Memorandum submitted by the Environment Agency (EA) (AQ 25)


1. Summary

· Air quality in the UK is not improving sufficiently quickly to meet UK air quality objectives within the required timescales.

· There have been significant reductions in emissions of the key air pollutants through the Environment Agency's regulation of installations under IPPC/EPR.

· There is an extensive network of air quality monitors in the UK but the modelling methods used to predict pollution impacts sometimes do not represent accurately the impacts of industrial processes.

· Some effects of morbidity from air pollution are not included in the UK's cost-benefit methodology. The cost of effects on the natural environment are also not included. This may lead to the impacts of air pollution on wildlife being given inadequate attention.

· We believe the measures identified as cost beneficial in the UK's Air Quality Strategy 2007 should be implemented. The National Ammonia Reduction Strategy that was also proposed should be put in place to protect sensitive habitats.

· The Department for Transport's (DfT) Sustainable Development Framework for Transport Planning needs to give more weight to air quality in its matrix of challenges to ensure that transport planning delivers its contribution to improving the UK's air quality.

· Transport and spatial planners should use the range of measures available to them to improve air quality and reduce its effects on people's health and sensitive ecological systems.

2. Introduction

2.1 There is growing evidence that the mechanisms for delivering acceptable air quality are failing in a number of areas, particularly the measures related to transport. The UK has had to seek additional time for compliance with the EU limit values on particulates. Improved monitoring and assessment by local authorities has led to the designation of more Air Quality Management Areas for nitrogen dioxide and the UK will be seeking additional time for compliance with the EU limit values on nitrogen dioxide. Whilst there have been gradual reductions in the national emission of nitrogen oxides the complex atmospheric chemistry of these compounds has led to increasing levels of ozone in some urban areas. Peak levels of ozone across the UK are generally declining but background levels are increasing, a situation which has implications both for human health and agricultural productivity.

2.2 The Environment Agency regulates the release of air pollutants in England and Wales from approximately 2,800 large and more complex industrial installations e.g power stations, oil refineries and chemical plants. We also regulate facilities where waste is handled, stored, treated or disposed of, such as landfills, waste transfer and treatment facilities, as well as intensive livestock units and food manufacturing factories. We do this under the Environmental Permitting Regulations (2007).

2.3 Overall, the Environment Agency has helped to bring about significant reductions in emissions of a number of key pollutants through the application of the IPPC/EPR permitting regime. Releases of sulphur dioxide from regulated installations have reduced by 60 per cent from a 2000 baseline; particulate matter (PM10) by 44 per cent and nitrogen oxides by 15 per cent The value of health benefits from the reductions in emissions of sulphur dioxide, nitrogen oxides and particulate matter from installations we regulate is estimated to have totalled £1,100 million between 1990 and 2005.

3. Monitoring air quality in England and Wales

3.1 There is an extensive network of monitors in the UK that monitor levels of nitrogen dioxide, ozone, particulates (PM10 and PM2.5) and sulphur dioxide in the air. Around 400 of these are funded by Defra and the devolved administrations. The largest of the monitoring networks, with 130 sites, is the Automatic Urban and Rural Network (AURN). In addition to the national networks there are many sites operated by local authorities as part of their Local Air Quality Management activities. Some of these sites are also affiliated with, and provide high quality data to, the national networks.

3.2 Modelling is a valuable tool for assessing levels of air pollutants provided that reliable data on emissions are available. Defra use modelling to supplement their monitoring of air quality in order to predict the levels of air pollution in the UK. However, all models involve degrees of uncertainty and there have been instances where monitoring on the ground has shown that models have over- or under-predicted ground level concentrations arising from point sources. Potentially, this could lead to exceedences of air quality standards being missed or regulatory effort expended unnecessarily on non-existent exceedences.

3.3 The Environment Agency carries out occasional monitoring campaigns in the vicinity of installations we regulate as part of our pollution control responsibilities. Usually these are for a short period of time (3 - 6 months).

