Memorandum submitted by the Mayor of London (AQ03)




The Mayor of London believes that progress is being made at all levels of government to reduce emissions, yet more needs to be done if limit values are to be met and the negative health impacts of poor air quality are to be minimised in London. The Mayor therefore makes the following recommendations:

The Government needs to take a clear strategic lead, setting out its vision, a delivery framework, national measures that will be taken and advise on regional and local measures.

The Government should use the time extension notification process for the NO2 limit values to set a framework for local and regional authorities to take action over the next few years.

Government departments need to work more closely together to develop strategies to improve air quality.

Funding for air quality measures should be available from health budgets as well as environment budgets.

The Government should publish an annual report setting out air quality data and updating the Government's approach and priorities.

Legislative processes and requirements should be streamlined in London so that the delivery chain is clearer.

Research is needed to explain the disparity between air quality modelling and monitored air quality.

The Government should publish clear information on the health impacts of poor air quality to inform decision makers.

A common methodology for assessing the benefits of potential measures at national, regional and local level should be developed.

Government-led research should focus on the needs of policy makers.



1. The Mayor of London welcomes the opportunity to provide a written submission to the Environmental Audit Committee. The Mayor, along with his Adviser on the Environment, Isabel Dedring, is committed to improving air quality in London to protect the health of its citizens.


2. The Mayor is required under the Greater London Act 1999 to prepare an Air Quality Strategy. This must contain the Mayor's policies and proposals for the implementation in Greater London of the Government's Air Quality Strategy for England, Scotland, Wales and Northern Ireland, as well as for achieving air quality standards and objectives prescribed in regulations under the Environment Act 1995.


3. Consultation recently ended with the London Assembly and functional bodies on a draft of a revised Mayor's Air Quality Strategy. The Mayor and GLA officials are now considering comments made during the consultation period and are discussing resource allocation and national measures with the Government. The Mayor will publish a further draft of the Strategy for consultation with the public early in 2010, and it is currently planned that the Strategy will be published by autumn 2010.


4. The Mayor also has a role in the Local Air Quality Management (LAQM) process in London. London boroughs are required to consult the Mayor when undertaking their LAQM functions. The Mayor must review air quality review and assessment methodologies, reports and action plans to ensure consistency with mayoral strategies. The Mayor also has reserve powers to require boroughs to conduct air quality reviews and assessments.


5. The Mayor can direct boroughs to take specified steps, for example where it appears that objectives are not likely to be achieved or when technical or material developments cause a borough's actions to be inappropriate. The Mayor can direct boroughs to declare (or modify) air quality management areas, to prepare action plans and to implement any measures in action plans. The Mayor is required to consult with boroughs before using his powers of direction and must take into account national guidance when using them. The Mayor is also able to carry out investigations and research on matters concerning air quality in London and to provide advice and information to the boroughs.


6. The Mayor is also responsible for strategic planning in the capital, carried out through:

the formulation a spatial development strategy for London (the London Plan); and

his role in decisions on major planning applications (applications of potential strategic importance).


7. The Mayor uses his powers in the planning process to promote sustainable development and improve air quality.


Modelling and Monitoring Systems


8. The Mayor appreciates the work of Defra in managing the Automatic Urban and Rural Network (AURN) for monitoring air quality in England. Eight of the 121 sites in the AURN are also part of the London Air Quality Network (LAQN) which is sponsored by the Mayor and the Environment Agency. The UK Air Quality Archive, which is funded by Defra and the devolved administrations is also a useful and well presented source of air quality information. However, the Mayor believes that an annual report produced by Defra on air quality trends would be a useful way to raise awareness of air quality issues.


9. The Mayor also recognises the important role of the National Atmospheric Emissions Inventory (NAEI) in modelling air quality in the UK. Although London has its own inventory, the London Atmospheric Emissions Inventory (LAEI), some of the supporting data in the NAEI is useful in the LAEI's development. Although the LAEI and the NAEI are developed using slightly different methodologies, largely due to the difference in geographic scale between the two inventories, GLA and Defra officials have worked to ensure consistency between them as far as possible, and the Mayor hopes that such co-operation will continue.


