Memorandum submitted by the Air Quality Management Resource Centre, University of the West of England, Bristol (AQ07)


This letter constitutes a response to the Environmental Audit Committee's call for evidence on air quality. The key points made in our response can be summarised as follows:

Over the last decade, the UK's Local Air Quality Management regime has identified a very large number of air pollution 'hotspots' that were unforeseen. In this regard the Review and Assessment part of the LAQM process can be considered as a major policy success.

The LAQM process has not been as successful at controlling or mitigating air pollution problems as it has been at identifying them. A number of key reasons lie behind this. They include a lack of political priority and other drivers for action at a local authority level, a tendency for policies at a national level to focus on technical measures and not adequately support potential measures at a local level, and a continuing growth in road traffic on urban networks that are unable to cope with the traffic flows (both in terms of congestion and having characteristics that prevent the dispersion of the consequent pollution).

Air quality has not been effectively integrated within policies concerning transport, spatial planning or health at either local or national levels and this has led to it failing to be given due regard in these areas

About the Air Quality Management Resource Centre at UWE, Bristol

1. The AQMRC is based at the University of the West of England, Bristol and was formed in 1998. Since 1999, it has (in partnership with Air Quality Consultants Ltd.) held a contract with Defra (and formerly with DETR) for undertaking management tasks in relation to the Local Air Quality Management process. These tasks include:

the appraisal of local authority Review and Assessment reports

the management of archives of reports and Air Quality Management Area orders,

the maintenance of databases to record and track these documents and other elements and indicators of progress within the LAQM system

the operation of a telephone, email and internet based helpdesk service to help local authorities with their work, and

support in the writing and updating of official guidance for Defra and the Devolved Administrations.

2. In addition to the LAQM contract with Defra and the Devolved Administrations, AQMRC has also carried out a wide-range of other LAQM work for UK local authorities. This has included carrying out and providing assistance for review and assessment work and air quality action planning, support and facilitation for consultation and engagement exercises with the public and other key stakeholders, and training provision to enhance capability and capacity, specifically for LAQM but also in related areas of air pollution, climate change, and land-use and transport planning. AQMRC has a significant research background based on air quality management funded by prestigious research organisations including ESRC, NERC and EPSRC. This has generated an extensive peer reviewed publications list, and has allowed the development of a renowned track record in supervising and examining PhD students in the field of LAQM. AQMRC was also instrumental in the design and development of the Institute of Air Quality Management in order to promote and support the increasing number of professionals working in this field.

3. AQMRC are internationally recognised for their leadership in the field and have been involved in a number of major international projects. The group has also had significant involvement in the promotion of the UK LAQM Framework as good practice in a range of contexts, including the EU Framework V INTEGAIRE (Integration of Environmental Governance and Air Quality in Europe) project, the provision of support for the development of air quality capacity in Bangkok Metropolitan Administration, and in the development of the South African National Framework on Air Quality (which used the UK system as a basic model).

4. The AQMRC is a part of the Institute for Sustainability, Health and Environment (ISHE). This is an Institute comprising a wide-range of research groups covering key areas of research into: sustainable communities and the built environment; public health and well-being; and environmental sustainability.

Responses to the specific issues raised:

5. The following sections provide specific responses to the issues raised in the call for evidence.

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

6. The answer to this depends upon the spatial scale of analysis that is used or required. National monitoring networks and modeling efforts provide an adequate basis for determining the general spatial and temporal variation in air pollution across the UK. The adequacy declines when shorter timescales or smaller spatial scales of analysis are required. Thus this question fails to distinguish between monitoring and modelling carried out by national and local government. Through the LAQM system, which requires (where appropriate) modelling and monitoring to be carried out by Local Authorities, there is a strong case for arguing that the Government has established a system whereby LAs are its 'eyes and ears' on the ground with regard to air quality - a fact that has allowed the Government to identify well over 500 individual air quality hotspots in the UK - many of which would be invisible to them were they to rely solely on the national monitoring and modelling programmes.

7. National modelling is unable to recognise and account for the major influence on air quality of local congestion and street scale topography (e.g. street canyons, bus stops, minor junctions, pedestrian crossings etc). These very local circumstances now constitute the majority of problems identified and declared as AQMAs by the LAQM process.

