Memorandum submitted by the Chartered Institution of Water and Environmental Management (AQ11)




The Chartered Institution of Water and Environmental Management (CIWEM) is the leading professional body for the people who plan, protect and care for the environment and its resources, providing educational opportunities, independent information to the public and advice to government. Members in 98 countries include scientists, engineers, ecologists and students. This response has been prepared by CIWEM's Air Panel which comprises academics and practitioners working in the air quality field.


1. Summary


1.1 The UK has a long history of managing air quality going back to when coal was first used as a fuel. Since the Clean Air Act of 1956 the winter smogs[1] caused by burning coal gradually disappeared, such that by the late 1970s this type of smog was a thing of the past. Since then the dominant source of poor air quality has been, in most areas, traffic emissions. Emissions from motor vehicles have been controlled for nearly 40 years, yet we fall short of ambient air quality objectives, continue to exceed EU limit values, and pay no regard to the WHO guidelines set for the protection of human health. People continue to be adversely affected by poor air quality.


1.2 UK air quality policy relies on computer modelling that does not properly account for congested traffic. This modelling has consistently forecast improvements since the early 1990s, yet the reality in many locations has been that air quality over the last decade or so has remained the same or deteriorated.


1.3 Local Air Quality Management (LAQM) has been implemented since 1997, yet new air quality management areas (AQMAs) continue to declared, as monitoring programmes have been extended and non-compliance with the objectives identified. Few have been revoked.


1.4 We now know more about air quality than at any time in history, yet air quality management, nationally and locally, has failed to deliver clean air.


1.5 We believe that there are significant gaps in our knowledge and approach to managing air quality in this country.


1.6 Our concerns can be summarised by five key inter-related issues that need addressing:

a) Lack of leadership and responsibility

b) Climate change diverting political interest away from air quality

c) Inadequate research funding

d) Over reliance on modelling

e) Lack of local authority priority


2. Lack of leadership and responsibility


2.1 We believe that air quality management at both the national and local levels has delivered little because of the lack of high-level leadership.


2.2 This is illustrated by the fact that it is rare for a member of the Cabinet nationally or locally to publically speak about air quality. While to a certain extent this reflects society's change in focus to climate change, it does not reflect the severity of the issue.


2.3 Information campaigns, at public expense, are undertaken to reduce road traffic injuries and death, yet no similar campaigns are undertaken to educate the public on the impacts of traffic on air quality and subsequently their health.


2.4 We believe that without political leadership air quality management will continue to be marginalised and ineffective, and the health of many people will continue to be adversely affected, with an associated reduction in their quality and length of life.


2.5 There is a public perception that the air quality issues have been solved, when this is clearly not the case.


2.6 There is a lack of co-ordination between the departments that should be involved in the management of air quality. It affects and is affected by transport, planning, local government structure and funding mechanisms.


2.7 At the national level Defra, Department of Health (DH), Department for Transport (DfT), Department of Communities and Local Government (CLG), Department for Energy and Climate Change (DECC) and Her Majesty's Treasury (HMT) all have an important role to play, so it is encouraging that the Cabinet Office Strategy unit has included air pollution in its approach to the wider costs of transport in English urban areas (


2.8 Air Quality Management Areas (AQMAs) are often declared due to emissions from roads that come under the responsibility of the Highways Agency (HA). Although the HA has responsibility for air quality on paper there is little evidence of measures being implemented that have had a significant impact on air quality along HA roads. Often the HA's contribution is limited to giving directions to local planning authorities where new development is predicted to increase traffic. Whilst it is recognised that it is difficult to reduce emissions from HA roads without a very significant reduction in emissions / traffic the agency has been reluctant to even consider measures that might improve the situation, such as implementing lower speed limits. Where lower speeds have been introduced the primary objective has been to relieve congestion, not improve air quality.


2.9 It is the same at the local level. For those areas outside London where there is a two-tier local government structure, there can be conflict. If only one or two Districts have an AQMA, for most of the County it is not a priority.


2.10 However, even within unitary authorities, the environmental protection department tends to have a lower status, and hence power, than the transport department, and air quality management is often marginalised.


