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Environmental Audit Committee Air Quality Inquiry. Written Evidence from the Joint Nature Conservation Committee, 14 December 2009. (AQ14) 1. Summary 1.1. This response focuses on the impacts of air
quality on the natural environment in the context of 1.2. There is strong evidence of the effects of air
pollution on semi-natural ecosystems in the 1.3. The 1.4. The Government's understanding of, and commitment to, investigating the environmental risks of air quality at a broad level is good. However, there is a need for more work to interpret effects in relation to policies for biodiversity and ecosystem services. 1.5. Impacts on ecosystem services should be a central part of air pollution policy alongside human health. There are synergies between air pollution policies focused on human health and environmental health. 1.6. The UK Air Quality Strategy should give greater attention to protection of ecosystems, including more ambitious targets.
2. The monitoring and modelling systems used by the Government and whether these provide an adequate measure of air quality 2.1. The 2.2. There are also a number of monitoring schemes which provide evidence of air pollution impacts on ecosystems. Some of these schemes have been established and designed specifically to monitor the effects of air pollution on a small sample of sites and also provide information on the process underlying responses. Examples include the government-funded Acid Waters Monitoring Programme, Environmental Change Network and Forest Level II survey. A number of other schemes, which are not specifically targeted at assessing air pollution impacts, provide useful data on changes to vegetation which can be correlated to atmospheric deposition. As such, they provide a general detection mechanism, but attribution of a signal to a specific pressure, i.e. air pollution, is more difficult. An example is the Countryside Survey[2] which has shown vegetation change between 1978 and 2000, stabilising in 2007, consistent with a response to excess nitrogen and which correlates significantly with nitrogen deposition. 2.3. However, there are no schemes which provide
direct and comprehensive assessment of air pollution impacts on terrestrial
semi-natural ecosystems. This gap was
identified in the report of the National Expert Group on Transboundary Air
Pollution[3]
in 2001, which made recommendations for further monitoring. Yet, there are a wide range of surveillance
schemes covering different aspects of 2.4. The project will assess the adequacy of the evidence base and whether new surveillance or a modification to existing surveillance is required. The recommendations will be put to the UK Terrestrial Biodiversity Surveillance Strategy[4] Implementation Group. This work relates closely to a recommendation in the draft report of the Review of Transboundary Air Pollution1 which states there should be a review of existing soils and vegetation schemes and proposals. However, the scope of their recommendation is wider than nitrogen deposition, which is the focus of the JNCC led study (as this is seen as the priority), and includes ozone, acidification and heavy metals. 3. The extent to which the Government fully understands and has identified the health and environmental risks caused by poor air quality 3.1. There is unequivocal
evidence that air pollution has caused widespread changes to sensitive
ecosystems in the 3.2. The Government has
commissioned a Review of Transboundary Air Pollution (RoTAP) which is due to
publish its report in the spring 2010. The RoTAP report aims to review the current state of rural
air pollution issues in the 3.3. It describes widespread exceedance of critical
loads for acid and nutrient nitrogen deposition and presents strong evidence
that nitrogen has reduced plant species diversity in semi-natural habitats
across the 3.4. Therefore the Government's understanding of,
and commitment to, investigating the environmental risks of air pollution at a
broad level is good. However, it is also
important to consider the significance of these effects in terms of the 3.5. In particular, the Habitats Directive[5] requires Member States to take measures to maintain at, or restore to, favourable conservation status, the natural habitats and species of Community Importance. The UK's second report under Article 17 of the directive[6], on the conservation status of habitats and species, identified air pollution as a threat to the conservation status of 53 out of the 77 habitats reported on for the UK Atlantic region. 3.6. The 3.7. Over the past decade, nutrient
nitrogen critical load exceedance has remained virtually unchanged with
approximately 60% of sensitive semi-natural habitat area in the 3.8. The ecosystem services concept offers an additional approach to evaluate the marginal benefits of different air pollution polices. Such an approach would provide a holistic consideration of the positive and negative impacts of air pollution on the services ecosystems provide and the resulting effects on human well-being. Defra funded a scoping study in 2008[9] which scoped the potential for the approach to be applied to air pollution policy, using ammonia as a case study. It showed potential for the methodology, but data gaps remain particularly regarding the valuation of marginal benefits. However, the approach in respect to air pollution policy remains in its infancy and we recommend further development to identify and rectify the most critical data gaps and greatest uncertainties, such that the application of the concept in respect of air pollution is sufficiently robust to inform future policy development. 3.9. In conclusion, the UK
Government has a strong understanding of the environmental risks caused by air
pollution, although a number of research questions remain (for example, see the
draft RoTAP report). There is convincing
evidence of pollution impacts on ecosystems in the 4. 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 4.1. Responsibility for air pollution policy and control is spread across different government departments, both centrally and locally, as well as government agencies. 4.2. The conservation agencies are statutory
advisers under pollution and planning legislation and provide advice on the
local impacts of air pollution arising from point sources, road schemes and
other planning casework in relation to the various statutory obligations in
addition to more strategic advice at a country and 4.3. One area which appears to fall between current
governance structures is that of ammonia from agriculture, with the exception
of large pig and poultry installations which are regulated under the
Environmental Permitting Regulations (EPR) in 5. The steps that need to be taken to ensure that air quality targets will be met in the future 5.1. Our evidence focuses on the impacts on
biodiversity in relation to both concentrations of air pollutants and
deposition. Our response in section 3
outlined the strong evidence of air pollution impacts on Emission Ceilings 5.2. Exceedance of ecosystem critical loads was a
major driver for the National Emissions Ceilings Directive and the Gothenburg
Protocol. These policy instruments are
now being reviewed, which will introduce lower national emission ceilings as
well as additional pollutants, including fine particulates. There are many synergies between air
pollution policies driven by human health issues and that for ecosystems, for
example ammonia is a source of secondary fine particulate matter as well as a
major contributor to eutrophication, and it is important that the co-benefits
are maximised whilst conflicts minimised.
