3 Areas for action
The priority given by Defra
23. Under the previous 'public service agreement'
system of departmental targets, DfT and Defra were given a joint
responsibility for achieving air quality targets. Government priorities
and commitments, and accountability against these, is now managed
through departmental business plans.
24. Business plans have been published by all
government departments. They are the key tool of the Government
for making departments accountable for implementing the reforms
set out in the Coalition Agreement, and give the public the opportunity
to check that departments are meeting their commitments. Business
plans include key indicators against which Government will publish
data to show the cost and impact of public services and departmental
activities. As explained to us by the Minister for Government
Policy in a previous inquiry, they are also the means by which
Minsters are internally held to account within Government.[34]
25. There are no air quality actions for Defra
or DfT in their departmental business plans. The omission is surprising
in light of the Government's statement in its response last year
to our predecessor Committee that it considered 'more needs to
be achieved' and the commitment in the Coalition Programme for
Government to work towards full compliance with the EU air quality
standards.[35] When we
asked the Minster why air quality had not been included in the
Defra business plan he told us that:[36]
The fact that air quality is not
explicitly mentioned in the current business plan, published in
May 2011, does not in any way reflect a lack of importance we
attach to this area, especially since it is a cross government,
coalition commitment to work towards full compliance with EU air
quality standards; this remains a major driver for action which
would not be increased if air quality were covered in the Defra
Business Plan itself. In addition our Natural Environment White
Paper sets out more specific commitments on air quality including
our consultation on plans for the achievement of NO2
limit values, investigation of low emission zones and improving
arrangements for local air quality management and delivery. This,
with the coalition commitment, will continue to ensure that air
quality is given priority across government policies.
26. The fact that air quality is not included
in any of these departmental business plans is symptomatic of
its low priority. We are not satisfied that air quality's inclusion
in the Natural Environment White Paper will provide sufficient
drive to deliver the EU limit values targets. In particular, we
fail to see how the Government's consultation on NO2
limit values can provide a solution, because its proposals for
action sit alongside explicit acceptance that targets will not
be achieved. In any case neither of these processes would provide
the transparency and accountability that inclusion in the business
plans would provide, and that the issues clearly merit. Defra
must include progress towards achieving EU air quality targets
for particulate matter and nitrogen dioxide in its business plan
at the next update. If these targets are not included, we expect
the Minster for Government Policy to report on why this is the
case and what discussions he has had with Defra on this during
his review of their business plan.
Joined up policy
27. The Government and the devolved administrations
published the latest Air Quality Strategy in 2007.[37]
This recognised that air pollution has wide-ranging environmental
impacts, from loss of biodiversity and reduced crop yields to
a potential contribution to climate change, and that air quality
is affected by a wide range of policy areas. The spread of causes
and effects of poor air quality across departments means it is
vitally important that thinking on this is joined-up across Government.
Our predecessors' report found that links between departments
required improvement. Defra and DfT had quarterly liaison meetings
between their officials, and the Cabinet Office Strategy Unit
included air pollution in its analysis of the wider costs of transport
in English urban areas, but consistently joined-up policy across
all relevant departments was lacking. It was essential that DECC,
DCLG, DoH and the Treasury also engaged and prioritised air quality
issues, which they appeared to have been somewhat reluctant to
do.[38]
28. One area in particular where air quality
needs to be linked with other policy is on climate change. There
are benefits of carbon emissions reduction policies for both climate
change and air quality, for example in the promotion of electric
vehicles and other new technologies that reduce both greenhouse
gas emissions and air pollution. In these cases a coherent and
consistent regulatory base is essential to drive innovation and
instil investor confidence in developing products and services.
