Memorandum submitted by Dr Mark Broomfield
(AQ 17)
1. This evidence is provided by Dr Mark
Broomfield, technical director with Enviros Consulting Ltd. The
views set out in this document are my own, and do not necessarily
represent the views of Enviros Consulting Ltd.
2. In summary, my evidence is as follows:
— Air quality differs from other areas
of environmental science, in that it can be readily measured.
There are tools available to forecast air quality, and their strengths
and limitations are well understood.
— Air quality differs from other areas
of environmental science, in that public exposure to polluted
air is very hard to manage.
— The Government's monitoring systems provide
an adequate measure of air quality. A change in the substances
measured, and a move away from measurement towards more detailed
analysis would be helpful.
— The health and environmental risks caused
by poor air quality are relatively well understood. Research into
some new areas (eg micro-organisms, fine particulate matter and
ammonia) would be helpful.
— Appropriate systems are in place for
control of emissions and management of ambient air quality.
— The delivery of improvements in air pollution
derived from road traffic is the key weakness in the system. Consequently,
air quality continues to fall below the relevant standards and
objectives in some areas.
— It is recommended that guidance is given
to local authorities to support them in deciding to take steps
to manage air quality, where the need to do so outweighs other
considerations.
— It is recommended that a Public Service
Obligation to deliver satisfactory air quality could be placed
on relevant departments.
3. The Committee has asked to be informed
on a number of specific issues. I have set out my views and supporting
evidence on some of these issues below.
INTRODUCTION
4. It may be helpful for the Committee to
appreciate key differences between the management of air quality,
and the management of other environmental pathways for exposure
to pollution.
5. Air quality science has had the benefit
of many years of investment in research to develop tools for monitoring
and forecasting/estimating air quality. Additionally, air quality
issues are relatively amenable to the use of forecasting tools.
For example, the influence of meteorology on the dispersion of
air pollutants is essentially repeatable, and can therefore be
coded into predictive model systems. In contrast, other pathways
for exposure to environmental pollution cannot be forecast in
the same way. This means that there are highly detailed tools
available for measuring and forecasting air pollution. The use
of these instruments and models is more widespread than is the
case for other environmental media.
6. A very important difference is the difficulty
of managing exposure to air pollution. In the case of (for example)
water pollution, people can be advised or prevented from drinking
a particular water supply. In the case of a hazardous contaminated
land site, access can be prevented. While these measures are undesirable,
relatively straightforward controls are available. In contrast,
in the case of air pollution, the public cannot be advised not
to breathe the air. The management measures broadly comprise moving
people away from a source of pollution, and reducing emissions
from the source(s) of air pollution. In many cases, neither option
is particularly straightforward or attractive.
7. The availability of measurement and forecasting
methods, and the difficulty of control, have shaped the practice
of air quality management in the UK.
The monitoring and modelling systems used by the
Government and whether these provide an adequate measure of air
quality
8. The Government's systems for measuring
air quality comprise principally the following:
— A wide-ranging network of air quality
monitoring stations (www.airquality.co.uk).
— Interpolated datasets of background air
quality (www.airquality.co.uk).
— A framework for local authorities to
assess air quality in their boroughs known as "Local Air
Quality Management", supported by a set of assessment and
modelling tools (www.defra.gov.uk/environment/quality/air/airquality/index.htm;
see also www.uwe.ac.uk/aqm).
— A system of regulation of industrial
pollution implemented by the Environment Agency and local authorities.
9. The availability of detailed air monitoring
methods, together with quality assurance procedures and systems
for data dissemination means that the Government's monitoring
systems provide an adequate measure of air quality.
10. The monitoring systems used on behalf
of national and local government deliver an extremely large body
of data. There is limited benefit in continuing to expand this
network. Instead, attention should be limited to monitoring air
quality in areas of high pollution; areas which are representative
of the range of exposures experienced by the public; and locations
which are required to fulfil obligations under European directives.
11. It would be more beneficial to investigate
the measurements carried out in more detail. At present, most
datasets are simply analysed to identify compliance with air quality
objectives and guidelines. There is much more information within
these datasets which could be developed—for example, to
support models of exposure. The European-funded OpenAir project
is an example of work in this area (www.openair-project.org).
More detailed data analysis could be brought more into the mainstream
of Government's thinking on air quality.
12. It would also be very useful for investment
to be shifted towards measurements of other substances, rather
than focusing mainly onEn those specified under the European directives.
Substances which are particularly relevant at present include
ultrafine particulate matter and nanoparticles. There is considerable
concern about these fractions of particulate matter, but very
little environmental data compared to the much more widespread
data available for larger size fractions such as PM10. There is
a need for baseline measurements of Chromium VI with an appropriate
Limit of Detection, following the guideline published in the recent
EPAQS report www.defra.gov.uk/environment/quality/air/airquality/panels/aqs/index.htm).
More widespread measurements of airborne hydrogen fluoride and
hydrogen chloride would be helpful in support of the development
of installations such as power stations and waste management facilities.
