Memorandum submitted by Barry & Vale Friends of the Earth (AQ 23)
Friends
of the Earth in
This response is restricted to particulate pollution of the ambient air, whether or not covered by the Air Quality standards.
1. the Committee's first question ● whether the Government is developing an effective strategy for meeting its obligations under the EU Air Quality Directives
We attach
our objection (PM10
extension-resp toDefra March09.doc) to the Government's request to the
Commission for extra time to meet the PM10
standard for 2005. This gives arguments
why current plans are not effective for meeting the 2005 PM10 standard at
Proposed Additional Measures for Abating Traffic-related PM10 and NO2
● Speed limit of ~50 mph through and near to urban areas on all roads including motorways; ● Taxation to improve the public transport to private car cost ratio; ● Giving real force to 'smog' alerts, including incentives or legal measures to reduce vehicle use for the duration; and ● Congestion charging that reduces traffic in congested areas could be helpful.
2. the Committee's second question:
● whether the strategy is enough to ensure that air pollution is reduced to acceptable levels
We answer this from the standpoint that particulate pollution is a major public health hazard (worse than secondary cigarette smoking) and that the EU standards do not adequately address this hazard. The WHO guideline for PM2.5 of 10 mg/m3 (cf. 12 mg/m3 adopted in Scotland) shows the EU standard (25 mg/m3) is quite inadequate. Moreover, there is no standard for ultrafine particulates (nanoparticles, <0.1mg/m3) that are probably the most harmful pollution fraction. 1. The
first AQS chose PM10 as index, when inhalation was better
approximated by PM2.5 and the QUARG report [1] gave several other
reasons for choosing PM2.5 (which we considered persuasive). While the 2. The
AQS has ignored ultrafine particles, despite their recognition as probably the
major reason for adverse health impact and appreciation that they are hardly
captured by the PM10 index. Our criticisms drew on the Royal Society
conference of 1999 (Ultrafine particles
in the atmosphere, Royal Society 2000) and contacts with specialists in
fetal toxicology at 3. We have submitted criticisms of the EPAQS reports, including their ignoring of ultrafine particles. This fault was evidently prescribed by Defra's AQ section, for the chair Prof. Anthony Seaton is a pioneer on identifying ultrafine particles as having the major impact on health, and long-term member (current chair of COMEAP) stressed ultrafine particles are probably the main hazard to a European meeting in 2003 [2].4. We have pointed out that COMEAP under the DoH has consistently underestimated the harm to health as shown in epidemiology studies ([3]; reports of 1998 and 2001), including in its latest report (dated June 2009; ANNEX 1). As this is over 2 years old and was to provide underpinning for the 2006-7 AQS review, it appears that it has been held up for political reasons, as it's at odds with the findings of the leading epidemiologists internationally and, effectively, failed its peer review. Thus the figures the Committee call quotes from the AQ Strategy are too low by a factor two (maybe 3 times) "estimated to reduce the life expectancy of every person in the They should read 15-24 months and up to £60 bn/year.
For an up-to-date scientific review on the hazards to health from ultrafine particles, we attach as ANNEX 2 an extract of the evidence given by Prof. V Howard at a recent public inquiry (Ringaskiddy).
Whether the Strategy will suffice to reduce particle pollution to acceptable levels (as the Committee asks) must be answered with a resounding no! While no 'safe' levels of PM and ultrafines have been identified, it a) doesn't suffice to meet the PM10 standards b) doesn't seek to meet the WHO's PM2.5 guideline, and c) ignores the ultrafine particle issue entirely, despite scientists believing it is the most serious fraction.