3.4 The monitoring of emissions from installations we regulate under environmental permitting is the responsibility of the operator. The pollutants monitored, the techniques used and the frequency of monitoring are prescribed by the permit. This may need to reflect the requirements of EU legislation such as the Waste Incineration Directive. Any monitoring must comply with MCERTS requirements where applicable and the results are submitted to our local offices where they are made publicly available. MCERTS is the Environment Agency's Monitoring Certification Scheme. It provides the framework for businesses to meet our quality requirements. If operators comply with MCERTS we can have confidence in the monitoring of emissions to the environment. MCERTS accreditation is managed by the UK Accreditation Service (UKAS). Data on the emissions of key pollutants from installations we regulate are published by us in our Pollution Inventory which is publicly available.

3.5 We are developing a new capability to coordinate and monitor air quality in the event of emergency incidents, for example the Buncefield oil terminal fire. We are working with partners to test the new arrangements and expect them to be fully operational in 2010.

4. Has the Government fully understood and identified the health and environmental risks caused by poor air quality?

4.1 The UK Air Quality Strategy (AQS) has generally identified the pollutants that are likely to have the greatest health effects and has set controls for these. It has taken steps in the right direction by also including controls for PM2.5. However, the mechanism for particulate toxicity, especially involving ultra fine particles is not fully understood. The Environment Agency believes there is merit in the World Health Organisation, the European Union, government and academia investigating further the effects of particles smaller than PM2.5 ,for example PM1 and PM0.1 , in order to develop reliable dose-response relationships which can then be used as a basis for setting standards.

4.2 Unlike the European Commission's Clean Air For Europe (Café) programme the Government's cost-benefit methodology for assessing air quality policies and measures does not fully include morbidity effects such as chronic bronchitis, restricted activity days (RADs), respiratory medication use and lower respiratory symptoms. This risks leading to a substantial underestimate of the costs of the effect of poor air quality on morbidity.

4.3 The UK AQS focuses on human health effects as there is currently no method to cost the effects of poor air quality on the natural environment. The impacts of air pollution may therefore be underestimated.

5. The air quality delivery chain

5.1 The delivery chain through which declared policies for the improvement of air quality are translated into actual improvements on the ground is complicated by the number of bodies whose activities can have an impact on air quality. Local authorities, Government departments including Defra, DfT, DCLG, BIS, DECC and the Environment Agency all have roles.

5.2 A key example is the relationship between transport planning and local air quality control. If air quality objectives are unlikely to be met local authorities are required to declare an Air Quality Management Area (AQMA) and develop an Air Quality Action Plan (AQAP) to work towards meeting the objectives. In about 95 per cent of cases road transport emissions are the main reason for local authorities declaring AQMAs. Many of the roads contributing to pollution hotspots are the responsibility of DfT and the Highways Agency and in the past neither body has given a high priority to air quality issues in their plans. We have particular concerns that this situation may continue within the DfT's recent Sustainable Development Framework for Transport Planning (see point 6.4 below). We have further concerns that the guidance for the 3rd round of Local Transport Plans (LTPs) does not specifically require prioritisation for dealing with air quality issues.

5.3 The DfT is also responsible for vehicle standards and implements EU requirements via type approval procedures. These have not always produced the results intended. For example, regenerative traps for particulates have increased emissions of primary nitrogen dioxide by diesel-fuelled vehicles.

5.4 In some instances policies in one part of the delivery chain could be in direct conflict with those elsewhere. For instance, the widespread introduction of biomass burners may help deliver renewable energy targets but, if they are not designed to the highest air quality emission standards or are poorly operated, they could have an adverse impact on air quality.

6. Steps to ensure air quality targets will be met

6.1 Local authorities do not have the powers to ensure that actions identified in their Air Quality Action Plans are implemented. In some areas we are aware that actions which were identified for other parties up to 10 years ago have still not been delivered.

6.2 If air quality targets are to be met, we believe the Government and devolved administrations should implement as quickly as possible the measures identified as cost beneficial in the UK AQS, published in July 2007. The 'exposure reduction' concept for particulates (by which general levels, including background, are reduced instead of focussing on hotspots) should be put into practice as soon as is practicable. This provides the greatest benefit to the population as a whole by reducing their exposure to fine particles.

6.3 Transport planning policies alone will not be sufficient to address the problem of vehicle pollution in urban areas. Additional measures such as higher vehicle standards, work on hybrid vehicles and the enforcement of vehicle emission regulations are all needed The effect on air quality of the scrappage schemes for the most polluting vehicles needs further investigation. Measures to regulate traffic along the worst polluted routes using established traffic management techniques, and the establishment of low emission zones, may also be appropriate.

