Session 2009-10
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Memorandum submitted by the Local Authorities Coordinators of Regulatory Services (LACORS) (AQ 15)


LACORS (The Local Authorities Coordinators of Regulatory Services) is part of the LGA Group. LACORS promotes quality regulation to councils in the areas of trading standards, environmental protection, licensing and gambling, food safety, health and safety, hygiene and standards, animal health and welfare and private sector housing. LACORS offer comprehensive advice and guidance to councils and their partners, disseminating good practice and providing up-to-date information on policies and initiatives that affect local people and local services. We lobby on behalf of councils and ensure that legislation and government policy can be practically implemented, and with our colleagues in the LGA group, ensure we contribute to sector-led improvement.

LACORS works with all local authorities across England and Wales in a number of key policy areas, including that relating to environmental protection.


· The monitoring and modelling systems provide an adequate measure of air quality. It is the question of how actions to improve air quality can be delivered more effectively that now requires additional focus.

· There is a significant evidence base regarding the health impacts of air pollution; however the Government may not be using the most up-to-date information.

· It is often frustrating for local authorities working towards improving air quality that they lack control over many of the main sources of pollution in their areas and funding for measures.

· The delivery chain for air quality is fragmented and there is a need for more co-ordinated working at all levels of government and between the various stakeholders.

· Significant behaviour change is required to reduce emissions and greater public understanding of air quality sources and impacts is necessary to achieve this.

Detailed comments on the areas of interest to the Committee are set out below.

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

1. Local monitoring, national monitoring and modelling and the associated reporting are well established and relevant local authorities have developed a considerable amount of expertise in this area. Overall, the monitoring side of local air quality management works well. The current system may not provide an exact measurement of public exposure due to the limitations of locating monitoring stations where exposure is highest, but we consider that it does provide an adequate measure of air quality.

2. There does sometimes appear to be a disconnect between local monitoring and Department for Environment, Food and Rural Affairs (Defra) central modelling, on which we would seek further clarification.

3. Whilst the measurement of air quality is of course important, it is the question of how actions to improve air quality can be delivered more effectively that now requires additional focus.

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

4. There is a significant evidence base on the health impacts of air pollution, especially with regard to particulate matter. The Committee on the Medical Effects of Air Pollution (COMEAP) has produced several reports, including on the effect on mortality of long-term exposure to air pollution. Other international studies have also contributed to our understanding of the impacts.

5. However, the oft-quoted figure of 24,000 premature deaths per year is now over ten years old. In a letter to Mayor Johnson dated 20th September 2009, the Campaign for Clean Air in London highlighted that figures for premature deaths caused by air pollution could be significantly higher than those used by the Government, if calculated using more up-to-date relative risk coefficients and by applying the precautionary principle.1

6. The Air Quality Strategy 2007 and many other Government publications quote the statistic of 7-8 months of life lost which may not necessarily be the most effective way of expressing the impact, especially to the public. Averaging out the health impacts across the general population diminishes the impact per person actually affected i.e. years lost per statistical victim, which could be as high as 9.8 years2.

7. In comparison with particulate matter, there is much less evidence on the impacts of nitrogen dioxide partly, due to relatively limited research. As a result, some people doubt the need for action although LACORS would advocate a precautionary approach. Moreover, nitrogen dioxide targets are of course enshrined in EU legislation.

8. That the health impacts of air quality are relatively well established has not translated into prioritisation of the issue by the Government, particularly outside of Defra.

9. There is no question that the UK must act to improve air quality; indeed, failure to meet EU objectives and the known health impacts make it imperative. This being the case, the Government should use cost-effectiveness analysis to assess which measures should be taken as opposed to cost-benefit analysis which has a tendency to rule out many actions that could make a significant difference. Several measures considered in the Air Quality Strategy 2007 were ruled out for this reason.

10. We would also encourage the Government to review the weighting given to air quality impacts in its analyses to ensure that the figures are appropriate and up-to-date with current evidence.

11. It is not only the Government that needs to better understand the risks posed by poor air quality. If we are to be successful in reducing emissions, significant behavioural change such as a modal shift away from private vehicle use is needed by the public. In addition, many ‘big wins’ for air quality, such as low-emission zones, require significant public buy-in for them to be politically tenable. The experience of the referendum on congestion charging in Manchester illustrates this point. Air pollution often cannot be seen, smelt or tasted by the public and most people do not understand that it harms their health, all of which contributes to its low profile.