For this to happen a clear message, one that involves engagement
from Defra, BIS, DfT and DECC, must be developed. At the same
time there can be conflicts, for example in encouraging diesel
vehicles over petrol: Diesel cars are generally more energy efficient
and produce less carbon dioxide per mile than a petrol equivalent,
but they can also produce up to 20 times as much PM10 emissions.[39]
Environmental Protection UK (EPUK) wanted DECC to concentrate
on securing maximum policy benefits from their renewable policies
rather than simply focusing on a narrow carbon reduction remit.[40]
The Environmental Research Group notes that climate change targets
- an 80% reduction in CO2 equivalent emissions by 2050 - could
generate major improvements in air quality and public health if
co-benefits are identified at an early stage.[41]
However, Defra told us that inter-department discussion only occurs
on an 'ad hoc' case by case basis at official level, and that
such discussions are undertaken in the context of other local
environmental matters, such as noise pollution. There is no formal
structure at a Ministerial level connecting policy decisions with
air quality issues and it is difficult to see any formal structures
that join up thinking at official level.[42]
The Local Government Group told us:
[...]it is difficult to comment on the effectiveness
of the Government's strategy due to a lack of transparency about
what the strategy is. We are aware of various pieces of work
on air quality being undertaken, but an up-to-date, coherent strategy
taking account of all measures and planned action across government
departments does not appear to exist, at least as far as we are
aware. The most recent publicly available UK Air Quality Strategy
was published in 2007 and is widely considered not to be fit for
purpose. The LG Group has raised this with the Government, who
have informed us that its application to the European Commission
for a time extension for nitrogen dioxide limit values will in
effect act as its strategy. [43]
29. A lack of joined-up thinking
between departments is especially worrying while the Government
is undertaking the 'Red Tape Challenge' to reduce regulation.
We recognise that the existing legal framework is somewhat disjointed
and could benefit from reorganisation. Client Earth told us that
it should be consolidated to clarify the legal duties and powers
of central government, local authorities and devolved administrations.[44]
However, this must be done carefully. Air quality could be affected
by changes to regulations in a range of policy areas and any impacts
to air quality must be explored before regulations are cut.
30. The Government should produce
an action plan setting out how air quality is to be considered
in policy development across Government, to encourage co-benefits
with other policies, to discourage policy conflicts and to assess
the impacts of consolidating air quality regulations. It should
establish a ministerial group to oversee and ensure adherence
to the action plan. The Cabinet Office, because of its role in
directing policy across departments, should take the lead in implementing
this.
Support for local authorities
31. The Government's response to our predecessors'
report acknowledged that more needed to be done to tackle poor
air quality. But, where that involves local authority action the
approach would be to encourage and guide local authorities rather
than require particular actions. This is the theme of the localism
agenda. The response promised that:
- Local authorities would be
encouraged to communicate locally action on air pollution but
leaving the means to local discretion;[45]
- Local authorities would be able to set transport
policies and priorities locally, while those transport projects
which are assessed centrally would follow an enhanced Green Book
methodology;[46]
- Government would ensure local authorities have
the 'tools' to address air quality, without 'unnecessary form-filling
and bureaucracy'[47];
- Rather than develop a 'national framework for
low emissions zones', as the Committee recommended, local authorities
would decide on these.[48]
32. The response said that the new National Planning
Policy Framework (NPPF) would address 'environmental and social
priorities' as well as economic factors and that DCLG would be
reviewing how local authorities' role on air quality could be
maintained under the localism agenda.[49]
We will explore these planning issues in more detail in our inquiry
into the NPPF. It also envisaged that public health reforms would
give local authority-based Directors of Public Health enhanced
powers and ring-fenced budgets to co-ordinate local programmes
aimed at improving health and wellbeing, which could address air
quality issues at local level.[50]
33. Under the Environment Act 1995, local authorities
have a duty to work towards improved air quality. Local authorities
are required to carry out regular reviews and assessments of air
quality in their area against the objectives in the Defra Air
Quality Strategy. Where any of these objectives are not being
achieved, authorities must designate air quality management areas
and prepare and implement remedial action plans to tackle the
problem. Once an air quality action plan has been set, local authorities
must report to Defra or the relevant devolved administration on
delivery against this action plan.
34. As well as their specific role to protect
the environment, local authorities are responsible for other functions
that may affect air quality, and local air quality improvements
are often an indirect result of measures to tackle congestion,
road safety or employment. Good cooperation between transport,
regulation, air quality, climate change, public health and spatial
planning departments, as well as with partner organisations, is
essential to ensure a strategic approach to improving the quality
of life for those living near to busy roads and junctions.
35. In its guidance on Local Transport Plans,
DfT expects authorities to consider their contribution to national
transport goals as over-arching priorities for their local transport
plans. These include reducing social and economic costs of transport
to public health, including air quality impacts, in line with
EU obligations. DfT also provides guidance on assessing the impact
of transport schemes on local air quality.[51]
It requires the impacts on air quality to be appraised and monetised.
