten that hundreds of thousands of people are currently
suffering and dying prematurely in the UK from the effects of
poor air quality. The AQS gave the reduction in average lifetime
in the UK as seven months, which is considered an underestimate.
3.4 The climate change agenda has resulted
in measures that promote the use of diesel vehicles which have
higher particulate matter (PM) and primary NO2 emissions than
petrol vehicles. For example, for many years the fuel duty on
diesel was set higher than petrol in recognition of the higher
PM emissions, but this has been removed because of the lower carbon
dioxide (CO2) emissions.
3.5 Another example has been the promotion
of biomass boilers in urban areas where there is existing poor
air quality. Whilst using renewable energy sources must be good
for society, we believe burning biomass where there is poor existing
air quality is inappropriate.
3.6 In many small market towns the only
solution to poor air quality is reducing congestion in town centres.
Building a by-pass is often an unacceptable solution, and even
where it is acceptable locally, there is little money available
for such schemes. As a consequence residents continue to be exposed
to poor air quality.
4. RESEARCH.
4.1 Insufficient research is being undertaken
to solve our air pollution issues.
4.2 When air quality was higher up the political
agenda there were on-going programmes sponsored jointly by Defra
and DfT (and their predecessors) to fund the on-road measurement
of emissions to ensure an up-to-date database on which all national
and local modelling is based. This appears to have been halted
and there is little real world data for Euro 4 vehicles, let alone
Euro 5 HGVs, which are now using our roads. This work is expensive
but essential. An update of the Emission Factor Toolkit, which
is used extensively for local air quality management, assessing
the impacts of new development, and national modelling, has been
promised by Defra for several years, but has failed to materialise.
Therefore modelling, a key tool in the management of air quality,
is based on out-of-date data. This adds to the uncertainity of
the impacts predicted.[10]
4.3 For vehicles meeting future emission
standards it is assumed that emissions will drop in direct proportion
to the improvement in the emission limits, which has historically
proved to be an over-simplistic approach. It is, therefore, hard
to have confidence in this information when projecting forward
into the future.
4.4 The emissions database needs to be extended
to include primary NO2 and, for vehicles fitted with selective
catalytic reduction, ammonia.[11]
Diesel vehicles emit a higher percentage of the NOx as NO2 than
petrol vehicles. The increasing percentage of new cars and vans
using diesel has resulted in a change in the proportion of primary
and secondary NO2 emissions from traffic. This has been exacerbated
by the conversion of NO to NO2 in the exhaust of heavy duty vehicles
fitted with some diesel particle filters, to assist the removal
of PM.
4.5 Also, the DETR-funded TRAMAQ programme
was undertaken several years ago to understand in some detail
emissions from different driving conditions, such as congestion.
This data was not converted into user-friendly tools for use in
LAQM. Much of this data may no longer be relevant as the vehicle
fleet has changed to meet new emission standards, but it needs
updating and converting into useable data for managing air quality.
4.6 Finally, further research is needed
into how both NO2 and nitric oxide (NO) behave in the atmosphere.
It is likely that further vehicle emission legislation is needed
that controls NO2 as well as NOx emissions.
4.7 The UK (DETR) invested substantial sums
of money in the Particle Management Programme (PMP), in association
with a number of other EU member states, as well as Switzerland
and Japan. The aim was to recommend a new type approval test procedure
to measure the number of particles rather than the mass. We need
to show similar international leadership on the NO2 issue.
5. MODELLING
5.1 The current methods of modelling air
quality at a national level cannot take account of local characteristics,
with the consequence that poor air quality in some areas is being
inadequately taken into account in national decision making. This
is not a criticism of the modelling per se, but rather a recognition
that local issues cannot be reflected in national models and that
a mechanism to account for significant local issues needs to be
built into a more robust decision-making process.
5.2 UK policy formulation in recent years
has been based on cost-benefit analysis, which has been inadequate
at accounting for the costs and benefits, and the uncertainties
attached to both. Though extended and updated in the Stratgy Unit's
2009 report, the precision attached to such figures is unmerited.