8. Automatic monitoring as carried out in the AURN tends mainly to be focused on urban centre/background sites rather than roadside sites where AQ problems are worst (although this is now changing due to EU regulations). Even where monitoring is at roadsides, it is rare that automatic monitors can actually be sited in the narrow streets that are the worst hotspots (see above). The fact that the national monitoring network has not picked up these areas has allowed the national modelling to also overlook them.

9. National modelling itself only covers major roads (predominantly trunk roads) and these tend not to be the ones where the problems caused by congestion and canyon effects occur.

10. The LAQM process can be split into two clear sections - Review and Assessment and Action Planning. The Review and Assessment part of the process can be considered to be a significant achievement. When the LAQM regime was established in 1997, it was thought that there would only be the need for the declaration of a handful of Air Quality Management Areas, and yet 10 years later, despite a vastly cleaner transport fleet, 60% of Local Authorities have now had to declare AQMAs. Although some information from this process is used to address the EU-orientated work (such as the reporting to Defra of Local Authority operated automatic monitoring sites that exceed the Limit Values), there is little sign that national policies are significantly responsive to the, now widespread, problems at the LA level.

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

11. Within Defra, and in the Department of Health (e.g. COMEAP) there is a significant understanding of the risks of poor air quality. However there is little evidence that that this appreciation is shared by the departments that are more closely related to the control of many air pollution sources (e.g. DfT, DECC, BERR).

12. Government reports have identified the health impacts of air quality in the UK as being almost twice those of physical inactivity (20 billion compared to 10.7 billion - Defra Air Quality Strategy 2007, Chief Medical Officers Report 2004) yet it fails to receive quite the same level of attention as the latter within medical and media circles. Similarly, some studies have suggested that the cardiovascular risk of exposure to traffic pollution "may well be similar to that played by passive smoking" (COMEAP 2006), however at the level of national action there seems to be little evidence of comparative attention being given to the issue.

13. There seems to be a lack of clarity regarding how the Government communicates the health risks of air pollution on individuals, both in terms of differing levels of personal exposure to pollutants and to how susceptible people are to the effects of pollution. For example, the 7-8 month average shortening of life cited in the Air Quality Strategy is probably an over-estimate for the majority of people, but a very significant under-estimate for the most sensitive individuals. Without making health information meaningful to people, it is not likely that air pollution will raise high enough on local political agendas for effective action to be prioritised by local authorities.

14. There has been very little linkage made between air quality and other policy areas covering health and environmental risks - the causes and effects of air pollution are still dealt with in different departments DfT, DCLG, DoH. The consequent lack of joined-up policy fails to emphasise the multiple wins that would be achieved by much greater coordination of policies. One example would be the promotion of cycling and walking. This can help relieve congestion, reduce emissions of 'conventional' air pollutants, and see a significant increase in average levels of physical activity (thus both reducing the incidence of heart disease, and increasing resilience of individuals to the impacts of air pollution). In addition to this it would also help reduce climate change related emissions. If we turn this round and look at what bio-fuel policies have achieved, they may have failed even to reduce the climate impacts that they were introduced to mitigate, but they also failed to address any of the other negative impacts of transport (there is some evidence to suggest that they may be slightly less harmful in terms of 'conventional' air pollution emissions but this is not well established).

15. There has been a failure to provide suitable information to relevant stakeholders on the health effects of air pollution. Like it or not, the main statistic that the public and media are interested in is "How many people die every year from air pollution?". The only authoritative figure that has been produced for this is from the 1998 COMEAP report (The quantification of the effects of air pollution on health in the United Kingdom) that cited 24,000 premature deaths for 1995/6. At the time there was some concern that this might be an over-estimate, yet by 2007 it was still the only figure that the Royal Commission for Environmental Pollution could cite in its report on the Urban Environment. In addition to an initial perception that this might have been too high, there is often an assumption made that, over time, this figure is likely to have reduced. Contrary to this though, the science on the impacts of air pollution on health has advanced and based on the latest evidence (as summarised in work such as COMEAP's 2009 study "Long-term effects of Air Pollution on Health") groups ranging between Clean Air For London (see their submission to the EAC for further details) and the European Environment Agency currently suggest that this figure should be somewhere between 30,000 and 50,000.

