Memorandum submitted by Environmental Protection UK (AQ05)


Summary of Our Views


National-level monitoring and modelling has generally been successful, but does not pick up many local air quality hotspots caused by issues such as street canyons, bus stops, minor junctions, pedestrian crossings, etc. These local hotspots are the source of significant public exposure to polluted air.


The health and other environmental risks associated with poor air quality have been identified by bodies such as the Committee on the Medical Effects of Air Pollution (COMEAP). However, many Government reports and strategies currently rely on outdated recommendations for premature death and monetised health impacts. Outside of parts of Defra and the Department of Health the health effects of air pollution, and indeed the fact that air pollution is still a problem at all, seems to be only dimly understood by government.


The delivery chain for air quality is fragmented. Responsibility for meeting air quality objectives lies with Defra, however delivery largely rests with other government departments and bodies such as the Highways Agency, who often do not dedicate adequate resources to the problem. At a local level, local authorities often lack the national enabling actions and political will to act decisively on air quality.


Effective delivery will need the delivery system to be re-examined, and national enabling actions to be taken alongside stronger obligations at regional and local levels. Greater resources need to be provided at all levels. Tight integration on air quality and climate change policy is currently lacking-improving this situation will reduce the costs of achieving air quality and climate change targets as well as reducing the risk of unintentional policy trade-offs, as we have seen with promotion of diesel vehicles.


Detailed Comments


We have detailed our comments below in each of the four areas requested by the Committee:


The monitoring and modelling systems used by the Government and whether these provide an adequate measure of air quality


1. Two separate levels of monitoring/modelling are used in the UK:


National-level monitoring/modelling organised by Defra, which includes the Automated Urban and Rural Network (AURN). National-level monitoring and modelling is used to monitor compliance with EU Air Quality Limit Values and the UK Air Quality Standards;

Local monitoring/modelling carried out by local authorities in support of their responsibilities under the Local Air Quality Management regime.


It is important to note that whilst both levels of monitoring/modelling may use valid techniques, they may not necessarily produce the same results. Indeed, as the Committee's questions suggest, monitoring and modelling will always provide only an approximate indication of public exposure to air pollution.

1. The nationwide system of monitoring, that includes the Automated Urban and Rural Network (AURN), has been implemented successfully and has achieved international acclaim. However, it is important to note that the approach taken by the UK to comply with European monitoring requirements uses relatively few monitoring sites, with the gaps filled in by modelling. Automatic monitoring, as carried out in the AURN, also tends mostly to be urban centre/background sites, rather than the roadside sites where air quality problems are worst. Even where monitoring is at roadside, it is rare that automatic monitors can fit in the narrow streets that are the worst hotspots (see paragraph 3).


2. The 'gaps' in the widely dispersed national monitoring system are filled by air quality modelling. The national-level modelling has been carried out to a high standard using the best available techniques, however it is important to note the limitations of the modelling process at a national level. Modelling is only as good as the input data provided, and the models themselves may also have limitations, for example gas-based models are often used to model particulate (PM10) concentrations. National modelling also fails to recognise the major influence of local congestion and street-scale topography (e.g. street canyons, bus stops, minor junctions, pedestrian crossings, etc) on air quality.


3. These local factors are now very likely to constitute the majority of problems identified and declared as Air Quality Management Areas (AQMAs) under the Local Air Quality Management (LAQM) process. The fact that national-level monitoring has not picked up these areas has allowed national modelling to also overlook them, meaning that these problem areas are not included in terms of reporting against the national Air Quality Standards. This effectively devolves action on these poor air quality hotspots to local authorities alone, which have neither the binding legal commitment nor in many cases the effective tools to take meaningful action and resolve the problem(s).



The extent to which the Government fully understands and has identified the health and environmental risks caused by poor air quality

4. The health and other environmental risks associated with poor air quality have been clearly identified by bodies such as the Committee on the Medical Effects of Air Pollution (COMEAP), and these have been acknowledged in those parts of Defra and the Department of Health/Health Protection Agency with responsibilities for these matters.


5. However, COMEAP's latest recommendations for quantifying the health impacts of particulate matter are currently failing to find their way through into official estimates of premature deaths and monetised health impacts. The current (2007) Air Quality Strategy used a premature death co-efficient for PM10 from COMEAP's 1998 quantification report (a far lower figure than that recommended in their latest 2009 report). The health impact quantification methodology used in the 2007 Air Quality Strategy has been used in several subsequent reports, for example the recent Cabinet Office report 'The Wider Costs of Transport in English Urban Areas in 2009', which means that health impacts continue to be widely underestimated. The Campaign for Clean Air in London provided a detailed explanation of these issues in a letter to Mayor Johnson dated 20th September 2009[1].