5.3 The approach is inappropriate for identifying
the best policies for achieving the EU limit value, which is a
legally binding requirement. Cost-benefit analysis[12]
has a role in identifying priorities for a range of possible options,
but not how to meet a mandatory requirement. For the latter cost
effectiveness is the most appropriate technique to use. This is
the means of identifying the cheapest package of measures to society
to meet a target.
5.4 National modelling is undertaken on
behalf of Defra to identify air quality policies and quantify
the emissions benefits of a range of measures. Extensive modelling
was undertaken as part of the review of the Air Quality Strategy
(AQS),[13]
and more recently as part of the evidence base for understanding
how and when the UK will achieve the EU limit values for PM10
and NO2. This is necessary to identify an action plan to justify
Defra's application for a time extension under the 2008 Air Quality
and Cleaner Air for Europe, Directive (EU/2008/50)[14]
but the NO2 modelling fails to account for many local exceedances
(arising from congested traffic).
5.5 This modelling is clearly very dependent
on the emissions factors used, for which there are significant
concerns, as highlighted above.
5.6 The modelling approach for the AQS was
cost-benefit analysis. We are concerned that due to the time lag
in policy development, the 2006 US reassessment that doubled the
health impacts of PM2.5 was not incorporated in the 2007 AQS,
nor in the 2009 Strategy Unit figures. For example the dose-response
relationships for the impact of PM10/PM2.5 on health came from
the recent work of the Committee on the Medical effects of Air
Pollution (COMEAP), yet ignored the comments of two eminent US
scientists, who concluded that COMEAP had significantly under-estimated
the health impact.[15]
If the US coefficient of 6-17% were used instead of the 6% taken
in the AQS, further abatement measures are shown as cost effective.
Air pollution costs would be increased to £20-30 billion,
well in excess of other wider costs of transport in the Strategy
Unit's 2009 report.
5.7 Another issue of cost benefit analysis
is how revenue from fuel duty is included in the calculations.
Measures that reduce HMT income are a disbenefit, and although
the price of carbon can be included, this is insufficient to outweigh
the loss of revenue in the NATA model (`New Approach to Transport',
revised version to apply in 2010, www.dft.gov.uk/consultations/archive/2008/consulnatarefresh/natarefresh2009.pdf).
5.8 The national air quality modelling undertaken
does not allow for local circumstances, such as topography and
the presence of street canyons. Concentrating exclusively on the
national model results in a number of measures, for example the
introduction of low-emission zones, seeming not to be cost effective.
However at a local scale they may be.
5.9 Defra's initial modelling showed that
even in 2015 the NO2 limit value would not be achieved in many
areas.
6. LOCAL AUTHORITY
PRIORITIES
6.1 Whilst central government is responsible
for international and national measures to improve air quality,
the LAQM regime has devolved responsibility to local government
for local measures. However, air quality is not high on the agenda
for most local authorities (LAs). LAQM only requires LAs to `work
towards' achieving the objectives. Responsibility for achieving
the mandatory EU limit values lies with Defra.
6.2 Without a mandatory requirement Council
Chief Executives are not going to prioritise air quality. Councillors
are often reluctant to draw attention to the issue, because they
are competing with other areas to draw people, and hence traffic,
to their particular retail and commercial locations. The Government's
policy of giving local authorities more control over the setting
of their own priorities is likely to result in air quality being
marginalised even further.
6.3 Over 230 local authorities have declared
air quality management areas, mainly for exceedence of the NO2
annual mean objective. When LAQM was first introduced it was thought
that there would be a handful of AQMAs in London, not hundreds
with some even in the most rural districts. There was concern
that the declaration of AQMAs would affect property prices however
is no evidence that this is the case.
6.4 LAQM has been very successful at monitoring
and modelling air quality, and since the first AQS was published
in 1997 technical understanding in most LAs has increased exponentially.
