Memorandum submitted by the Local Authorities
Coordinators of Regulatory Services (LACORS) (AQ 15)
INTRODUCTION
LACORS (The Local Authorities Coordinators of
Regulatory Services) is part of the LGA Group. LACORS promotes
quality regulation to councils in the areas of trading standards,
environmental protection, licensing and gambling, food safety,
health and safety, hygiene and standards, animal health and welfare
and private sector housing. LACORS offer comprehensive advice
and guidance to councils and their partners, disseminating good
practice and providing up-to-date information on policies and
initiatives that affect local people and local services. We lobby
on behalf of councils and ensure that legislation and government
policy can be practically implemented, and with our colleagues
in the LGA group, ensure we contribute to sector-led improvement.
www.lacors.gov.uk
LACORS works with all local authorities across
England and Wales in a number of key policy areas, including that
relating to environmental protection.
SUMMARY
The monitoring and modelling systems provide
an adequate measure of air quality. It is the question of how
actions to improve air quality can be delivered more effectively
that now requires additional focus.
There is a significant evidence base regarding
the health impacts of air pollution; however the Government may
not be using the most up-to-date information.
It is often frustrating for local authorities
working towards improving air quality that they lack control over
many of the main sources of pollution in their areas and funding
for measures.
The delivery chain for air quality is fragmented
and there is a need for more co-ordinated working at all levels
of government and between the various stakeholders.
Significant behaviour change is required to
reduce emissions and greater public understanding of air quality
sources and impacts is necessary to achieve this.
Detailed comments on the areas of interest to
the Committee are set out below.
The monitoring and modelling systems used by the
Government and whether these provide an adequate measure of air
quality
1. Local monitoring, national monitoring
and modelling and the associated reporting are well established
and relevant local authorities have developed a considerable amount
of expertise in this area. Overall, the monitoring side of local
air quality management works well. The current system may not
provide an exact measurement of public exposure due to the limitations
of locating monitoring stations where exposure is highest, but
we consider that it does provide an adequate measure of air quality.
2. There does sometimes appear to be a disconnect
between local monitoring and Department for Environment, Food
and Rural Affairs (Defra) central modelling, on which we would
seek further clarification.
3. Whilst the measurement of air quality
is of course important, it is the question of how actions to improve
air quality can be delivered more effectively that now requires
additional focus.
The extent to which the Government fully understands
and has identified the health and environmental risks caused by
poor air quality
4. There is a significant evidence base
on the health impacts of air pollution, especially with regard
to particulate matter. The Committee on the Medical Effects of
Air Pollution (COMEAP) has produced several reports, including
on the effect on mortality of long-term exposure to air pollution.
Other international studies have also contributed to our understanding
of the impacts.
5. However, the oft-quoted figure of 24,000
premature deaths per year is now ten years old and based on the
impacts of particulate matter alone; as a result, figures for
air pollution are likely be higher when taking into account other
pollutants such as ozone and sulphur dioxide. In a letter to Mayor
Johnson dated 20 September 2009, the Campaign for Clean Air in
London highlighted that figures for premature deaths caused by
air pollution could be significantly higher than those used by
the Government, if calculated using more up-to-date relative risk
coefficients and by applying the precautionary principle.[22]
6. The Air Quality Strategy 2007 and many
other Government publications quote the statistic of seven to
eight months of life lost which may not necessarily be the most
effective way of expressing the impact, especially to the public.
Averaging out the health impacts across the general population
diminishes the impact per person actually affected ie years lost
per statistical victim, which could be as high as 9.8 years.[23]
7. In comparison with particulate matter,
there is much less evidence on the impacts of nitrogen dioxide
partly, due to relatively limited research. As a result, some
people doubt the need for action although LACORS would advocate
a precautionary approach. Moreover, nitrogen dioxide targets are
of course enshrined in EU legislation.
8. That the health impacts of air quality
are relatively well established has not translated into prioritisation
of the issue by the Government, particularly outside of Defra.
9. There is no question that the UK must
act to improve air quality; indeed, failure to meet EU objectives
and the known health impacts make it imperative. This being the
case, the Government should use cost-effectiveness analysis to
assess which measures should be taken as opposed to cost-benefit
analysis which has a tendency to rule out many actions that could
make a significant difference. Several measures considered in
the Air Quality Strategy 2007 were ruled out for this reason.
10. We would also encourage the Government
to review the weighting given to air quality impacts in its analyses
to ensure that the figures are appropriate and up-to-date with
current evidence.
11. It is not only the Government that needs
to better understand the risks posed by poor air quality. If we
are to be successful in reducing emissions, significant behavioural
change such as a modal shift away from private vehicle use is
needed by the public. In addition, many `big wins' for air quality,
such as low-emission zones, require significant public buy-in
for them to be politically tenable. The experience of the referendum
on congestion charging in Manchester illustrates this point. Air
pollution often cannot be seen, smelt or tasted by the public
and most people do not understand that it harms their health,
all of which contributes to its low profile.