6. Although bodies such as COMEAP have done much good work, there are still many questions that remain to be answered. For example, there appears to be a lack of clarity regarding how air pollution affects individuals, both in terms of differing levels of personal exposure to pollutants and regarding how susceptible different people are to the effects of pollution. Average figures, for example the 7-8 month average shortening of life cited in the UK Air Quality Strategy, can be of limited use for determining health impacts.


7. The evidence base for the health effects of air pollution is often not thoroughly communicated amongst government and the general public. The health impacts of air quality in the UK are estimated at almost twice those of physical inactivity (Defra Air Quality Strategy 2007, Chief Medical Officer's Report 2004), yet it fails to receive quite the level of attention of the latter. Similarly, some studies have suggested that the cardio vascular risk of exposure to traffic pollution "may well be similar to that played by passive smoking" (COMEAP 2006)-the comparative level of national action, however, seems to be very different.


8. Outside of Defra and the Department of Health it is questionable whether these risks are fully understood. There has been very little linkage made between air quality and other policy areas of health and environmental risks-the causes and effects of air pollution are still dealt with in different departments, for example DfT, DCLG, DoH. The consequent lack of joined up policy fails to emphasise the multiple wins that would be achieved by co-ordinated policies. For example the promotion of cycling and walking can help relieve congestion, reduce conventional (air quality) emissions, and see a significant increase in average levels of physical activity thus reducing the incidence of heart disease and increasing resilience to the impacts of air pollution. In addition to this, it would help reduce climate change related emissions.



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

9. The delivery chain for improving air quality is, at best, fragmented. At a national level, Defra and the DoH/HPA have at least some understanding although this may not spread across the whole department. On the other hand there are other government departments, DfT, CLG, DECC and the Treasury for example, where there appears to be at best very limited awareness of air quality issues and, often, a total lack of understanding that air quality is still a major problem in terms of its health and wider environmental impacts. It is imperative that these departments are involved in the air quality management process as each has an important role to play. DfT must be more closely engaged as traffic, and in particular road traffic, is the main cause of air quality problems in much of the UK. CLG has a major role in the planning process in particular and in local government in general. The Treasury has an essential role in providing funding.


10. Harmonisation of air quality and climate change policy is key, as both policy areas are largely aiming to address the same combustion processes. Coordinated policy can lead to lower overall costs, whilst un-coordinated policy can cause unintentional trade-offs. The current departmental split between air quality (Defra) and climate change (DECC) is therefore unfortunate, and there is currently little evidence of the assurances that policy would be 'joined up' given at the time that DECC was created. Win-win measures between climate change and the natural environment (including air quality) are not being identified and fast tracked, whilst the potential negative effects of climate measures are not being fully identified before implementation. Time consuming and expensive policy amendments are often later needed; examples of this include sustainability considerations with liquid biofuels, and the air quality impacts of biomass combustion.


11. Government agencies also have a key role to play, in particular the industrial regulators (the Environment Agency, SEPA and NIEA in England and Wales, Scotland and Northern Ireland respectively) and the Highways Agency. The industrial regulators have a legal duty to address the problem where a regulated installation is causing a breach of an air quality limit value. By contrast the Highways Agency are simply obliged to, in effect, 'not make air quality worse', and as a result AQMAs brought about by roads managed by the HA often go unaddressed, which is a major area of frustration for local authorities.


12. We have previously mentioned the disconnect between national- and local-level monitoring (see paragraph 4). A similar situation exists with delivery-national Government (Defra) is the legally obligated party, and local authorities are only required to 'work towards' achieving the Air Quality Standards, which can restrain the political will needed to tackle the problem at a local level. This problem is especially acute in cities such as London, where the current mayor holds many of the powers needed to improve air quality yet fails to take ownership of the problem, as exemplified by the content of the recently released London Mayor's draft Air Quality Strategy.


13. Within local authorities themselves links need to be established and maintained between the air quality professionals, transport planners, climate change officers and development control planners. Although there are some local authorities where effective links exist, there are many where they do not. Outside of unitary authorities air quality is a district-level function, whilst transport rests with the county councils. However there does not appear to be any consistent relationship between the local authority structure and the existence of effective cross department links for air quality-there are good and bad examples under both unitary and multi-tier arrangements.


14. One of the other missing links in the delivery chain is the role of Regional Government; in most regions over half the local authorities will have declared AQMAs. Regional Government has been given no clear tasks or roles in trying to help relieve the problem, which is especially significant considering their role in regional transport programmes and spatial planning. There also seems to be a significant lack of air quality assessments for future developments coming through the channel of Strategic Environmental Assessments for Regional Spatial Strategies and Local Development Frameworks-this is extremely important as it is very difficult to deal with the air quality impacts of thousands of new homes when they are presented to air quality officers piecemeal at a development control level.


15. Much can be learnt from overseas examples of air quality management. For example in the Unites States clear roles and responsibilities under their Clean Air Act are assigned to the Environmental Protection Agency (federal level), and states, tribes, and other local agencies[2].



