Memorandum submitted by the Royal Borough of Kensington and Chelsea (AQ 19)

The following comments respond to the four points posed by the Committee.



Over-reliance on modelling pollution levels by the Government, without sufficient reference to actual monitoring results has led to over optimistic predictions.


Ignoring mounting evidence of more serious health effects from fine particle is short-sighted and for government objective setting is irresponsible.


In failing to meet the EU PM10 target, the Government has demonstrated that air quality is not a national health priority.


Local authorities are however committed to spending considerable effort on addressing the air quality problem through local initiatives.


There must be a far more coherent approach from all levels of government ensuring that actions are co-ordinated and support each other. This must include measures which address climate change issues to ensure that conflicts are resolved and enable air quality to be targeted effectively.


In Response to Point 1


1 The Government's reliance on modelling future levels and reliance on optimistic assumptions has been at odds with monitoring data for a number of years, yet there has been a reluctance to acknowledge this.  For some time it has become apparent that the expected improvements as a result of decreasing emissions through improved vehicle technology (implementation of Euro standards) has not materialised as measured pollution levels at a significant number of inner urban monitoring stations.  This is likely to be due to a number of reasons:


models contain a large number of uncertainties and simplifications;

laboratory test cycle emissions rarely reflect real life use of vehicles or the deterioration of vehicle technology over time;

real driving conditions are difficult to simulate e.g. time varying traffic speeds, congested stop start driving;

assumptions in the way the fleet changes may be inaccurate;

the effects of retrofitting particulate traps to vehicles may be poorly understood;

the increasing proportion of NOx being emitted directly as NO2 especially in diesel vehicles;

the use of national scale models.


In Response to Point 2


2 Central London local authorities have been dismayed by the apparent reluctance of the Government and their advisers COMEAP to acknowledge recent international research particularly into the health effects of fine particles. These are showing, through long term studies, that the impact of fine particle concentrations below the current objectives is having a significant impact on cardio-respiratory health. Concentrating on "hotspots" where the objectives are exceeded is important in the short term, but is ignoring the longer term public health implications of objectives set at a level where significant harm to health is occurring.


In Response to Point 3


3 The delivery chain for air quality management should be led and be executed more effectively at a national level. The failure to meet the PM10 objective level and the very high likelihood that NO2 will follow a similar fate, has demonstrated that the UK Government is not committed to addressing this issue. In the last review of the national air quality strategy many national measures considered in the review were not considered cost effective/beneficial including Low Emissions Zones consequently this has led to a delay in the implementation of measures that could have improved the air quality situation.


4 With background concentrations relatively high, it is extremely challenging to manage air quality and make significant improvements despite the actions of local authorities without significant intervention from national and London Government working far more closely together. More co-ordinated actions which have already been shown to be effective should be applied across action plan areas.


5 The Government has focused much attention on producing strategies and detailed guidance which aim to devolve most of the responsibility to local authorities. Local authorities are obliged to inform the Government on progress with action plans, which takes a considerable amount of time each year. Feedback from Defra has largely been in the form of questioning the methodology used rather than commenting on the conclusions being drawn by local authorities that local action alone is not sufficient to meet targets.


6 It would be of greater value to spend more time implementing the targets within the action plan, of which we as a council have over 20 rather than on reporting. Most of these actions involve collaborating with other departments such as our transportation and highways department, contracts managers, and the planning department and many external organisations.


7 Many local authority actions have a limited impact because they can only address a small proportion of the pollutant emissions within the borough. There is also considerable uncertainty over the extent to which these measures can deliver the improvements necessary to meet the air quality objectives. Many measures are by their nature trials and do not necessarily deliver the expected benefits. Limited resources and data are available to evaluate the emissions reductions that the measures can deliver.


8 A considerable amount of scientific evidence and technical data is continuously emerging on PM10 and NOx and how these pollutants react in the atmosphere and contribute to overall concentrations. The complexity of this information with data often remaining in the scientific community and the fact that it cannot be easily applied means it is not possible to produce effective solutions.


9 In any case many sources are beyond the direct control of councils, for example the huge volumes of traffic passing through individual boroughs are often under the direct control of other agencies and authorities. For example in London the major routes are under the control of TFL. Traffic management schemes often have a limited effect or simply move the problem elsewhere. The Mayor's air quality strategy has identified that an 80% reduction in traffic is necessary to achieve the air quality limit value for NO2 in London.


10 Other organisations/disciplines must be given ownership of the air quality problem as it is too often seen as an environmental issue and as such sits within Environmental Health departments and consequently it is not given sufficient priority in other departments.


11 As we enter the next stage of the recession, local authorities are faced with further reductions in resources. This could put our air quality action plans and monitoring sites at risk. These sites provide important information and have demonstrated clearly that improvements to air quality have not occurred as predicted and in some cases have deteriorated.