10. It is widely acknowledged, however, that in recent years, monitored emissions have not fallen to the extent that models predicted that they would. It is important to policy makers that the causes of this disparity are established, as modelling contributes greatly to the air quality policy development process. Officials from the GLA group would be willing to use their experience in London and the data that is available to them to work with Defra officials to investigate this issue further. However, the Mayor feels that in order to investigate this issue further, it is important that the AURN network is maintained, if not expanded, including the monitoring sites in London.


Health and Environment Risks


Health information


11. Over recent years, there has been emerging evidence about the health impacts of poor air quality. The Government's advisory body, the Committee on the Medical Effects of Air Pollutants (COMEAP) has been at the forefront of research into this issue, which has contributed greatly to policy development in London.


12. However, the Mayor feels that the Government could make better use of this research. It is extremely important that clear health information and messages are communicated to key audiences. Air quality issues are sometimes neglected by decision makers at all levels of Government, largely through a lack of knowledge and because the causes and impacts of other environmental challenges, especially climate change, are easier to understand. Clear guidance on the health impacts of poor air quality would enable officials at all levels of government to raise awareness and understanding of air quality issues among senior managers and thus improve the decision-making process. Such information, if effectively communicated, could also persuade individuals to make the small changes in behaviour that collectively are important in improving air quality in urban areas.


13. It is sometimes argued that the failure to communicate clearly the health impacts of poor air quality has resulted in air quality proposals being rejected by policy makers. It is striking that the Government's Air Quality Strategy for England, Scotland, Wales and Northern Ireland concluded in 2007 that few national measures had positive net benefits. Further analysis making use of the recently updated COMEAP guidance, which significantly increases the assessment of the negative health impacts of poor air quality, would be informative.


14. There is a need for advice from the Government on a methodology for assessing the net benefits of potential measures which could be applied at both national and regional level, and which takes into account wider costs and benefits - such as CO2 emissions - rather than focussing narrowly on air quality impacts. GLA officials have experience of implementing assessment techniques for air quality measures, such as the London Low Emission Zone and Taxi Emissions Strategy, and would be willing to work with the Government to develop a practical methodology.


Technical information


15. The Mayor also recognises the high-quality work carried out in recent years by the Air Quality Expert Group (AQEG). However, AQEG-led studies tend to be complex and take a long time to complete. This research is valuable but given the urgent need to take action to meet European Union limit values, policy makers need quick answers to technical issues that arise - for example, the relationship between NOx and NO2, the impacts of new technology and fuels and analysis of tyre and brake wear emissions. It would be helpful if AQEG could also undertake short, focussed pieces of research responding to the needs of those implementing policies on the ground.


16. For these reasons, the Mayor generally supports the conclusions of the Defra-commissioned review of AQEG that was carried out by Enviros and published in December 2008. In particular, the GLA believes that AQEG could be made more effective by:

being more flexible to undertake more short-term research projects;

focussing its efforts on research that will have direct relevance to policy implementation; and

increasing interaction with policy implementers both at project inception stage and during the research phase.


Delivery Chain


17. The Mayor appreciates the efforts that have been made by Defra to engage on policy development in London. Improving air quality in London is a shared responsibility between the Mayor and the Secretary of State, and the development of policies that complement each other and the adequate resourcing of measures will be vital if limit values are to be achieved.


18. However, despite this engagement on particular measures in London, there is a lack of clarity as to the Government's policy priorities or overall strategy. The Mayor considers that the Government needs to set out a strategy that:

describes a clear vision for air quality in the UK;

sets the framework for delivering air quality improvements across the country;

explains broad actions that the Government will take to meet limit values; and

proposes policy areas that local and regional authorities should focus on.