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

12. The delivery chain for improving air quality is fragmented, largely due to so many different actors, both centrally and locally, having an interest or control, be it the measurement of air pollution, its health impacts or control over its sources. This can result in no one organisation fully grasping all aspects of air quality which can result in the issue ‘falling through the cracks’.

13. It is often frustrating for local authorities working towards improving air quality that they have a lack of control over many of the main sources of pollution in their areas, such as roads overseen by the Highways Agency and bus operators, and insufficient funding to implement measures.

14. The Highways Agency has a commitment to ‘not make air quality worse’ and to work with local authorities on Local Air Quality Management; however there is frustration amongst some local authorities that the air quality in their areas is largely affected by traffic from roads that are the responsibility of the Highways Agency. The Highways Agency is itself constrained by limited funding for ‘environmentally incentivised schemes’, which has to cover the full spectrum of the environment and is not sufficient to address air quality problems. There are some localised problems of communication between local authorities and the Highways Agency that the Highways Agency is seeking to resolve through improved internal arrangements, which are to be welcomed.

15. Buses can be a significant source of pollution in some areas and for local authorities outside of London the deregulation of bus services has left them with very limited power over the quality of both services (routes, timing etc) and vehicles standards.

16. The Department for Transport (DfT) contends that the introduction of Quality Bus Contracts and Partnerships have restored the balance of power in this respect. However, Quality Bus Contracts have had very limited take-up as they are expensive and complex to establish. Bus companies also prefer the informal approach of Quality Bus Partnerships and are therefore reluctant to enter into a more formal contract.

17. Links between central government departments require improvement. Recently, Defra and DfT appear to be linking up more effectively including quarterly liaison meetings between officials from these departments and LACORS officers. However, truly consistent joined-up policy across all relevant departments is still lacking. Although Defra and DfT are principal government departments with regard to air quality, it is essential that the Department for Energy and Climate Change, Communities and Local Government, Department of Health and HM Treasury also engage in and indeed prioritise air quality issues, which they appear to have been somewhat reluctant to do thus far.

18. We recognise that there is also a challenge for local government to work more effectively across authorities, both between departments and across geographical areas. This can be, but is not always, more pronounced in two-tier areas where air quality officers sit within the district authority and transport planners, who can lever key action on air quality, are located at the county level.

19. The link between air quality and planning is crucial. The places we live have too often been planned around private transport and individual journeys. The work done by the low-emission strategies group highlights some best practice in using the planning system to encourage new technologies and reduce emissions from developments3.

20. Co-ordinated policies across departments in both central and local government would help to highlight the links to other public health issues such as obesity, physical fitness and climate change which could increase awareness and the profile of air quality.

21. Local authorities are not adequately resourced to make many of the changes required to bring about a significant improvement in air quality, for example public transport improvements and making cycling and walking easier. Many would be willing to take further measures, but are constrained by a lack of funding. At a time when local government is facing even greater pressure on budgets, which must be stretched and shared between competing services, lack of action does not necessarily denote a lack of understanding or commitment.

22. A recent Cabinet Office report on urban transport4 estimated the health costs of particulate matter alone to be in the region of £5-10 billion per annum. Combined with the threat of EU infraction fines potentially running into hundreds of millions of pounds, a compelling economic argument for investing in measures to mitigate air pollution becomes clear.

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

23. As outlined in the response above, there are many barriers to improving air quality. Some parties argue for strengthened duties or targets on local authorities to deliver cleaner air or to deliver EU targets. Whilst recognising that the current wording in the Environment Act 1995 could be tightened, placing a more stringent duty on local government is completely meaningless without the necessary powers and funding that could actually deliver air quality improvements, and indeed duties on others to act.

24. As highlighted in the section above, the Highways Agency has a duty not to make air quality worse. A duty to improve air quality where possible would drive further action. This should also be accompanied by an appropriate increase in funding for measures.

25. Detailed guidance on Quality Bus Contracts was only extremely recently published by DfT and we hope that this will help QBCs to be taken up more widely. However, there is still likely to be a lack of control over bus services in most areas outside of London. One option is devolving the distribution of bus subsidies to local level would allow the funding to be targeted according to local priorities, which could include encouraging the uptake of cleaner vehicles, improving service performance and reducing congestion.