2.10 The guidance and shared responsibilities for the second round of Local Transport Plans (LTPs) encouraged the inclusion of the Air Quality Action Plan (AQAP) within the second local transport plan (LTP2). Some transport authorities successfully achieved this, but for most, if included at all, it was simply an add-on, not fully integrated into the plan.


2.11 DfT is giving more responsibility during the third local transport plan (LTP3) process to local authorities to determine their own priorities. This 'downgrading' of air quality will result in even less consideration being given to the full integration of air quality issues within local transport planning.


2.12 The monitoring and management of air quality is undertaken by Environment Departments (Defra/Environmental Protection), whereas the main cause, road traffic, is the responsibility of transport/traffic departments (DfT/Transport) which have historically been more concerned with traffic congestion and infrastructure provision than environmental protection.


3. Climate change


3.1 Climate change dominates the political air pollution agenda, to such an extent that some measures are being taken that have a detrimental impact on air quality and funding for air quality management and research has been reduced too much.


3.2 At first sight it would appear that the mitigation of greenhouse gas emissions and the improvement of air quality have a common goal, and indeed for measures that reduce energy demand this is the case. However, there are some technologies that have lower carbon dioxide emissions but higher emissions of nitrogen oxides (NOx)[2], nitrogen dioxide (NO2), and particles (PM10/PM2.5) to the detriment of local air quality.


3.3 Whilst climate change will have very significant impacts on our weather in the future, it should not be forgotten that hundreds of thousands of people are currently suffering and dying prematurely in the UK from the effects of poor air quality. The AQS gave the reduction in average lifetime in the UK as seven months, which is considered an underestimate.


3.4 The climate change agenda has resulted in measures that promote the use of diesel vehicles which have higher particulate matter (PM) and primary NO2 emissions than petrol vehicles. For example, for many years the fuel duty on diesel was set higher than petrol in recognition of the higher PM emissions, but this has been removed because of the lower carbon dioxide (CO2) emissions.


3.5 Another example has been the promotion of biomass boilers in urban areas where there is existing poor air quality. Whilst using renewable energy sources must be good for society, we believe burning biomass where there is poor existing air quality is inappropriate.


3.6 In many small market towns the only solution to poor air quality is reducing congestion in town centres. Building a by-pass is often an unacceptable solution, and even where it is acceptable locally, there is little money available for such schemes. As a consequence residents continue to be exposed to poor air quality.


4. Research


4.1 Insufficient research is being undertaken to solve our air pollution issues.


4.2 When air quality was higher up the political agenda there were on-going programmes sponsored jointly by Defra and DfT (and their predecessors) to fund the on-road measurement of emissions to ensure an up-to-date database on which all national and local modelling is based. This appears to have been halted and there is little real world data for Euro 4 vehicles, let alone Euro 5 HGVs, which are now using our roads. This work is expensive but essential. An update of the Emission Factor Toolkit, which is used extensively for local air quality management, assessing the impacts of new development, and national modelling, has been promised by Defra for several years, but has failed to materialise. Therefore modelling, a key tool in the management of air quality, is based on out-of-date data. This adds to the uncertainity of the impacts predicted.[3]


4.3 For vehicles meeting future emission standards it is assumed that emissions will drop in direct proportion to the improvement in the emission limits, which has historically proved to be an over-simplistic approach. It is, therefore, hard to have confidence in this information when projecting forward into the future.


4.4 The emissions database needs to be extended to include primary NO2 and, for vehicles fitted with selective catalytic reduction, ammonia[4]. Diesel vehicles emit a higher percentage of the NOx as NO2 than petrol vehicles. The increasing percentage of new cars and vans using diesel has resulted in a change in the proportion of primary and secondary NO2 emissions from traffic. This has been exacerbated by the conversion of NO to NO2 in the exhaust of heavy duty vehicles fitted with some diesel particle filters, to assist the removal of PM.


4.5 Also, the DETR-funded TRAMAQ programme was undertaken several years ago to understand in some detail emissions from different driving conditions, such as congestion. This data was not converted into user-friendly tools for use in LAQM. Much of this data may no longer be relevant as the vehicle fleet has changed to meet new emission standards, but it needs updating and converting into useable data for managing air quality.