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
12. The delivery chain for improving air
quality is fragmented, largely due to so many different actors,
both centrally and locally, having an interest or control, be
it the measurement of air pollution, its health impacts or control
over its sources. This can result in no one organisation fully
grasping all aspects of air quality which can result in the issue
`falling through the cracks'.
13. It is often frustrating for local authorities
working towards improving air quality that they have a lack of
control over many of the main sources of pollution in their areas,
such as roads overseen by the Highways Agency and bus operators,
and insufficient funding to implement measures.
14. The Highways Agency has a commitment
to `not make air quality worse' and to work with local authorities
on Local Air Quality Management; however there is frustration
amongst some local authorities that the air quality in their areas
is largely affected by traffic from roads that are the responsibility
of the Highways Agency. The Highways Agency is itself constrained
by limited funding for `environmentally incentivised schemes',
which has to cover the full spectrum of the environment and is
not sufficient to address air quality problems. There are some
localised problems of communication between local authorities
and the Highways Agency that the Highways Agency is seeking to
resolve through improved internal arrangements, which are to be
welcomed.
15. Buses can be a significant source of
pollution in some areas and for local authorities outside of London
the deregulation of bus services has left them with very limited
power over the quality of both services (routes, timing etc) and
vehicles standards.
16. The Department for Transport (DfT) contends
that the introduction of Quality Bus Contracts and Partnerships
have restored the balance of power in this respect. However, Quality
Bus Contracts have had very limited take-up as they are expensive
and complex to establish. Bus companies also prefer the informal
approach of Quality Bus Partnerships and are therefore reluctant
to enter into a more formal contract.
17. Links between central government departments
require improvement. Recently, Defra and DfT appear to be linking
up more effectively including quarterly liaison meetings between
officials from these departments and LACORS officers. However,
truly consistent joined-up policy across all relevant departments
is still lacking. Although Defra and DfT are principal government
departments with regard to air quality, it is essential that the
Department for Energy and Climate Change, Communities and Local
Government, Department of Health and HM Treasury also engage in
and indeed prioritise air quality issues, which they appear to
have been somewhat reluctant to do thus far.
18. We recognise that there is also a challenge
for local government to work more effectively across authorities,
both between departments and across geographical areas. This can
be, but is not always, more pronounced in two-tier areas where
air quality officers sit within the district authority and planners,
who can lever key action on air quality, are located at the county
level.
19. The link between air quality and planning
is crucial. The places we live have too often been planned around
private transport and individual journeys. The work done by the
low-emission strategies group highlights some best practice in
using the planning system to encourage new technologies and reduce
emissions from developments.[24]
20. Co-ordinated policies across departments
in both central and local government would help to highlight the
links to other public health issues such as obesity, physical
fitness and climate change which could increase awareness and
the profile of air quality.
21. Local authorities are not adequately
resourced to make many of the changes required to bring about
a significant improvement in air quality, for example public transport
improvements and making cycling and walking easier. Many would
be willing to take further measures, but are constrained by a
lack of funding. At a time when local government is facing even
greater pressure on budgets, which must be stretched and shared
between competing services, lack of action does not necessarily
denote a lack of understanding or commitment.
22. A recent Cabinet Office report on urban
transport[25]
estimated the health costs of particulate matter alone to be in
the region of £5-10 billion per annum. Combined with the
threat of EU infraction fines potentially running into hundreds
of millions of pounds, a compelling economic argument for investing
in measures to mitigate air pollution becomes clear.
The steps that need to be taken to ensure that
air quality targets will be met in the future
23. As outlined in the response above, there
are many barriers to improving air quality. Some parties argue
for strengthened duties or targets on local authorities to deliver
cleaner air or to deliver EU targets. Whilst recognising that
the current wording in the Environment Act 1995 could be tightened,
placing a more stringent duty on local government is completely
meaningless without the necessary powers and funding that could
actually deliver air quality improvements, and indeed duties on
others to act.
24. As highlighted in the section above,
the Highways Agency has a duty not to make air quality worse.
A duty to improve air quality where possible would drive further
action. This should also be accompanied by an appropriate increase
in funding for measures.
25. Detailed guidance on Quality Bus Contracts
was only extremely recently published by DfT and we hope that
this will help QBCs to be taken up more widely. However, there
is still likely to be a lack of control over bus services in most
areas outside of London. One option is devolving the distribution
of bus subsidies to local level would allow the funding to be
targeted according to local priorities, which could include encouraging
the uptake of cleaner vehicles, improving service performance
and reducing congestion.