19. The Government published its Air Quality Strategy for England, Scotland, Wales and Northern Ireland in 2007. It could be argued that this document describes a vision for air quality in the UK, in the form of compliance with EU limit values and national objectives, though perhaps the vision should focus more on the health impacts of poor air quality. Even here, however, the picture is confused. In some cases, the EU limit values and national objectives are subtly different, which means that local and regional authorities are unsure exactly what targets take priority.


20. There is a case for making the EU limit values the only legal objectives, though a narrow focus on limit values and targets alone could be detrimental to achieving the deeper cuts in emissions that are so important for health reasons. Even in areas that are already meeting PM10 limit values, it is desirable to reduce concentrations further. Without a strong lead from the Government, there is little reason why local authorities should take any action to reduce these concentrations once legal compliance has been achieved. This underlines the need for the Government to state unequivocally the health case for improving air quality.


21. To an extent, the Government's Air Quality Strategy sets a framework for delivering air quality improvements, largely through the Local Air Quality Management (LAQM) process. The GLA has contributed to the current review of the LAQM process which is being undertaken by the Government, and awaits its outcomes with interest. Overall, the Mayor supports the current LAQM system, which provides an impetus to local authorities to take action to improve air quality and which ensures that the monitoring information which is integral to evidence-based policy development is properly collated. Nevertheless, the bureaucratic process could be greatly streamlined and there is also a need for the chain of responsibility in London in particular to be clarified (see below).


22. Perhaps the main problem with the Government's Strategy is that it fails to set out the broad policy areas that it will focus on at a national level. The only three new measures that the Government committed itself to considering further in the Strategy were:

incentivising the early uptake of new tighter European vehicle emissions standards;

Iicreased uptake of low-emission vehicles; and

reducing emissions from ships.


23. The Mayor considers that there are other measures that could be more cost-effective if implemented nationally rather than piecemeal by individual authorities and which merit further consideration by the Government. These include:

tax incentives for cleaner vehicles;

a national framework for low-emission zones;

a certification scheme for NOx abatement equipment;

extended and targeted vehicle-scrappage schemes;

grants schemes for retrofitting vehicles;

development and promotion of new technologies;

restructure of energy-efficiency schemes; and

awareness campaigns.


24. As mentioned above, a number of national measures were rejected by the Government because they did not result in positive net benefits in the analysis process. However, if local authorities had confidence that the Government would implement certain national measures, they might be more willing to put in place complementary local measures, which would improve the effectiveness of both the national and the local measures. However, without such a clear steer from the Government, anecdotal evidence suggests that local authorities are unwilling to take the plunge by developing innovative new policies.


25. Similarly, the Government has failed to provide enough guidance about the types of measures that it believes should be implemented at a local level. While local authorities are best placed to respond to local needs, high-level advice and guidance from the Government would reduce the effort that local authorities would have to put into the initial policy scoping process. Government endorsement of policies would also be likely to persuade decision-makers at local level to support particular actions, especially if this was backed up by an indication of funding support from government for these actions.


26. The Mayor considers that there is sometimes a lack of consistency between different government departments. It makes sense for one department - Defra - to take the lead on improving air quality. However, Defra does not always seem to be able to persuade the Department for Transport of the merit of transport policies that will improve air quality, or the Department of Health of the benefits to public health that would result from air quality improvement policies. In addition, the removal of climate change policies from Defra that occurred after the creation of the Department of Energy and Climate Change (DECC) makes it more difficult to maximise the air quality benefits of measures to reduce carbon dioxide emissions or to minimise any negative impacts.


27. There is an urgent need for departments to work more closely on packages of policies and to ensure that messages given to stakeholders - including local authorities - are consistent. Given the health benefits that would result from better air quality, it could also be argued that funding for air quality measures should be made available from government health budgets, as well as environment budgets.