26. Low-emission zones can be effective mechanisms for reducing emissions and are more widely implemented in other EU member states5. Although a ‘one size fits all’ approach would not be appropriate, a national framework setting out common standards for different types of vehicles that local authorities could select from depending on the nature of local pollution sources, and a common easy-to-enforce approach, would have a number of benefits. It would help to provide more of a central lead, reducing the political and financial risk involved in their establishment; provide more consistency for industry affected; help to prevent the displacement of higher-emission vehicles such as buses into other areas with lower standards; and reduce the scope for concern that businesses will locate in other nearby areas. LACORS has had initial discussions with DfT and Defra on this issue and will continue to liaise with them on how this framework might look to ensure that, if produced, it contains what local authorities need.

27. Central government could play a useful role by co-ordinating a stronger and more comprehensive evidence base on the effectiveness of measures that local authorities could access to inform their air quality action plans. Central collation of this information, for example what measures work well or not in which type of area or situation, would reduce duplication at local level across the country.

28. In the future, it must be ensured that the planning system gives more consideration to reducing reliance on cars. ‘Retrofitting’ existing poor planning is not easy, but greatly improved public transport and cycling and walking infrastructure can play a big role in this and would bring major benefits including for air quality, climate change, fitness and general wellbeing.

29. The challenges of finding funding for measures such as public transport improvements have been highlighted earlier in this response. The Department for Health is the key beneficiary of reducing pollution levels in terms of health benefits and consideration should therefore be given to providing some funding for local authority actions through Primary Care Trusts.

30. It is vitally important that the Government adopts and uses the most up-to-date evidence regarding impacts on health and mortality of air pollution and that the public is made aware of this evidence.

31. Behavioural change would bring some of the greatest benefits for air quality and climate change, although it is hard to achieve; as discussed in paragraph 11, it is important that public understanding of air quality issues is raised. Defra carried out a ‘Citizen’s Jury’ in 2006 to explore public views on air quality6. The results showed that at the beginning of the exercise, there was no understanding of how air quality is measured, the health impacts, or that action can be taken by individuals to improve it. At the end of the process the participants agreed that the issue of air quality was more important than originally thought, due to the health impacts. The citizen jurors recommended a public awareness campaign that provided information on the cause and implications of air quality and what individuals could do to make a difference and how they would benefit as a result. This campaign should now be delivered with urgency, funded by central government and delivered in co-operation with local authorities.

32. Other initiatives could also be rolled out on a wider basis as part of such a campaign. For example, air alerts established in London7 and Sussex8 provide free alerts of expected air pollution incidents and related health advice to those with medical conditions that are exacerbated by air pollution. Innovations such as the low-pollution route option available on can also help raise awareness.

33. The relationship between air pollution and climate change is not straightforward and it is essential that further effort is made to consider both these challenges in an integrated and holistic manner at both the local and national level. Many actions to encourage a modal transport shift will benefit both and these ‘win-win’ solutions should be taken wherever possible. There must also be greater recognition that there are sometimes trade-offs, for example, recent years have seen a marked uptake in the use of diesel vehicles and biomass burning. Both are considered to be beneficial for carbon dioxide reductions, but can have negative consequences for local air quality and hence people’s health.

34. The opportunity to raise the profile of air quality by linking to the momentum surrounding climate change and CO2 reduction campaigns should be taken wherever possible. The Government must also ensure that opportunities are not missed to integrate air quality considerations into research on transport modal changes.

35. More effective and joined-up policy is required between all the relevant central government departments and links between all organisations must be strengthened: between central government departments, local authorities, the Highways Agency, the Environment Agency and other stakeholders.

36. There is no simple solution to the issues around local authorities working together more effectively, which requires greater partnership working. One option is to create more strongly shared responsibility across tiers of local government, for example, responsibility for delivering certain elements of the air quality action plan sitting where the ability to deliver them resides.

14 December 2009


[2] Künzli et al. (2001). Assessment of Deaths Attributable to Air Pollution: Should We Use Risk Estimates based on Time Series or on Cohort Studies? American Journal of Epidemiology , 153 (11), 1050-1055 .







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Prepared 11:06 on 16th March 2010