Memorandum submitted by the Environment
Agency (AQ 25)
1. SUMMARY
Air quality in the UK is not improving sufficiently
quickly to meet UK air quality objectives within the required
timescales.
There have been significant reductions in emissions
of the key air pollutants through the Environment Agency's regulation
of installations under IPPC/EPR.
There is an extensive network of air quality
monitors in the UK but the modelling methods used to predict pollution
impacts sometimes do not represent accurately the impacts of industrial
processes.
Some effects of morbidity from air pollution
are not included in the UK's cost-benefit methodology. The cost
of effects on the natural environment are also not included. This
may lead to the impacts of air pollution on wildlife being given
inadequate attention.
We believe the measures identified as cost beneficial
in the UK's Air Quality Strategy 2007 should be implemented. The
National Ammonia Reduction Strategy that was also proposed should
be put in place to protect sensitive habitats.
The Department for Transport's (DfT) Sustainable
Development Framework for Transport Planning needs to give more
weight to air quality in its matrix of challenges to ensure that
transport planning delivers its contribution to improving the
UK's air quality.
Transport and spatial planners should use the
range of measures available to them to improve air quality and
reduce its effects on people's health and sensitive ecological
systems.
2. INTRODUCTION
2.1 There is growing evidence that the mechanisms
for delivering acceptable air quality are failing in a number
of areas, particularly the measures related to transport. The
UK has had to seek additional time for compliance with the EU
limit values on particulates. Improved monitoring and assessment
by local authorities has led to the designation of more Air Quality
Management Areas for nitrogen dioxide and the UK will be seeking
additional time for compliance with the EU limit values on nitrogen
dioxide. Whilst there have been gradual reductions in the national
emission of nitrogen oxides the complex atmospheric chemistry
of these compounds has led to increasing levels of ozone in some
urban areas. Peak levels of ozone across the UK are generally
declining but background levels are increasing, a situation which
has implications both for human health and agricultural productivity.
2.2 The Environment Agency regulates the
release of air pollutants in England and Wales from approximately
2,800 large and more complex industrial installations e.g power
stations, oil refineries and chemical plants. We also regulate
facilities where waste is handled, stored, treated or disposed
of, such as landfills, waste transfer and treatment facilities,
as well as intensive livestock units and food manufacturing factories.
We do this under the Environmental Permitting Regulations (2007).
2.3 Overall, the Environment Agency has
helped to bring about significant reductions in emissions of a
number of key pollutants through the application of the IPPC/EPR
permitting regime. Releases of sulphur dioxide from regulated
installations have reduced by 60% from a 2000 baseline; particulate
matter (PM10) by 44% and nitrogen oxides by 15% The value of health
benefits from the reductions in emissions of sulphur dioxide,
nitrogen oxides and particulate matter from installations we regulate
is estimated to have totalled £1,100 million between 1990
and 2005.
3. MONITORING
AIR QUALITY
IN ENGLAND
AND WALES
3.1 There is an extensive network of monitors
in the UK that monitor levels of nitrogen dioxide, ozone, particulates
(PM10 and PM2.5) and sulphur dioxide in the air. Around 400 of
these are funded by Defra and the devolved administrations. The
largest of the monitoring networks, with 130 sites, is the Automatic
Urban and Rural Network (AURN). In addition to the national networks
there are many sites operated by local authorities as part of
their Local Air Quality Management activities. Some of these sites
are also affiliated with, and provide high quality data to, the
national networks.
3.2 Modelling is a valuable tool for assessing
levels of air pollutants provided that reliable data on emissions
are available. Defra use modelling to supplement their monitoring
of air quality in order to predict the levels of air pollution
in the UK. However, all models involve degrees of uncertainty
and there have been instances where monitoring on the ground has
shown that models have over- or under-predicted ground level concentrations
arising from point sources. Potentially, this could lead to exceedences
of air quality standards being missed or regulatory effort expended
unnecessarily on non-existent exceedences.
3.3 The Environment Agency carries out occasional
monitoring campaigns in the vicinity of installations we regulate
as part of our pollution control responsibilities. Usually these
are for a short period of time (3—6 months).
3.4 The monitoring of emissions from installations
we regulate under environmental permitting is the responsibility
of the operator. The pollutants monitored, the techniques used
and the frequency of monitoring are prescribed by the permit.
This may need to reflect the requirements of EU legislation such
as the Waste Incineration Directive. Any monitoring must comply
with MCERTS requirements where applicable and the results are
submitted to our local offices where they are made publicly available.