6.4 We believe that DfT's recent Sustainable Development Framework for Transport Planning needs to give more weight to air quality in its matrix of 'challenges' since air quality is currently not given sufficient consideration. We believe a 'challenge' that specifically relates to the human health effects of traffic-related air pollution should be included under the goal of "Improve quality of life". The goal to "contribute to better safety, security and health" does have the 'challenge' of "reducing the social and economic costs of transport to public health, including air quality impacts" but we do not consider this to be sufficiently strong to achieve the necessary outcome.

6.5 Where people live, work, shop and undertake leisure activities, and how they get there, has a crucial influence on air quality. Decisions on such matters may be taken at local, regional or national level with major projects now coming under the aegis of the Infrastructure Planning Commission. With few exceptions, air quality is not usually seen as a key issue when such decisions are taken. Any proposed major infrastructure development should be subjected to a detailed air quality impact assessment.

6.6 We are a statutory or recommended consultee on individual development proposals and strategic environmental assessments of local and regional spatial and transport plans. If air quality is to be safeguarded, planners working at both a regional and local level should use whatever opportunities arise to reduce the effects of poor air quality. Planning policies have a fundamental effect on the generation and dispersion of air pollution and the exposure of local populations to poor air quality. The Environment Agency has proposed a number of key, high-level air quality objectives for Regional Planning Bodies and Local Authorities that we would like to see implemented. These are that transport and spatial planning:

· should aim to achieve improvements in local air quality and public health;

· should seek to minimise the adverse air quality impact of all new transport schemes and developments, particularly where there may be cumulative impacts from multiple developments;

· should pursue the sustainability appraisals for regional spatial strategies, local development documents and the strategic environmental assessments for local transport plans contain an appropriate assessment for air quality; and

· should ensure that all proposed developments which could adversely affect air quality have received an appropriate assessment of air quality effects and a health impact assessment.

6.7 In addition the Environment Agency believes that:

· all local planning documents should include policies which address air quality if relevant;

· the guidance developed by Environmental Protection UK on "Development Control - Planning for Air Quality" should be used in the planning process;

· the techniques described in the "London Best Practice Guidance: The control of dust and emissions from construction and demolition" should be a condition of development where relevant;

· planning policies in local development frameworks and supplementary planning documents should require travel plans for major developments and use the DfT guidance on this matter; and

· Low Emission Strategies should be used to ensure new developments are designed with the lowest environmental impact possible.

6.8 The impact of ammonia emissions on natural habitats is an issue of concern. Currently 60 per cent of sensitive habitats exceed the critical load for nutrient nitrogen (Review of Transboundary Air Pollution, Draft Report ) and ammonia is a major source of this nutrient. Agricultural activities are the principal source of this pollutant but only a small fraction of national ammonia emissions comes under current regulatory control. The Environment Agency agrees with the need for a national ammonia reduction strategy, as proposed in the UK's AQS 2007, but we are concerned that there are still no definite proposals.

6.9 The Local Air Quality Management regime should include objectives for the protection of vegetation.


7. Other matters

7.1 The Department for Transport consulted on the proposals to expand Heathrow Airport. The Environment Agency concluded that the evidence presented was not sufficiently robust to be sure that the proposed development will not lead to a breach in the long-term EU air quality limit value for nitrogen dioxide. However the decision has been made to go ahead with expansion on the basis that additional flights would only be allowed if air quality limit values had already been complied with.

7.2 The Secretary of State for Transport proposed that the Environment Agency should have a role in assessing and monitoring air quality around the airport to ensure, along with other partners, that the air quality limit values will be met. The exact form of the Environment Agency's role is still under discussion with government but is likely to fall into three main areas:

· Coordination of air quality monitoring and modelling to assess compliance with air quality limits;

· Auditing of studies to assess the extent to which future capacity can be released; and

· Action in the event that limit values are, or are likely to be, breached.

7.3 We have developed consistent and auditable techniques for the assessment of impacts from major sources and believe that there is scope to apply similar approaches to air quality impact assessments undertaken for major developments such as airports.


16 December 2009