References [1] Quality of Urban Air Review Group, 1996 report, chaired by Prof. Roy Harrison. [2] Jon Ayres, Health Effects of Airborne Particles, to MVEG sub-group on Euro 5 and Euro 6, 4 Sept. 2003 http://ec.europa.eu/enterprise/automotive/mveg_meetings/subgroup_euro/meeting1/ayres_presentation.pdf [3]
Attachments as e-files PM10 extension-resp toDefra March09.doc FOE consultation response PM10(10Mar09).pdf
15 December 2009 ----------------------------------------------------------------------------------------------------------------------------------------------
ANNEX 1 Particulates and long-term Mortality - COMEAP's report fails its peer review
The Committee on the Medical Effects of Air Pollutants (COMEAP)
has published** its long-awaited report on the Long-Term Exposure to Air
Pollution: Effect on Mortality and in so doing has confirmed the extent to
which the UK Government considers there to be a strong link between the effect
of air pollution, illness and life expectancy.
The dose-effect coefficient settled upon by the Committee for fine
particulate matter (PM2.5), a common pollutant in cities worldwide,
is 6% (with a range 2-11%). This means
that the Committee suggests that on average confirms its January 2006 figure of
there will be a 6% increase in all-cause mortality for an increase of 10µg/m3
of PM2.5. This figure was the
basis for the 2007 Air Quality Strategy for
Several responses to the consultation on COMEAP's draft report
criticised the use of this low coefficient (Appendix 1), when more recent and intensive analyses of
the large-scale evidence studies from the
The report had four peer reviews, of which
California EPA's Dr Ostro was the most detailed. He compared the results with five their final estimates are robust to the technique used and their central estimate is always greater than that developed for COMEAP. Dr Ostro, the head of California EPA, has been involved
in the extensive analysis in the COMEAP answers only weakly (their Appendix 2) that they: "adopted a cut-off in early 2006 for published work... this,
unfortunately, excludes an important and influential Evidently, COMEAP's report failed its peer review. COMEAP
has a record of undercounting - in 1998 COMEAP discounted long term (chronic)
effects as too uncertain, in 2001 they accepted that PM probably caused chronic
mortality, but decided the coefficient value of 1% was "most likely". In
January 1996, in an interim report they upped it to 6% after reviews in the EU
fixed on the range 2 to 11 %. The latest
Report quibbles about the endpoints, but essentially accepts the range 2-11% of
2005 as well as sticking to the 6%. Yet already in mid-2006, the range 6% to
17% was established by the COMEAP admit their report is out of date and make no case for
departing from the findings from more thorough and up-to-date analysis in the
---------------------------------------------------------- ** on 18 June: http://www.advisorybodies.doh.gov.uk/comeap/finallongtermeffectsmort2009.htm Committee on the Medical Effects of Air Pollutants, Advisory Committee under the Dept of Health http://ukwin.org.uk/2009/06/22/comeap-report-fails-peer-review ---------------------------------------------------------------------------------------------------------------------------------
ANNEX 2 Particulate Emissions and Health Statement of Evidence to Inquiry June 2009 Professor C. Vyvyan Howard MB. ChB. PhD. FRCPath.
1.3 Particulates and Health: Epidemiological studies worldwide have consistently demonstrated links between ambient particulate matter exposure and adverse health outcomes, including increased rates of respiratory and cardiovascular illness, hospitalizations, and pre-mature mortality [9, 10]. Particles are usually defined by their size, e.g., PM10 and PM2.5, as the mass of particles with aerodynamic diameters less than 10 to 2.5 μm, respectively. Recently, however, interest has also focused on the fraction of ultrafine particles (UFP) with a diameter less than 0.1 μm, which are abundant in number but contribute little to the mass [11, 12]. The UFPs are only usually measured for research purposes and are effectively outside regulatory control. It is these emissions that are the main theme of this evidence. Studies have shown that ultrafine particles are more toxic than larger particles [13-15]. Furthermore, individual particles have been shown to be capable of inducing inflammation and oxidative stress [15], suggesting that particle number concentrations, which are dominated by ultrafine particles, may be more indicative of some potential health impacts than particle mass concentrations. UFP are also important because of their high alveolar deposition fraction, large surface area, ability to induce inflammation, and potential to translocate into the blood circulation system. At a given mass, ultrafine particles (diameter < 0.1 μm) have 102 to 103 times more surface area than particles with diameters in the 0.1- 2.5 μm range and approximately 105 times more surface area than coarse particles (2.5 μm < diameter < 10 μm) [16]. This surface area-to-mass effect may affect the relative toxicity of particles to respiratory systems, in combination with a higher deposition efficiency of ultra fines in the alveolar region (Hughes et al., 1998). Estimates of the number of excess deaths on a global scale due to particle inhalation have been made, and they amount to about 2 million/year of which c.370,000 per year are within the EU. The health effects are not limited to lung injuries. The deaths also include cardiovascular diseases and cancers [17].