4.6 Finally, further research is needed into how both NO2 and nitric oxide (NO) behave in the atmosphere. It is likely that further vehicle emission legislation is needed that controls NO2 as well as NOx emissions.


4.7 The UK (DETR) invested substantial sums of money in the Particle Management Programme (PMP), in association with a number of other EU member states, as well as Switzerland and Japan. The aim was to recommend a new type approval test procedure to measure the number of particles rather than the mass. We need to show similar international leadership on the NO2 issue.


5. Modelling


5.1 The current methods of modelling air quality at a national level cannot take account of local characteristics, with the consequence that poor air quality in some areas is being inadequately taken into account in national decision making. This is not a criticism of the modelling per se, but rather a recognition that local issues cannot be reflected in national models and that a mechanism to account for significant local issues needs to be built into a more robust decision-making process.


5.2 UK policy formulation in recent years has been based on cost-benefit analysis, which has been inadequate at accounting for the costs and benefits, and the uncertainties attached to both. Though extended and updated in the Stratgy Unit's 2009 report, the precision attached to such figures is unmerited.


5.3 The approach is inappropriate for identifying the best policies for achieving the EU limit value, which is a legally binding requirement. Cost-benefit analysis[5] has a role in identifying priorities for a range of possible options, but not how to meet a mandatory requirement. For the latter cost effectiveness is the most appropriate technique to use. This is the means of identifying the cheapest package of measures to society to meet a target.


5.4 National modelling is undertaken on behalf of Defra to identify air quality policies and quantify the emissions benefits of a range of measures. Extensive modelling was undertaken as part of the review of the Air Quality Strategy (AQS)[6], and more recently as part of the evidence base for understanding how and when the UK will achieve the EU limit values for PM10 and NO2. This is necessary to identify an action plan to justify Defra's application for a time extension under the 2008 Air Quality and Cleaner Air for Europe, Directive (EU/2008/50)[7] but the NO2 modelling fails to account for many local exceedances (arising from congested traffic).


5.5 This modelling is clearly very dependent on the emissions factors used, for which there are significant concerns, as highlighted above.


5.6 The modelling approach for the AQS was cost-benefit analysis. We are concerned that due to the time lag in policy development, the 2006 US reassessment that doubled the health impacts of PM2.5 was not incorporated in the 2007 AQS, nor in the 2009 Strategy Unit figures. For example the dose-response relationships for the impact of PM10/PM2.5 on health came from the recent work of the Committee on the Medical effects of Air Pollution (COMEAP), yet ignored the comments of two eminent US scientists, who concluded that COMEAP had significantly under-estimated the health impact[8]. If the US coefficient of 6-17% were used instead of the 6% taken in the AQS, further abatement measures are shown as cost effective. Air pollution costs would be increased to 20-30 billion, well in excess of other wider costs of transport in the Strategy Unit's 2009 report.


5.7 Another issue of cost benefit analysis is how revenue from fuel duty is included in the calculations. Measures that reduce HMT income are a disbenefit, and although the price of carbon can be included, this is insufficient to outweigh the loss of revenue in the NATA model ('New Approach to Transport', revised version to apply in 2010,

5.8 The national air quality modelling undertaken does not allow for local circumstances, such as topography and the presence of street canyons. Concentrating exclusively on the national model results in a number of measures, for example the introduction of low-emission zones, seeming not to be cost effective. However at a local scale they may be.


5.9 Defra's initial modelling showed that even in 2015 the NO2 limit value would not be achieved in many areas.




6. Local authority priorities


6.1 Whilst central government is responsible for international and national measures to improve air quality, the LAQM regime has devolved responsibility to local government for local measures. However, air quality is not high on the agenda for most local authorities (LAs). LAQM only requires LAs to 'work towards' achieving the objectives. Responsibility for achieving the mandatory EU limit values lies with Defra.


6.2 Without a mandatory requirement Council Chief Executives are not going to prioritise air quality. Councillors are often reluctant to draw attention to the issue, because they are competing with other areas to draw people, and hence traffic, to their particular retail and commercial locations. The Government's policy of giving local authorities more control over the setting of their own priorities is likely to result in air quality being marginalised even further.