MCERTS is the Environment Agency's Monitoring Certification Scheme.
It provides the framework for businesses to meet our quality requirements.
If operators comply with MCERTS we can have confidence in the
monitoring of emissions to the environment. MCERTS accreditation
is managed by the UK Accreditation Service (UKAS). Data on the
emissions of key pollutants from installations we regulate are
published by us in our Pollution Inventory which is publicly available.
3.5 We are developing a new capability to
coordinate and monitor air quality in the event of emergency incidents,
for example the Buncefield oil terminal fire. We are working with
partners to test the new arrangements and expect them to be fully
operational in 2010.
4. HAS THE
GOVERNMENT FULLY
UNDERSTOOD AND
IDENTIFIED THE
HEALTH AND
ENVIRONMENTAL RISKS
CAUSED BY
POOR AIR
QUALITY?
4.1 The UK Air Quality Strategy (AQS) has
generally identified the pollutants that are likely to have the
greatest health effects and has set controls for these. It has
taken steps in the right direction by also including controls
for PM2.5. However, the mechanism for particulate toxicity, especially
involving ultra fine particles is not fully understood. The Environment
Agency believes there is merit in the World Health Organisation,
the European Union, government and academia investigating further
the effects of particles smaller than PM2.5,for example PM1 and
PM0.1, in order to develop reliable dose-response relationships
which can then be used as a basis for setting standards.
4.2 Unlike the European Commission's Clean
Air For Europe (Café) programme the Government's cost-benefit
methodology for assessing air quality policies and measures does
not fully include morbidity effects such as chronic bronchitis,
restricted activity days (RADs), respiratory medication use and
lower respiratory symptoms. This risks leading to a substantial
underestimate of the costs of the effect of poor air quality on
morbidity.
4.3 The UK AQS focuses on human health effects
as there is currently no method to cost the effects of poor air
quality on the natural environment. The impacts of air pollution
may therefore be underestimated.
5. THE AIR
QUALITY DELIVERY
CHAIN
5.1 The delivery chain through which declared
policies for the improvement of air quality are translated into
actual improvements on the ground is complicated by the number
of bodies whose activities can have an impact on air quality.
Local authorities, Government departments including Defra, DfT,
DCLG, BIS, DECC and the Environment Agency all have roles.
5.2 A key example is the relationship between
transport planning and local air quality control. If air quality
objectives are unlikely to be met local authorities are required
to declare an Air Quality Management Area (AQMA) and develop an
Air Quality Action Plan (AQAP) to work towards meeting the objectives.
In about 95% of cases road transport emissions are the main reason
for local authorities declaring AQMAs. Many of the roads contributing
to pollution hotspots are the responsibility of DfT and the Highways
Agency and in the past neither body has given a high priority
to air quality issues in their plans. We have particular concerns
that this situation may continue within the DfT's recent Sustainable
Development Framework for Transport Planning (see point 6.4 below).
We have further concerns that the guidance for the 3rd round of
Local Transport Plans (LTPs) does not specifically require prioritisation
for dealing with air quality issues.
5.3 The DfT is also responsible for vehicle
standards and implements EU requirements via type approval procedures.
These have not always produced the results intended. For example,
regenerative traps for particulates have increased emissions of
primary nitrogen dioxide by diesel-fuelled vehicles.
5.4 In some instances policies in one
part of the delivery chain could be in direct conflict with those
elsewhere. For instance, the widespread introduction of biomass
burners may help deliver renewable energy targets but, if they
are not designed to the highest air quality emission standards
or are poorly operated, they could have an adverse impact on air
quality.
6. STEPS TO
ENSURE AIR
QUALITY TARGETS
WILL BE
MET
6.1 Local authorities do not have the powers
to ensure that actions identified in their Air Quality Action
Plans are implemented. In some areas we are aware that actions
which were identified for other parties up to 10 years ago have
still not been delivered.
6.2 If air quality targets are to be met,
we believe the Government and devolved administrations should
implement as quickly as possible the measures identified as cost
beneficial in the UK AQS, published in July 2007. The `exposure
reduction' concept for particulates (by which general levels,
including background, are reduced instead of focussing on hotspots)
should be put into practice as soon as is practicable. This provides
the greatest benefit to the population as a whole by reducing
their exposure to fine particles.
6.3 Transport planning policies alone will
not be sufficient to address the problem of vehicle pollution
in urban areas. Additional measures such as higher vehicle standards,
work on hybrid vehicles and the enforcement of vehicle emission
regulations are all needed The effect on air quality of the scrappage
schemes for the most polluting vehicles needs further investigation.