36. The evidence we have received suggest that
there is no longer a significant issue about providing local authorities
with the guidance to deliver local air quality management. Instead,
the problem now lies in empowering local authority environmental
health officers with the levers to deliver change, and putting
the air quality issue on the agenda of key decision makers at
the highest levels of local government. The Government's review
of Local Air Quality Management found that local politicians tend
to accord air quality a low priority.[52]
the Healthy Air Campaign told us that raising air quality as a
priority is particularly difficult while many local authorities
have to cut their budgets and are reducing their environmental
health departments.[53]
The Local Government Group told us that Government needs to engage
actively in promoting a clear message about the impacts of poor
air quality with those in key decision making positions in local
authorities.[54]
37. The Government must engage
with local authority leaders to set out clearly the risks of failing
to act on improving air quality. It must help local authorities
to join up thinking across their departments to help identify
where conflicts arise and where improvements can be made. This
needs to be done in a way that influences decisions taken by local
enterprise partnerships and planning authorities and takes account
of new public health reforms. Government engagement with local
authorities also needs to address establishing a national framework
for low emissions zones (paragraph 38) and a public awareness
campaign (paragraph 43).
38. The Localism Bill would provide a means by
which EU fines from failure to comply with air quality targets
could be passed on from central government to local authorities.
However, there is ambiguity about how the responsibility for delivering
air quality improvements is divided between local authorities
and central government. The LG Group have called for clearer understanding
between central and local governments about which levers each
can use to deliver change. Councillor Richard Kemp told us:
[...]at the moment it seems to me there is a lot
that has just been devolved to local government, but frankly,
if you are Warrington Council and you have two major motorways
intersecting in the middle of your town, and you have another
one on the fringe and you are not far from Manchester Airport,
there are some things that you could and should do but there are
some things that are clearly outside your control. We need to
split who should be doing what so there is clarity between us.
If we did that, then we could come to local agreements, council
by council. [55]
39. A blanket approach of transferring
EU fines to those local authorities failing to meet air quality
targets would be unfair. The causes of poor air quality are often
beyond an individual authority's control. Any fines must take
account of contributing sources of pollution from beyond a local
authority's boundary and policy areas beyond its control. Fines
should also take account of a local authority's failure to act
in improving air quality. Transferring EU fines to local authorities
might help to deliver air quality improvements but, if it pursues
this, the Government must establish a mechanism where it only
passes on a share of fines proportionate to a local authority's
ability to influence local air quality. Many of the causes of
poor air quality arise from policies for which central Government
is responsible. Otherwise, the process is likely to result in
lengthy and costly legal battles, and risks being seen simply
as cutting local government financial support. Before it does
this, the Government needs to assess the resource requirements
of individual local authorities, depending on their circumstances,
to be able to deal efficiently with the air quality challenge
at a time of squeezed budgets.
Health reforms
40. The Health and Social Care Bill envisages
directors of public health being located within local authorities,
having new public health improvement and health protection duties.
An air quality indicator was included in the draft public health
outcomes framework.[56]
The LG Group argued that it is useful to have consistent baseline
evidence to allow councils to compare performance, and that the
new framework for health, social care and wellbeing could lessen
reporting burdens and ensure all partners are working together
on the same priorities.[57]
41. James Grugeon, from the Healthy Air Campaign,
told the committee that the transfer of public health duties to
local authorities would also provide a significant opportunity
to join up action between public health and environmental health
departments to tackle air quality problems, to link up funding
and potentially create greater resources for local authorities
to tackle air pollution.[58]
Councillor Richard Kemp recognised the greater influence that
public health authorities may have in steering other areas of
local policy:[59]
[...] we are going to make sure that public health
is an important part of the work that we do within local government,
not necessarily because they are a big department, but because
they move into local government they are able to challenge our
housing policy, our transport policy, our education policy, what
we do in our parks, what we do in our youth clubs, and so on.
There is a real thirst from most of the professionals for the
move over.
As our witnesses noted, this will require direction
at a national level with engagement from Department of Health.
The Government
must take full advantage of public health reforms to improve local
authorities' abilities to improve air quality. In particular the
Government should introduce indicators to measure public health
improvements from better air quality in its public health reforms.
Low emission zones
42. The European Union plays a key role in regulating
pollution from road vehicles by setting European wide fuel standards
and emission limits. Significant emission reductions from road
vehicles have been achieved by fuel-based standards. The introduction
of unleaded petrol and changes to the sulphur content of fuel
led to a 99% reduction in lead emissions, a 96% reduction in sulphur
dioxide.[60] The use
of duty differentials incentivised rapid uptake of these cleaner
fuels. Fuel standards, however, cannot be used to control NO2
or PM10 emissions in the same way. Emission and fuel standards
work to reduce emissions of air pollutants from vehicle tail pipes.