12 As a central London borough, our incentive to improve air quality is driven primarily by the associated health effects of air pollution and the concerns voiced by people living and working in our borough. London has the poorest air quality not just in the UK but across Europe and quantifying the health consequences of this has proved challenging. Previous attempts to quantify the impacts were likely to be underestimates and recent research suggests that PM10 levels are causing approximately 3,000 premature deaths in London each year[1]. The Government must support further research into the health and cost implications of the issue which will emphasise the severity of the situation.


In Response to Point 4


13 In order to ensure that the UK meets the objectives in the future, air quality needs to be more prominent within the environmental agenda. The issue is often overshadowed by carbon campaigns in the media making public awareness of the problem extremely limited and directly by promoting biomass and some biofuels (as carbon neutral fuels) which in most cases can be significant negative effects on air quality.


14 As a borough, 69% of PM10 and 37% NO2 (2006 total) is derived from road transport sources. The Government should be applying more pressure on the vehicle industry to recognise their role in reducing PM10 and NO2 emissions. Stronger support and incentives should also be given for the development and application of alternative fuel use.


15 It should also be recognised that a balance should be reached between achieving the PM10 and NO2 objectives and the imperatives of carbon reduction measures. One example being the perception that diesel is a 'greener' fuel than petrol. Carbon emissions from diesel vehicles are lower due to fuel efficiency, but this is at the expense of PM10 emissions, particularly in urban areas. With particulate abatement systems leading to elevated tailpipe NOX emissions in diesel vehicles, the Government should be re-educating car owners. The introduction of local measure such as graduated resident parking permits (higher for diesel vehicles) can be met with some frustration from the public who were informed that they had made the greener choice of vehicle.


16 A valuable step would be to extend the banding system for Vehicle Excise Duty to include PM10 and NO2 and ensure that vehicles are labelled clearly with this information. This would ensure that both carbon and local air pollutants are considered when purchasing a vehicle.


17 Taking into consideration the capital's contribution to air pollution in the UK, the Mayor of London should reconsider his decision to defer Phase 3 of the Low Emission Zone and his plans to scrap the western extension of the Central Congestion Zone. These decisions will hinder any improvement initiatives introduced by London authorities and as a consequence further jeopardise the chance of reaching the national objectives in the future.


18 The Government should be targeting the use of private transport and taxi use more aggressively, making public transport a more convenient and preferable choice. With taxi's being responsible for around 35 per cent of road transport PM10 exhaust emissions in central London, the Mayor plans to restrict older vehicles but could be criticised for only requiring Euro 4 standard from 2012[2]. More stringent measures should be implemented on a national level.


19 The recently introduced national scrappage scheme should be funded after February 2010 and be extended to include more manufacturers and vehicles such as taxis. This scheme provides a clear incentive for car owners and the Government must continue to support these initiatives in order to meet future air quality objectives. It would be an advantage in future to offer the incentive only where the replacement is a low emission vehicle.


20 The planning system also has a vital role to play in the management of local air quality. Current legislation is not robust enough, making air quality a low priority on the list of planning considerations. The demand for housing and new roads in this country will inevitably exacerbate the situation when we approach the next set of air quality objectives.


21 There are a total of 235[3] local authorities in the UK which have declared Air Quality Management Areas but it is unclear of the significance of this in the planning process. Air quality should be an integral aspect of the process and influence decisions regarding transport and energy options. Air quality assessments and modelling calculations submitted by developers invariably result in over optimistic predictions of the impacts and should be replaced rapidly by low emission strategies.


22 As renewable energy use increases, there needs to be a clearer message regarding the impacts of biomass, CHP and decentralised energy production on air quality. There must be recognition that encouraging power generation especially in heavily populated cities already exceeding air quality objectives will be detrimental to health and reduce the likelihood of achieving objectives unless very strict standards can be applied. Legislation should be strengthened to make the Clean Air Act legislation more relevant to biomass and biofuel use in Smoke Control Areas and if necessary make new regulations that apply to CHP and waste to energy plant.


23 With a significant proportion of NO2 and to a lesser extent PM10 deriving from domestic emissions, in order to meet the objectives the Government must also review standards in terms of the energy efficiency of buildings. Focus should not be just on new housing but measures to replace old boilers including scrappage that takes into account air quality improvements as well as carbon, retro-fitting abatement to communal boiler systems, extending grants for upgrading energy efficiency measures.


24 The planning system should promote naturally ventilated buildings, reducing the heating and cooling requirements of large developments.


25 In conclusion, optimistic predictions of future air quality have meant the Government has acted too late and London is failing to achieve the NO2 and PM10 limit values. The EU has recently announced that no time extension will be granted with respect to the PM10 derogation for London. The detrimental health impacts and potential costs in fines must be recognised. Brave, innovative and robust measures need to be introduced in order to tackle this issue on a national scale.


14 December 2009


[1] Estimates for London have been calculated by Professor Frank Kelly using the European Environment Agency (2005) Spatial assessment of PM10 and ozone concentrations in Europe


[2] GLA (2009) Clearing the Air (consultation draft for the London Assembly and functional bodies)


[3] UK Air Quality Archive