Measures to regulate traffic along the worst polluted routes using
established traffic management techniques, and the establishment
of low emission zones, may also be appropriate.
6.4 We believe that DfT's recent Sustainable
Development Framework for Transport Planning needs to give more
weight to air quality in its matrix of `challenges' since air
quality is currently not given sufficient consideration. We believe
a `challenge' that specifically relates to the human health effects
of traffic-related air pollution should be included under the
goal of "Improve quality of life". The goal to "contribute
to better safety, security and health" does have the `challenge'
of "reducing the social and economic costs of transport to
public health, including air quality impacts" but we do not
consider this to be sufficiently strong to achieve the necessary
outcome.
6.5 Where people live, work, shop and undertake
leisure activities, and how they get there, has a crucial influence
on air quality. Decisions on such matters may be taken at local,
regional or national level with major projects now coming under
the aegis of the Infrastructure Planning Commission. With few
exceptions, air quality is not usually seen as a key issue when
such decisions are taken. Any proposed major infrastructure development
should be subjected to a detailed air quality impact assessment.
6.6 We are a statutory or recommended consultee
on individual development proposals and strategic environmental
assessments of local and regional spatial and transport plans.
If air quality is to be safeguarded, planners working at both
a regional and local level should use whatever opportunities arise
to reduce the effects of poor air quality. Planning policies have
a fundamental effect on the generation and dispersion of air pollution
and the exposure of local populations to poor air quality. The
Environment Agency has proposed a number of key, high-level air
quality objectives for Regional Planning Bodies and Local Authorities
that we would like to see implemented. These are that transport
and spatial planning:
— should aim to achieve improvements in
local air quality and public health;
— should seek to minimise the adverse air
quality impact of all new transport schemes and developments,
particularly where there may be cumulative impacts from multiple
developments;
— should pursue the sustainability appraisals
for regional spatial strategies, local development documents and
the strategic environmental assessments for local transport plans
contain an appropriate assessment for air quality; and
— should ensure that all proposed developments
which could adversely affect air quality have received an appropriate
assessment of air quality effects and a health impact assessment.
6.7 In addition the Environment Agency believes
that:
— all local planning documents should include
policies which address air quality if relevant;
— the guidance developed by Environmental
Protection UK on "Development Control—Planning for
Air Quality" should be used in the planning process;
— the techniques described in the "London
Best Practice Guidance: The control of dust and emissions from
construction and demolition" should be a condition of development
where relevant;
— planning policies in local development
frameworks and supplementary planning documents should require
travel plans for major developments and use the DfT guidance on
this matter; and
— Low Emission Strategies should be used
to ensure new developments are designed with the lowest environmental
impact possible.
6.8 The impact of ammonia emissions on natural
habitats is an issue of concern. Currently 60% of sensitive habitats
exceed the critical load for nutrient nitrogen (Review of Transboundary
Air Pollution, Draft Report ) and ammonia is a major source of
this nutrient. Agricultural activities are the principal source
of this pollutant but only a small fraction of national ammonia
emissions comes under current regulatory control. The Environment
Agency agrees with the need for a national ammonia reduction strategy,
as proposed in the UK's AQS 2007, but we are concerned that there
are still no definite proposals.
6.9 The Local Air Quality Management regime
should include objectives for the protection of vegetation.
7. OTHER MATTERS
7.1 The Department for Transport consulted
on the proposals to expand Heathrow Airport. The Environment Agency
concluded that the evidence presented was not sufficiently robust
to be sure that the proposed development will not lead to a breach
in the long-term EU air quality limit value for nitrogen dioxide.
However the decision has been made to go ahead with expansion
on the basis that additional flights would only be allowed if
air quality limit values had already been complied with.
7.2 The Secretary of State for Transport
proposed that the Environment Agency should have a role in assessing
and monitoring air quality around the airport to ensure, along
with other partners, that the air quality limit values will be
met. The exact form of the Environment Agency's role is still
under discussion with government but is likely to fall into three
main areas:
— Coordination of air quality monitoring
and modelling to assess compliance with air quality limits;
— Auditing of studies to assess the extent
to which future capacity can be released; and
— Action in the event that limit values
are, or are likely to be, breached.
7.3 We have developed consistent and auditable
techniques for the assessment of impacts from major sources and
believe that there is scope to apply similar approaches to air
quality impact assessments undertaken for major developments such
as airports.
16 December 2009
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