The steps that need to be taken to ensure that air quality targets will be met in the future

16. Policy measures tend to fall into two distinct groups. The first is nationally-based technical 'end-of-pipe' fixes for vehicle emissions, which previously seemed to offer the solution to the air quality issue. However, evidence from monitoring shows that, after a marked improvement in air quality during the 1990s following the initial introduction of catalytic converters, there has been little further improvement in spite of supposed improved vehicle technology. This is usually attributed to the fact that increases in the numbers of vehicles on the roads has swamped any benefits that may accrue from the technological improvements. This is not to undermine the importance of further improving vehicle emission standards, but is an acknowledgement that 'end of pipe' measures have suffered from diminishing returns, and cannot be solely relied upon to deliver compliance with air quality objectives.


17. The second group of measures are those concerning local action planning. These are delivered in the main by local authorities, and have to exist within the national context of more and more traffic being forced on to the roads. The most many local authorities can do is to re-route traffic from current hotspots, potentially at the risk of creating new ones. Although in Local Transport Plan 2 air quality was a 'shared priority', it was rarely an equal one. There seems to be little support from national government in raising the profile of air quality at a local level-whilst it is a statutory obligation, at the moment this is often the only reason it is kept on councils' agendas.


18. An effective way forward will need a tight balance between national and local measures. National measures tend to be broad brush and, assuming they are effective, will produce overall benefits. There are, however, many cases where air quality problems arise as a consequence of local problems which are not amenable to control by national measures. Defra has recognised this in the early drafts of its submission to the EU for an extension in meeting the Limit Value for nitrogen dioxide, by identifying areas where different types of traffic sources are responsible for air quality problems. Enabling actions taken at a national level will allow for a more tailored approach to be taken at a local level.


19. One example of where the national/local approach can be taken is with Low Emission Zones (LEZs)-designated areas where only vehicles meeting certain emission standards are allowed to enter. The main LEZ in the UK encompasses almost the entirety of Greater London, and at present applies to larger vehicles only, however there are simpler, cheaper more flexible way of implementing LEZs[3]. Whilst LEZs are an effective tool for addressing areas of poor air quality very few local authorities have implemented one. The main reason for this is the lack of a national framework for local LEZs to operate within, and the lack of a national testing and certification scheme for retrofit emissions abatement equipment (one exists for PM10, but not NOx). Without these, local authorities find it very difficult to establish a LEZ and, if they do, national vehicle operators may potentially have to comply with several different LEZs with different standards and criteria.


20. We have detailed the fragmented nature of the delivery system in paragraphs 10 to 12 above, and it is clear that delivery needs to be rethought, and obligations to act to improve air quality imposed on a number of key delivery bodies. One of these is the Highways Agency, who need a stronger obligation to actively improve air quality rather than simply 'not make air quality worse'. Local authorities also need a stronger obligation than simply 'working towards' the Air Quality Standards, as they are required to under the LAQM regime. We note that, at the time of writing, Defra is undertaking a review of the LAQM regime, and we look forward to seeing the outcomes.


21. At both national and local level, work on air quality is under resourced. There is an apparent lack of proportion in the allocation of funds for various initiatives. This can be best illustrated by comparing the funding for various road safety measures and that for air quality work, and the health impacts of road accidents and air quality. In the case of road safety there are numerous high profile campaigns, in particular the regular drink-driving campaigns, and many cases of extensive traffic management schemes, some of which may result in deterioration in local air quality. These measures are targeted at an annual UK death toll of approximately 3,000. In contrast poor air quality, which is believed to be responsible for at the very least 24,000 deaths advanced per year in the UK, only rarely attracts public attention.


22. It is generally accepted that in the medium- to long-term improvements in air quality will be secured via measures taken to tackle climate change, for example the greater use of electrically propelled vehicles would do a great deal to improve air quality. However, at the current time there is very little integration between air quality and climate change policy, with the result being some adverse effects from well intentioned measures. One specific example here has been action to lower vehicle CO2 emissions through tax measures and public information; this has encouraged diesel vehicles which normally emit lower amounts of carbon dioxide than petrol equivalents, but greater quantities of particles and nitrogen dioxide. The Government's vehicle labelling and 'Act on CO2' schemes both largely ignore air quality, despite their US equivalents including both a CO2 and air quality metric[4].


23. Both air quality and climate change policy need to be integrated with transport, policy and a strong push put forward towards introducing widespread notions of healthy urban planning. Infrastructure we build now will last 50 to 100 years, and over the last 50 years we have seen an 800% increase in road traffic. A long-term vision for transport is needed now-the alternative is that we micro-manage the ever-increasing amount of traffic on the roads, which will significantly hamper work to both improve air quality and reduce emissions of greenhouse gases.


9 December 2009


[1] See -

[2] This is explained at

[3] Many European examples are shown at