Recent research, however, shows that vehicle brakes and tyres
emit at least as much particulate matter.[61]
These types of emissions remain unregulated.
43. Retrofitting is a fast-acting solution to
minimise particulate emissions from diesel exhausts, and to make
older vehicle engines meet current and future emission standards.
The technology works by capturing these particles or pollutants.
Government incentives for retrofitting exhaust systems are limited
to the Reduced Pollution Certificate scheme, which offers reductions
in Vehicle Excise Duty for lorries and buses that meet new emissions
standards before they become mandatory. In its application for
an extension to meeting the PM10 EU limit value deadline until
2011, the Government concluded that a mass diesel retrofitting
programme for all polluting road vehicles would not be cost beneficial
compared to a partial exemption which would provide additional
time to enable planned measures to come into effect.[62]
Several other EU countries offer direct incentives to encourage
retrofitting for diesel engines. France, for example, offers a
grant for the fitting of particulate filters on buses and the
Netherlands provides subsidies for the fitting of particulate
filters to heavy-duty vehicles.
44. Vehicle emission standards ('EURO standards')
have been effective in reducing air pollution from road vehicles,
including PM10 and NOX emissions. However, the reductions
achieved by EURO standards have been more modest than those resulting
from fuel standards. This is because, even though they are mandatory
for new vehicles, they do not apply to vehicles already on the
roads. Furthermore, many NOX abatement technologies
used to achieve EURO emissions levels fail to work efficiently
in urban driving cycles, and so, in larger cities, the emissions
reductions have not been as good as predicted. Recent data on
emissions of regulated pollutants shows that there is still capacity
for EURO standards to reduce emissions of NOX and particulate
matter from all vehicles further, particularly from diesel vehicles[63].
The European Union is introducing further EURO standards on pollutant
emissions from both light and heavy-duty road vehicles, particularly
for emissions of NOX and particulate matter. As compliance
with some of these standards will not be mandatory for several
years, the impacts will not be seen until 2015 at the earliest.
45. Policies to encourage the use of cleaner
vehicles include car scrappage schemes, tax incentives and low
emission zones (LEZs), which deter the most polluting vehicles
from entering a particular area. In Germany, there is a national
framework for low emission zones, which facilitates local implementation
of low emission zones, and, importantly, provides certainty to
businesses that their fleets will be compliant with all emission
zones within the country. There is no such national legislative
framework in the UK. The Government response to the previous report
noted that rather than develop a national framework for LEZs,
local authorities would be able to decide individually on implementing
these.[64] Since the
Government response was published, Defra have conducted an impact
assessment of the costs and benefits that such a scheme would
entail. When account is taken of the costs of air pollution, this
estimates a net monetary benefit for implementing a national framework.
The Environmental Industries Commission regards a national framework
for LEZs as a key driver in delivering 'green' economic growth.[65]
46. In developing the London LEZ, Transport
for London worked with authorities such as the Vehicle and Operator
Services Agency and the Vehicle Certification Agency to develop
certification of approved retrofit technologies. This certification
could form the basis of a nationally recognised standard, which
local authorities could use as part of their own LEZ schemes under
a national framework. This would make it much easier for a local
authority to establish a local LEZ and to prescribe what standard
of vehicle would be allowed to enter, provided that they operate
within the parameters of the national framework. However, lessons
must be learnt from the failure of EURO standards to deliver the
anticipated emissions reductions. Approved technologies for an
LEZ must be proven to work effectively under the driving conditions
of particular LEZ areas. As
a matter of urgency, the Government must set up a national framework
for low emission zones to establish a recognised standard for
emissions and vehicle identification, supported by a national
certification scheme of retrofit technologies.
Increase public awareness
47. The public are also a key player in the delivery
of cleaner air. They could benefit from better understanding the
health impacts associated with air pollution and what action they
can take to reduce these impacts. In many aspects of their lives,
people can take action to reduce the impact that air pollution
has on their own health. Despite this, there remains a lack of
clarity in how the Government communicates the health risks of
air pollution for individuals, both in terms of differing levels
of personal exposure to pollutants, and how susceptible people
are to the effects of pollution. The Air Quality Management Resource
Centre notes that Government reports have identified the health
impacts of poor air quality in the UK as being almost twice those
of physical inactivity (£20 billion a year compared to £10.7
billion) yet it fails to receive the same level of attention within
medical and media circles.[66]
Similarly, some studies have suggested that the cardiovascular
risk of exposure to traffic pollution may well be similar to that
from passive smoking, though it does not get comparable attention.[67]
48. EPUK say Government documents and statements
have consistently downplayed the health impacts of air pollution.