1. Maynard,
R. and C. Howard, Eds, Particulate Matter: Properties and Effects upon
Health. 1999, 8. Polichetti, G., et al., Effects of particulate matter (PM10, PM2.5 and PM1) on the cardiovascular system. Toxicology. 9. Pope, A.C., 3rd and D.W. Dockery, Health Effects of Fine Particulate Air Pollution: Lines that Connect. Journal of the Air & Waste Management Association, 2006. 56: p. 709-742. 10. Nawrot, T.S., et al., Stronger associations between daily mortality and fine particulate air pollution in summer than in winter: evidence from a heavily polluted region in western Europe. J Epidemiol Community Health, 2007. 61(2): p. 146-149. 11.
Donaldson, K., X.Y. Li, and 12. Penttinen, P., et al., Number concentration and size of particles in urban air: effects on spirometric lung function in adult asthmatic subjects. Environ Health Perspect, 2001. 109(4): p. 319-23. 13. Wahlin, P., et al., Pronounced decrease of ambient particle number emissions from diesel traffic in Denmark after reduction of the sulphur content in diesel fuel. Atmospheric Environment, 2001. 35(21): p. 3549-3552. 14. Donaldson, K., et al., Combustion-derived nanoparticles: A review of their toxicology following inhalation exposure. Particle and Fibre Toxicology, 2005. 2(1): p. 10. 15. Li, N., et al., Ultrafine particulate pollutants induce oxidative stress and mitochondrial damage. Environ Health Perspect, 2003. 111(4): p. 455-60. 16. Harrison, R., et al., Measurement of number, mass and size distribution of particles in the atmosphere. Philos Trans R Soc A, 2000. 358: p. 2567-2579. 17. Aboh, I.J.K., et al., EDXRF characterisation of elemental contents in PM2.5 in a mediumsized Swedish city dominated by a modern waste incineration plant. X-Ray Spectrometry, 2007. 36(2): p. 104-110.
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Annex 1 Data
from the at <http://pollution.npt.gov.uk>
Annex 2 Proposed Additional Measures for Abating Traffic-related PM10 and NO2
● Speed limit of ~50 mph through and near to urban areas on all roads including motorways Reason - pollution per mile is minimised at ~50 mph; more nearly uniform speeds reduce the amount of congestion which itself gives higher pollution per vehicle-mile
● Taxation to improve the public transport to private car cost ratio Reason - private motoring has become cheaper in real terms since 1997, while public transport has increased. A reversal fits with declared objective of increased social inclusion and equity.
● Giving real force to 'smog' alerts, including incentives or legal measures to reduce vehicle use for the duration Reasons - restricting vehicles entering urban areas on high pollution days can reduce peak levels. 'Smog' actions also help in encouraging the public to reduce overall use of the car • To assist the public to understand the impact of air pollution on their health or the wider environment • To encourage the public to reduce emissions of pollutants within their control (for example by changing their driving habits) Maynard, R.L. & Coster, S.M. 1999. Informing the Public about Air Pollution. In S. T. Holgate, J. M. Samet, H. S. Koren and R. L. Maynard. Air Pollution and Health. p. 1019-1033. Academic Press
● Congestion charging that reduces traffic in congested areas could be helpful. Reason
- much of the pollution is emitted in urban starts and stops, as studies of However,
authorities proposing such schemes outside 15 December 2009 |