Steps Needed to Change


28. Given the need for action in the short term to meet EU limit values, the Mayor does not consider that a full revision of the Government's Air Quality Strategy for England, Scotland, Wales and Northern Ireland would be an effective use of time and resources. Nevertheless, there is a need for the Government to articulate what action it will take to improve air quality and to indicate what policy areas it advises local authorities to address.


29. An early opportunity to do this would be through the NO2 Action Plan that the Government will be developing in 2010 as part of its time extension notification to the European Commission for the NO2 limit values. This Action Plan needs to cover actions at national, regional and local level, so the Government should work closely with local and regional authorities in its development. The NO2 time extension application process should not just be about persuading the European Commission that action is being taken. It provides the Government with an opportunity to set out a framework for delivery and to help regional and local authorities implement measures that will be effective in improving air quality (not just NO2) over the next few years.


30. The Government needs to put in place procedures to ensure that the Action Plan is implemented. The LAQM process is effective in allowing the Government (and in London, the Mayor) to provide direct advice to local authorities on particular issues. There is still, though, a need for the Government to communicate on an ongoing basis its priorities and policy direction. The Government should therefore consider how this could be best achieved and how to include all relevant government departments within this process. One option would be for the Government to produce an annual National Air Quality Review. This could include up-to-date data about air quality and related health impacts in the UK, summarise how the Government intends to address any emerging challenges and provide advice and best practice for local authorities.


31. The Mayor hopes that the current co-operation between the GLA and the Government will lead to the joint action that is needed to improve air quality in London. Nevertheless, the legislative framework which sets the delivery framework in London could be improved. Under the GLA Act, the Mayor is required to produce an Air Quality Strategy that contains "policies and proposals - for the achievement in Greater London of the air quality standards and objectives prescribed in regulations made under [the Environment Act]." The Mayor considers that it is right that there should be requirements on him to take action to improve air quality and that legal objectives (ideally EU limit values) should be a prime consideration.


32. However, emissions from outside London account for around 40 per cent of PM10 concentrations in central London and 25 per cent of NO2 concentrations across London. In addition, the Mayor has limited scope to influence the vehicle fleet using London's roads. The Mayor, on his own, cannot take action that will ensure compliance with the limit values. There is thus a clear role for central government to improve air quality in London.


33. The Mayor believes that consideration should be given to expressing the Mayor's legal air quality obligations in terms of emissions reductions objectives rather than concentrations objectives. This would allow the Mayor to focus on measures which are fully within his control. The Mayor accepts that there would be practical difficulties in agreeing suitable emissions objectives and in determining methodologies and metrics for monitoring progress. Consideration would also have to be given to funding issues, to ensure that the Mayor has the resources to implement the necessary measures. In addition, it would be important that measures to reduce exposure (and consequently reduce the health impacts of poor air quality) are not neglected in favour of emissions-reduction measures.


34. Consideration should also be given to similar legal emission reduction objectives for local authorities, including boroughs. At the moment, local authorities are required only to work towards meeting air quality objectives. A requirement to achieve emissions reduction targets would provide a focus for local authorities and ensure that air quality is taken seriously at all levels of management within authorities.


35. As described above, the Mayor is a statutory consultee for LAQM documents produced by London boroughs. This is an important means by which the GLA can monitor action taken by boroughs, ensure borough measures are consistent with the Mayor's Air Quality Strategy and spread best practice. However, the Secretary of State is also a statutory consultee for boroughs' LAQM documents. While the GLA and Defra liaise to ensure that responses to their LAQM documents are consistent, there is always the possibility that mixed messages could be received by boroughs.


36. The Mayor therefore feels that he alone should be responsible for appraising boroughs' LAQM documents, and that he alone should have power of direction over the boroughs, while acknowledging the need for the Secretary of State to have power of direction over the Mayor and for him to have legal objectives (as discussed above). This would simplify the delivery chain in London.


11 December 2009