Measurements of a wider range of volatile organic compounds, particularly
focusing on halogenated compounds, would also be helpful for a
wide range of industrial and waste management processes.
The extent to which the Government fully understands
and has identified the health and environmental risks caused by
poor air quality
13. There has been considerable research
into the health and environmental risks posed by poor air quality.
This has highlighted potentially significant health risks posed
by a range of air pollutants, and has led to the development of
methods for evaluating these risks to health (eg www.dh.gov.uk/ab/COMEAP/DH_108151).
Health risks are also considered by the Expert Panel on Air Quality
Standards. While there remains some uncertainty in this area,
compared to other environmental pathways, the health and environmental
risks caused by poor air quality are relatively well understood.
This enables the loss of life and associated costs to the UK economy
resulting from poor air quality to be estimated-for example, as
in the introduction to the Environmental Audit Committee (EAC)
call for evidence.
14. The risks to health and the environment
caused by poor air quality are discussed in the Air Quality Strategy
2007, and form a key input into the specification of air quality
standards, and the system of air quality management in the UK.
15. The main outstanding areas of knowledge
and understanding are on substances other than those forming the
mainstream of local air quality management. Further attention
to these substances would be beneficial:
— Micro-organisms from sources including
agriculture, waste management and sewage processing;
— Ultrafine particulate matter and airborne
nanoparticles; and
— The potential effects of ammonia on ecosystems.
There is very limited evidence of the effects of ammonia on ecosystems.
This limited evidence has been used as the basis for a substantial
regulatory burden on operators of intensive livestock farms and
waste management facilities. Further evidence on the significance
of such effects, and the types of habitat site which could be
affected would be helpful.
Is the delivery chain for air quality coherent,
integrated, coordinated and effective? Do the bodies with responsibility
for managing air quality have appropriate incentives, understand
their role and responsibilities, and have adequate resources?
16. In broad terms, the delivery chain for
air quality management is as follows:
— Assessment of air pollution from individual
sources (ie "what goes up"): this is carried out by
the source operators, and is typically regulated by the Environment
Agency and/or local authorities. Appropriate systems are in general
in place via the pollution control or land-use planning systems.
— Assessment of ambient air quality (ie
"what comes down"): this is the responsibility of local
authorities. Now that local authorities have had considerable
experience of local air quality management, they generally have
appropriate arrangements in place for air quality assessment.
— Management of ambient air quality where
needed: this is the responsibility of local authorities working
jointly with the Highways Agency, the Environment Agency, and
local authority highways and environmental teams. The delivery
of improvements in air pollution derived from road traffic is
the key weakness in the system.
17. Road traffic is the principal cause
of air quality problems in the UK, and lies behind the vast majority
of declared air quality management areas. However, it is often
difficult to deliver genuine improvements in air quality in these
areas. The reasons for this include the following:
— It can be technically difficult to identify
an effective solution to an air quality problem.
— Dealing with an air quality problem (eg
by restricting traffic) could result in further problems (eg reduced
economic activity in a town centre, or air quality problems elsewhere).
— Changes in or restrictions to road traffic
tend to be unpopular with local people, and are difficult to deliver
politically. People are often not aware of an air quality problem,
but would be acutely aware of traffic restrictions. Good practice
for public consultation on air quality was studied by the University
of the West of England (www.uwe.ac.uk/aqm/files/Steps_to_Better_Practice_Guidance_on_LAQM_Consultation.pdf).
— The primary responsibility of highways
bodies is the safe and effective delivery of road transportation
infrastructure. This can work against the need to reduce traffic
to deliver satisfactory air quality.
18. In some cases, air quality and highways
improvements can go hand in hand. However, where a choice has
to be made between improving air quality and maintaining highway
capacity, it is often air quality which is sacrificed. The evidence
for this is the relatively high number of air quality management
areas in which air quality continues to fall below the relevant
standards and objectives.
The steps that need to be taken to ensure that
air quality targets will be met in the future
19. To meet air quality targets in the future,
it is important that an appropriate balance is struck between
achieving air quality, and other issues which affect the public.
These include economic issues, land-use policies, noise, health
and wellbeing, and highways considerations (safety, capacity etc).
The weight to be given to achieving air quality targets and the
means by which this can be achieved will always be a matter of
judgement.
20. It may be helpful for air quality policy
guidance (www.defra.gov.uk/environment/quality/air/airquality/local/guidance/index.htm)
to assist local authorities in identifying unambiguously what
steps are appropriate in order to achieve air quality targets,
having regard to other potentially competing policy objectives.
This could give more weight to a local authority in taking the
difficult decisions and securing the changes needed to deliver
genuine improvements in local air quality.
21. The benefits of achieving air quality
targets can be quantified in economic terms, and set in the context
of the costs and benefits of other policies. In the light of this,
it may become apparent that achieving the targets is not a sufficiently
high priority at present. One option to increase the priority
given to achieving air quality targets would be to specify a Public
Service Agreement for Defra, the Department of Health and the
Department for Transport to work together to deliver satisfactory
air quality under the LAQM regime.
14 December 2009
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