Often repeated quotes from the current UK Air Quality Strategy
include '99% of the UK meets European air quality standards'.[68]
This statistic is for geographical area rather than the percentage
of the population affected - the 1% of the UK that does not meet
the standards includes some of our most densely populated urban
areas, whilst much of the 99% that is 'clean' is sparsely populated
countryside. Another commonly repeated statistic is that 'air
pollution is currently estimated to reduce the life expectancy
of every person in the UK by an average of 7-8 months'. This suggests
that the impacts are evenly spread across the UK population, when
in fact the impacts are concentrated in particular areas and the
health impacts for those that live and work there are actually
severe.
49. The Government response to our predecessors'
report was that there would be no national campaign on air quality.
The Government's own review of Local Air Quality Management for
Defra reported that:
We would like to see the development of simpler and
clearer messages in three areas in particular. First, while recognising
that it is important not to prompt unjustified public alarm, we
consider that the health impacts of poor air quality need to be
communicated much more effectively. In particular, for communication
purposes, we would like to see less reliance on measurement in
terms of reduced average life expectancy, and the development
and publication of new comparative measures which convey the health
impacts in a way which is more meaningful to a non-expert audience.
[69]
50. In June 2011 COMEAP reported on a review
it was asked to undertake by Defra on the Air Quality Index, which
is used to communicate information about real-time and short-term
forecast levels of outdoor air pollution. The review found that
there is both a lack of awareness amongst the public regarding
the links between air pollution and ill-health, and a lack of
understanding concerning existing air quality information. It
recommended that greater public awareness be achieved through
the updating of the Air Quality Index.[70]
51. The Government already supports communications
expenditure which helps to raise awareness about air quality.
This includes systems to inform members of the public, including
vulnerable groups such as children and the elderly, about air
quality risks. However this information could be used to target
not only those affected by poor air quality but also those able
to influence its creation. At our evidence session on 8 June all
our witnesses called for a public awareness campaign on the health
effects of poor air quality. They believed that it would be the
most effective thing the Government could do to tackle the problem.
However, there appears to be reluctance in Government because
of measures to reduce spending on public awareness campaigns more
generally. The Minster told us the Government had decided in March
that only essential expenditure on new advertising and marketing
would be allowed and that central approval would be required for
government campaign spending over £100,000. He noted that:[71]
We are very interested in the Healthy Air Campaign
sponsored by Environmental Protection UK and launched in July
2011, and are keen to explore ways of working with them to support
their campaign and to promote awareness through their activities.
52. The costs to society from
poor air quality are on a par with those from smoking and obesity.
A public awareness campaign would be the single most important
tool in improving air quality. It should be used to inform people
about the positive action they could take to reduce emissions
and their exposure. It should also be used to provide an impetus
for action in local authorities to deliver more joined up thinking
on achieving air quality targets. The Government should provide
Defra with the means to launch such a campaign. This could be
done in collaboration with existing campaigning groups, to ensure
maximum cost effectiveness and coverage.
34 Environmental Audit Committee, Fourth Report of
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response ,HC 877 Back
35
Defra, Government response to the Environmental Audit Committee
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36
Ev 48 Back
37
Defra, Air Quality Strategy for England, Scotland, Wales and
Northern Ireland, 2007 Back
38
Environmental Audit Committee, Fifth Report of Session 2009-10,
Air Quality, HC 229 Back
39
HC Deb, 3 Oct 2011, col 1388W Back
40
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41
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42
Q 86 Back
43
Ev 35 Back
44
Ev w 43 Back
45
Cm (2010-12) 7966, para 47 Back
46
ibid Back
47
ibid Back
48
Cm (2010-12) 7966, paras 67, 72 Back
49
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50
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51
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52
Defra, Review of Local Air Quality Management, 2010 Back
53
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54
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55
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56
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57
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58
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59
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60
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61
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62
NAO, Air quality: Briefing for the Environmental Audit Committee,
2009 Back
63
ibid Back
64
Cm7966, November 2010, paras 67, 72 Back
65
Environmental Industries Commission, Manifesto to Government,
2011 Back
66
HC (2009-10) 229 Back
67
HC (2009-10) 229 Back
68
Ev 31 Back
69
Defra, Review of Local Air Quality Management, 2010 Back
70
COMEAP, Review of Air Quality Index, 2011 Back
71
Ev 47 Back
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