26. Low-emission zones can be effective
mechanisms for reducing emissions and are more widely implemented
in other EU member states.[26]
Although a `one size fits all' approach would not be appropriate,
a national framework setting out common standards for different
types of vehicles that local authorities could select from depending
on the nature of local pollution sources, and a common easy-to-enforce
approach, would have a number of benefits. It would help to provide
more of a central lead, reducing the political and financial risk
involved in their establishment; provide more consistency for
industry affected; help to prevent the displacement of higher-emission
vehicles such as buses into other areas with lower standards;
and reduce the scope for concern that businesses will locate in
other nearby areas. LACORS has had initial discussions with DfT
and Defra on this issue and will continue to liaise with them
on how this framework might look to ensure that, if produced,
it contains what local authorities need.
27. Central government could play a useful
role by co-ordinating a stronger and more comprehensive evidence
base on the effectiveness of measures that local authorities could
access to inform their air quality action plans. Central collation
of this information, for example what measures work well or not
in which type of area or situation, would reduce duplication at
local level across the country.
28. In the future, it must be ensured that
the planning system gives more consideration to reducing reliance
on cars. `Retrofitting' existing poor planning is not easy, but
greatly improved public transport and cycling and walking infrastructure
can play a big role in this and would bring major benefits including
for air quality, climate change, fitness and general wellbeing.
29. The challenges of finding funding for
measures such as public transport improvements have been highlighted
earlier in this response. The Department for Health is the key
beneficiary of reducing pollution levels in terms of health benefits
and consideration should therefore be given to providing some
funding for local authority actions through Primary Care Trusts.
30. It is vitally important that the Government
adopts and uses the most up-to-date evidence regarding impacts
on health and mortality of air pollution and that the public is
made aware of this evidence.
31. Behavioural change would bring some
of the greatest benefits for air quality and climate change, although
it is hard to achieve; as discussed in paragraph 11, it is important
that public understanding of air quality issues is raised. Defra
carried out a `Citizen's Jury' in 2006 to explore public views
on air quality.[27]
The results showed that at the beginning of the exercise, there
was no understanding of how air quality is measured, the health
impacts, or that action can be taken by individuals to improve
it. At the end of the process the participants agreed that the
issue of air quality was more important than originally thought,
due to the health impacts. The citizen jurors recommended a public
awareness campaign that provided information on the cause and
implications of air quality and what individuals could do to make
a difference and how they would benefit as a result. This campaign
should now be delivered with urgency, funded by central government
and delivered in co-operation with local authorities.
32. Other initiatives could also be rolled
out on a wider basis as part of such a campaign. For example,
air alerts established in London[28]
and Sussex[29]
provide free alerts of expected air pollution incidents and related
health advice to those with medical conditions that are exacerbated
by air pollution. Innovations such as the low-pollution route
option available on www.walkit.com can also help raise awareness.
33. The relationship between air pollution
and climate change is not straightforward and it is essential
that further effort is made to consider both these challenges
in an integrated and holistic manner at both the local and national
level. Many actions to encourage a modal transport shift will
benefit both and these `win-win' solutions should be taken wherever
possible. There must also be greater recognition that there are
sometimes trade-offs, for example, recent years have seen a marked
uptake in the use of diesel vehicles and biomass burning. Both
are considered to be beneficial for carbon dioxide reductions,
but can have negative consequences for local air quality and hence
people's health.
34. The opportunity to raise the profile
of air quality by linking to the momentum surrounding climate
change and CO2 reduction campaigns should be taken wherever possible.
The Government must also ensure that opportunities are not missed
to integrate air quality considerations into research on transport
modal changes.
35. More effective and joined-up policy
is required between all the relevant central government departments
and links between all organisations must be strengthened: between
central government departments, local authorities, the Highways
Agency, the Environment Agency and other stakeholders.
36. There is no simple solution to the issues
around local authorities working together more effectively, which
requires greater partnership working. One option is to create
more strongly shared responsibility across tiers of local government,
for example, responsibility for delivering certain elements of
the air quality action plan sitting where the ability to deliver
them resides.
14 December 2009
22 http://www.cleanairinlondon.org/ Back
23
Knzli et al (2001). Assessment of Deaths Attributable to Air Pollution:
Should We Use Risk Estimates based on Time Series or on Cohort
Studies? American Journal of Epidemiology, 153 (11), 1050¸1055. Back
24
http://www.lowemissionstrategies.org/ Back
25
http://www.cabinetoffice.gov.uk/strategy/work_areas/urban-transport.aspx Back
26
http://lowemissionzones.eu/ Back
27
http://www.defra.gov.uk/environment/quality/air/airquality/publications/citizens-jury/index.htm Back
28
http://www.airtext.info/ Back
29
http://www.sussex-air.net/AirAlert/Default.aspx Back
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