The air quality function is undertaken within the Environmental
Protection Departments, often by knowledgeable specialist air
quality officers. The more local authorities have understood air
quality in their areas, more or larger AQMAs have been declared.
6.5 In recent years Defra has provided direct
grant funding to local authorities for LAQM modelling and monitoring
of air quality. This has been perceived as additional money, and
has given local authorities an incentive to fulfil the LAQM review
and assessment requirements.
6.6 However as local authorities are only
under an obligation to `work towards' achieving the objectives
there is no incentive to implement measures which might be unpopular.
This is despite air quality in many areas remaining unchanged
or deteriorating.
6.7 Defra has supplied a range of tools
for LAQM review and assessment. However, similar tools have not
been provided for air quality action planning, and LAs have often
found it difficult to understand the cost and emissions impacts
of different potential measures. As a consequence most AQAPs have
been a long list of general measures with little or no understanding
of their relative importance.
6.8 Even where the impacts have been quantified
little has been achieved. The problem is that radical action is
generally required to comply with the air quality objectives.
In many AQMAs a large reduction in emissions, particularly of
NOx, is needed. The relationship between NOx emissions and NO2
concentrations is complex and non-linear. Reducing NOx emissions
by small amounts, say 10-20%, may make no difference to measured
air quality. Where the annual mean NO2 objective is exceeded by
25% or more (ie is greater than 50 µg/m3), very large changes
to emissions and traffic are required. In small market towns,
the only viable option is the building of a new road to take the
traffic away from busy residential historic streets, where dwellings
are close to the carriageway. If the problem is within a district,
the council has no direct control over transport, but even in
unitary authorities, there is little incentive to give air quality
any priority.
6.9 Unless LAs have a statutory duty to
achieve the air quality objectives it is unlikely that they will
prioritise air quality. However, careful consideration will need
to be given to whether new powers will be required.
6.10 It should be noted that LAs have no
direct responsibility for achieving EU limit values, and that
these apply over a much wider area than the UK objectives. The
latter apply where there is likely to be public exposure over
the relevant averaging time, the former apply more or less everywhere
(exceptions include a few places where the public do not go such
as the central reservation of motorways).
6.11 A new approach is required, that may require
giving LAs new powers to introduce low-emission strategies, to
ensure that the EU limit values are achieved by 2015. These new
powers are likely to be necessary to ensure that the EU grants
the UK government a time extension from the current requirement
for compliance by 2015 with the NO2 limit value.
6.12 We believe one solution may be for local
and national government to have joint responsibility for the delivery
of the air quality action plan. The local authority could estimate
how much of the required emissions reduction they can realistically
achieve, with the gap being filled by national and international
measures. The action plan would need to be drawn up initially
by the LAs and Defra approve it and agree its contribution. This
would be an iterative process to ensure that the balance between
local and national measures is appropriate.
11 December 2009
8 The word smog is derived from smoke and fog. Back
9
NOx is typically regarded to be nitrogen dioxide (NO2) and nitric
oxide (NO). Most NOx is emitted from combustion processes as NO
but is rapidly converted to NO2 in the atmosphere. Back
10
Air quality modelling will always have uncertainty because of
the difficulty in accurately simulating complex atmospheric processes
in mathematical terms. However, the more accurate the emissions
inputting into the dispersion models the more accurate the end
results will be. Back
11
These vehicles use a urea solution in water to produce ammonia
on board, which is an integral part of the emission-reduction
process. Back
12
Cost-benefit analyses put an economic cost to the benefits of
a measure. This is irrelevant if a mandatory limit has to be achieved. Back
13
The most recent Air Quality Strategy was published in 2007. Back
14
An application for a time extension for achieving the PM10 limit
value was submitted in 2009, and Defra has announced its intention
of submitting a time extension application for NO2 in 2010. Back
15
Long-term Exposure to Air Pollution: Effect on Mortality, Committee
on the Medical Effects of Air Pollutants, Department of Health,
June 2009. This report took two years to be published after the
consultant draft was issued in 2007. Peer reviews in Appendix
2 of the final report. Back
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