Modelling studies in the 5.3. While the Environmental Audit Committee's inquiry is focused mainly on local air quality in certain regions, it also noteworthy that the Government is predicting that it will fail to meet its NECD target for NOX. The NECD UK NOX ceiling is 1,167kt and Defra predicts we will be 11% short of this target in 2010[14]. This is in part due to increase coal burning for electricity production[15]. 5.4. In response to a 1998 Environment Agency
consultation on "Controls of Emissions from Coal and Oil Fired Power Stations",
CCW and English Nature called upon the Agency to require the fitting of
Selective Catalytic Reduction (SCR) on existing and new power stations to
control NOX emissions. At this time the
technology was well founded and was being applied in other parts of Europe,
such as 5.5. A report commissioned by Defra in 2008[16]
investigated how the
Air Quality Strategy 5.6. The 2000 AQS did not address the impact of air pollution on ecosystems to any significant extent. It was primarily concerned with the improvement of air quality for the protection of human health. The Government have stated that the scope of the strategy should be progressively extended to address key ecosystem impacts[17]. JNCC welcomes this and are pleased to see that the 2007 AQS went some way to encompass wider concerns, such as atmospheric deposition (and critical loads exceedance), ammonia and ozone. However, despite this, we remain concerned that the 2007 AQS still provides little in the way of protection of ecosystems from air pollution, over and above actions and commitments already in place. For example, it excludes ammonia, which is now seen as a priority6 and avoids setting targets or objectives for critical loads exceedance (although the Government did include critical loads exceedance when evaluating the benefits of different policy options for the 2007 AQS). 5.7. JNCC has raised these concerns with Defra, and its predecessor bodies, on a number of occasions over the past 10 years and has advised that the AQS still fails to fully address Government commitments and policies for biodiversity. 5.8. The AQS considers the impacts of NOX and SO2 on ecosystems and defines national objectives
for ecosystems for these two pollutants.
These are 20ugm-3 annual mean/winter mean for SO2
and 30ugm-3 annual mean for NOX. The 5.9. We have advised Defra that this conflicts with
the 5.10. The review of the strategy in 2006 considered options for extending the 2000 Strategy's objectives for SO2 and NOX for protection of vegetation, but none was adopted in the 2007 strategy which stated that Defra will instead "take forward additional analysis and consider how best to ensure protection of ecosystems against air pollution in the medium to the long term." JNCC has offered to support the Government on this further work. 5.11. The new Directive
on ambient air quality and cleaner air for 5.12. The main drivers stated for this air
quality inquiry are related to the 5.13. In future, many of the reductions in air pollution will be driven by efforts to reduce greenhouse gases. It is essential that the effects of climate change policies on air pollution emissions (and atmospheric chemistry), for example policies on power generation (CO2) and agriculture (CH4 and N2O), are fully considered at an early stage in policy formulation, so that the co-benefits can be maximised and potential conflicts addressed. This is recognised by the Air and Local Environment Programme at Defra and the devolved administrations. 14 December 2009 [i] For local impact or regional assessments, for example in respect of risk assessments of impacts from a local installation on a protected nature conservation site, the number and location of monitoring sites and the relatively coarse resolution of long-range models mean that in some cases additional monitoring is required. [ii] Special Areas of Conservation are defined under the Habitats Directive. [1] Draft Review of Transboundary Air Pollution. www.rotap.ceh.ac.uk [2] http://www.countrysidesurvey.org.uk/ [3] NEGTAP, 2001. Transboundary
Air Pollution: Acidification, Eutrophication and Ground-Level Ozone in the [4] http://www.jncc.gov.uk/page-4409 [5] Council Directive 92/43/EEC on the Conservation of natural habitats and of wild fauna and flora [6] http://www.jncc.gov.uk/PDF/FCS2007_ukapproach.pdf; http://www.jncc.gov.uk/page-4060 [7] Bill Beally, Centre for Ecology and Hydrology pers comm. [8] http://www.jncc.gov.uk/page-4245 [9] Hicks, K, Morrissey, T, Ashmore, M, Raffaelli, D, Sutton, M, Smart, J, Ramwell, C, Bealey, B and Heinemeyer A. 2008. Towards an Ecosystems Approach for Ammonia- Embedding an Ecosystem Services Framework into Air Quality Policy for Agricultural Ammonia Emissions. Defra Report NR0120. [10] http://www.environment-agency.gov.uk/netregs/businesses/forestry/62849.aspx [11] http://www.northwyke.bbsrc.ac.uk/AmmoniaInventoryWebsite/AmmoniaInventory.html [12] CCE. 2008. Hettelingh, JP., Posch, M.,
Slootweg, J. Eds. Critical Load, Dynamic Modelling and Impact Assessment in [13]Defra research contract AC0109 http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=14938&FromSearch=Y&Status=2&Publisher=1&SearchText=AC0109&SortString=ProjectCode&SortOrder=Asc&Paging=10#Description [14] UK national emissions ceilings Directive data submission, 2006 [15] ENDS Report 397, February 2008, p 14 (c) 2008 Haymarket Business Media [16] Entec, 2008. Multi-Pollutant Measures Database Interim Report to Defra: Meeting the NOx National Emission Ceiling for 2010. [17] Air Quality Strategy for |