6.3 Over 230 local authorities have declared air quality management areas, mainly for exceedence of the NO2 annual mean objective. When LAQM was first introduced it was thought that there would be a handful of AQMAs in London, not hundreds with some even in the most rural districts. There was concern that the declaration of AQMAs would affect property prices however is no evidence that this is the case.


6.4 LAQM has been very successful at monitoring and modelling air quality, and since the first AQS was published in 1997 technical understanding in most LAs has increased exponentially. The air quality function is undertaken within the Environmental Protection Departments, often by knowledgeable specialist air quality officers. The more local authorities have understood air quality in their areas, more or larger AQMAs have been declared.


6.5 In recent years Defra has provided direct grant funding to local authorities for LAQM modelling and monitoring of air quality. This has been perceived as additional money, and has given local authorities an incentive to fulfil the LAQM review and assessment requirements.


6.6 However as local authorities are only under an obligation to 'work towards' achieving the objectives there is no incentive to implement measures which might be unpopular. This is despite air quality in many areas remaining unchanged or deteriorating.


6.7 Defra has supplied a range of tools for LAQM review and assessment. However, similar tools have not been provided for air quality action planning, and LAs have often found it difficult to understand the cost and emissions impacts of different potential measures. As a consequence most AQAPs have been a long list of general measures with little or no understanding of their relative importance.


6.8 Even where the impacts have been quantified little has been achieved. The problem is that radical action is generally required to comply with the air quality objectives. In many AQMAs a large reduction in emissions, particularly of NOx, is needed. The relationship between NOx emissions and NO2 concentrations is complex and non-linear. Reducing NOx emissions by small amounts, say 10-20%, may make no difference to measured air quality. Where the annual mean NO2 objective is exceeded by 25% or more (i.e. is greater than 50 g/m3), very large changes to emissions and traffic are required. In small market towns, the only viable option is the building of a new road to take the traffic away from busy residential historic streets, where dwellings are close to the carriageway. If the problem is within a district, the council has no direct control over transport, but even in unitary authorities, there is little incentive to give air quality any priority.


6.9 Unless LAs have a statutory duty to achieve the air quality objectives it is unlikely that they will prioritise air quality. However, careful consideration will need to be given to whether new powers will be required.


6.10 It should be noted that LAs have no direct responsibility for achieving EU limit values, and that these apply over a much wider area than the UK objectives. The latter apply where there is likely to be public exposure over the relevant averaging time, the former apply more or less everywhere (exceptions include a few places where the public do not go such as the central reservation of motorways).


6.11 A new approach is required, that may require giving LAs new powers to introduce low-emission strategies, to ensure that the EU limit values are achieved by 2015. These new powers are likely to be necessary to ensure that the EU grants the UK government a time extension from the current requirement for compliance by 2015 with the NO2 limit value.


6.12 We believe one solution may be for local and national government to have joint responsibility for the delivery of the air quality action plan. The local authority could estimate how much of the required emissions reduction they can realistically achieve, with the gap being filled by national and international measures. The action plan would need to be drawn up initially by the LAs and Defra approve it and agree its contribution. This would be an iterative process to ensure that the balance between local and national measures is appropriate.


11 December 2009

[1] The word smog is derived from smoke and fog

[2] NOx is typically regarded to be nitrogen dioxide (NO2) and nitric oxide (NO). Most NOx is emitted from combustion processes as NO but is rapidly converted to NO2 in the atmosphere.

[3] Air quality modelling will always have uncertainty because of the difficulty in accurately simulating complex atmospheric processes in mathematical terms. However, the more accurate the emissions inputting into the dispersion models the more accurate the end results will be.

[4] These vehicles use a urea solution in water to produce ammonia on board, which is an integral part of the emission-reduction process.

[5] Cost-benefit analyses put an economic cost to the benefits of a measure. This is irrelevant if a mandatory limit has to be achieved.

[6] The most recent Air Quality Strategy was published in 2007

[7] An application for a time extension for achieving the PM10 limit value was submitted in 2009, and Defra has announced its intention of submitting a time extension application for NO2 in 2010.

[8] Long-term Exposure to Air Pollution: Effect on Mortality, Committee on the Medical Effects of Air Pollutants, Department of Health, June 2009. This report took two years to be published after the consultant draft was issued in 2007. Peer reviews in Appendix 2 of the final report.