The extent to which the delivery chain for air quality is coherent, integrated, coordinated and effective and whether the bodies with responsibility for managing air quality have appropriate incentives, understand their role and responsibilities, and are adequately resourced;

16. With regard to nitrogen dioxide, the Government is now at risk of failing to meet the EU Limit Value in 2010, but a decade ago the Government established its own domestic "Air Quality Objective" for this pollutant setting an achievement date of 31st December 2005, confident that it would be able to meet it. By the end of 2005 it was clear that a significant number of Local Authorities were not meeting this objective. However, there is little evidence that the clear and widespread failure to meet the objective at this time resulted in a significant 'ramping up' of action at the national level. There has therefore been nearly 5 years' notice that the expected improvements in UK air quality have not materialised at the rate anticipated and the failure to meet the EU Limit Values is in no way a sudden surprise.

17. The revision of the Air Quality Strategy in 2007 provided a suitable time to tackle this, however the final document has been widely criticised for downplaying behavioural change measures and placing too strong a reliance upon technical interventions (and even then not being prepared to push forward action in many circumstances where benefits out-weighed costs). In the light of the widespread failure to meet the 2005 NO2 objective, one of the most significant parts of the AQS revision can be seen to be the clear statement that the UK air quality objectives had no legally binding status and were merely "statements of policy intent".

18. AQ policy seems to have been forced down two separate roads in the UK with little alignment or co-ordination between them. These are:

Nationally based technical end-of-pipe fixes which, at best, are only able to produce increasingly small incremental improvements post Euro 3/III, and in practice often appear not to work as expected or hoped and, in any event, air quality gains from these measures being quickly eroded by growth in traffic,

Local action planning, which has to exist within the national context of more and more traffic entering the road network and individual vehicles travelling further each year, and struggle against a low profile for air quality at both national and local levels, with few obvious political champions for clean air.

19. The most that many LAs can do is to re-route traffic from current hotspots but this has the potential risk of creating new problems elsewhere. Although in LTP2 AQ was a "shared priority", research we have undertaken reveals that air quality was rarely an equal one and was often seen by LAs as the least important area of the stated priorities.

20. There is little support from national government in raising AQ's profile at a local level - whilst it is a statutory obligation at the moment this is often the only thing that means it is kept on councils' agendas - and the statutory obligations are focused far more on assessing air quality than on bringing about improvements. More work on supporting local activities would go a long way - but there is little evidence that the national policy response offers any ideas other than technical measures. Air quality needs to be more closely integrated with transport planning at local and national levels, and a strong policy and implementation emphasis given to introducing healthy urban planning. The current planning system still deals with development in a piecemeal way. It is unable to deal with the differences in timescale that exist between the renewal of urban infrastructure and the growth in traffic - leaving our urban centres choked by levels of traffic that they were never designed for. It is also unable to adequately cope with the cumulative impacts of new developments.

21. One of the other missing links in the delivery chain is the role of regional government. In most regions over half the LAs have now declared AQMAs. Despite this, regional government offices have been given no clear tasks or roles in trying to help relieve the problem - 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 SEAs for RSSs and LDFs - LA officers seem to be tasked with dealing with assessing the major housing provision on a development-by-development level which is unable to cope with the likely cumulative impacts of 1000s of new houses.

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

22. There has been recent discussion that the costs for failure to meet the EU Limit Values will be borne (directly or indirectly) at a LA level. This may be an entirely inappropriate action as LAs will claim that the support and policy steer that they have been given have always made it clear that responsibility for achieving EU Limit Values rests with central government not themselves. The strongest direction given was in phrases such as "responsibility to work towards meeting the objectives". Following the clear failure of a large number of authorities to meet the 2005 NO2 objective, at the point where stronger central direction would be most appropriate, the government chose to clarify the situation by stating that there was no expectation for either LAs or the Secretary of State to meet the objectives, and confirming that the objectives were merely "statements of policy intent". The time to threaten LAs with financial costs of not meeting the objectives would have been a decade ago, at which point it may well potentially have been a significant driver for action. However, over the last ten years there has been limited incentive for LAs to place air quality high on their political agendas. As a consequence local actions have been limited in concept, scope, implementation and have had limited effect.

23. Local action backed up by direct support from central government remains a basic requirement particularly in terms of an integrated offering in air quality, transport and land-use planning policies.


10 December 2009