Air quality: a follow up report

Written evidence submitted by the Mayor of London



· The Mayor of London’s Air Quality Strategy includes a range of measures to reduce emissions from the transport network, homes and workplaces that will ensure that in a normal meteorological year, London would comply with PM10 limit values. To provide additional reassurance, Transport for London (TfL) is implementing a £5m Clean Air Fund for targeted measures at hotspots in central London.

· Meeting NO2 limit values is much more challenging and is a problem in many urban areas in the UK. The Government needs to implement national measures such as tax incentives for cleanest vehicles, a NOx abatement certification scheme, scrappage schemes and incentives for vehicle retrofit. The Government also needs to provide local authorities with technical assistance and resources to develop local NO2 abatement measures.

· Emerging evidence shows that the poor performance of recent Euro standards for cars may be responsible in large part for the failure to meet NO2 limit values. The European Commission should commit to reviewing real-world emissions from Euro 6 vehicles as soon as they are on the market and bringing forward changes to the vehicle testing regime if necessary.

· The Government should consider a cross-departmental national air quality strategy that would maximise benefits across different policy areas while addressing potential conflicts. It should also provide clear policy guidance to local authorities.

· Further research is needed into the morbidity impacts of poor air quality as well as the impacts of NO2 pollution. This would provide useful evidence for policy makers at all levels of government.

· To support the localism agenda, air quality awareness-raising campaigns are required at local and national government level, to help communities play their part in air quality management.

· The Mayor welcomes the proposed devolution of public health functions to local authorities, as this could lead to better integration of health and air quality policies. However, devolution must be accompanied by the provision of appropriate resources to local authorities. The Department of Health should also take a lead in promoting the health benefits of air quality improvement measures.

· The Mayor is concerned by proposals in the Localism Bill for EU fines to be passed on to local authorities without corresponding delegation of funds, resources and powers. He is therefore committed to working with Ministers to develop a methodology that ensures that any allocation of fines takes into account resources and responsibilities.



1. The Mayor of London welcomes the opportunity to provide a written submission to the Environmental Audit Committee. The Mayor, along with Environment Director – Kulveer Ranger, is committed to improving air quality in London to protect the health of its citizens.

2. The Mayor is required under the Greater London Act 1999 to prepare an Air Quality Strategy. This must contain the Mayor’s policies and proposals for the implementation in Greater London of the Government’s Air Quality Strategy for England, Scotland, Wales and Northern Ireland, as well as for achieving air quality standards and objectives prescribed in regulations under the Environment Act 1995. The Mayor published his Strategy on 14 December 2010 and implementation is now underway.

3. The Mayor works closely with the Government on joint action to improve air quality in London. This includes a commitment to assist the Government in limit value time extension notifications for both particulate matter (PM10) and nitrogen dioxide (NO2).

Air quality in London


Particulate Matter (PM10)

4. Modelling carried out for the development of the Mayor’s Strategy showed that in 2011, if it was a normal meteorological year, all of London would be compliant with PM10 limit values. However, at a small number of locations in central London along major roads, compliance would be by a small margin.

5. Even at the kerbside of busy roads in central London (with high levels of local emissions) around 40 per cent of PM10 pollution originates from outside London. Significant sources of PM10 within central London include cars (responsible for around a quarter of central London emissions), taxis (also responsible for a quarter) and LGVs (responsible for 10 to 20 per cent). Considerable efforts have been made to reduce the emissions from buses, which now contribute less than 10 percent to PM10 in central London.

6. Around 35 per cent of PM10 emissions in 2008 from road transport in central London came from tyre and brake wear, and this is projected to increase to around 40 per cent in 2011, and 55 per cent in 2015 as exhaust emissions of PM10 are expected to reduce. Emissions of PM10 from car tyre and brake wear are now greater than those from car exhaust emissions and over the next five years, this is also expected to become the case with heavier vehicles such as HGVs and buses. This reflects the fact that measures have been taken to reduce emissions from exhausts but similar reductions have not been achieved for tyre and brake wear emissions, largely because there are no technical improvements affecting tyre and brake wear on the market.

7. Spring 2011 saw some of the highest levels of PM10 concentrations in London for eight years. Analysis from King’s College London suggests that much of the responsible pollution was blown in by easterly winds from continental Europe. During the April air quality episode, around 80 per cent of PM10 pollution at background locations and 60 per cent of pollution at roadside locations was caused by pollution from outside London, including much from continental Europe. The Mayor has raised with the European Commission the need for tighter emissions limits for all Member States, to reduce the amount of transboundary pollution that can have a considerable impact on London’s air quality.

Fine particulate matter (PM2.5)

8. Air quality modelling suggests that almost all of London, including all urban background locations, is already compliant with PM2.5 limit values. It is expected that all locations with relevant public exposure will be compliant with the limit values by their relevant dates. The sources of PM2.5 in central London are very similar to those of PM10. Therefore, many of the measures designed to reduce PM10 concentrations will also address PM2.5.

Nitrogen dioxide (NO2)

9. Modelling for NO2 shows that a number of locations across central and inner London exceed the annual mean NO2 (2010) EU limit value. At some of these locations the limit value is exceeded by a factor of two or more. Concentrations at a number of kerbside or roadside monitoring sites near busy roads also exceed the hourly mean EU limit value, although these short-term concentrations can be strongly influenced by local conditions and sources (e.g. road works and traffic diversions) and are generally confined to locations within a few metres of main roads. This is not untypical for an urban environment and is also observed in other UK and European cities.

10. Emissions from road transport and domestic gas dominated Greater London’s NOx emissions in 2008, contributing 46 per cent and 22 per cent respectively. NOx emissions from commercial gas, industry, airports, and rail are all estimated to contribute around seven to eight per cent of emissions in 2008.

11. NO2 levels have not fallen in recent years as modelling had predicted. This is a problem across major cities in the UK and across the EU. Emerging evidence, including a report by King’s College London, suggests that this may be due to the failure of recent Euro standards to deliver expected reductions of NO2 [1] . A Euro 5 car, for example, emits around five times as much direct NO2 as a fifteen year old car.

12. The Mayor has raised this problem with the European Commission, urging it to review real world emissions from Euro 6 cars as soon as they are on the market. If necessary, changes to the testing regime, including the introduction of a NO2 emissions limit, should be introduced as quickly as possible.

Implementing the Mayor’s Air Quality Strategy

13. The Mayor’s Air Quality Strategy [2] includes a number of measures aimed at reducing emissions from sources within the Mayor’s control, including the transport network, homes and workplaces. It was developed in conjunction with Mayoral strategies for transport, energy and climate change, and the overarching London Plan for strategic development. It builds on measures already underway, including the Low Emission Zone (LEZ) Phases 1 and 2 (Euro III standard for PM for buses, coaches and HGVs), the taxi retrofit programme, smarter travel schemes and improvements to the cycling infrastructure. The main new measures in the Strategy are:

· Age limits for taxis and PHVs from 2012, to remove the oldest, most polluting vehicles from the roads.

· Source London, which will provide the infrastructure to enable 100,000 electric vehicles to be on London’s streets by 2020 if not sooner.

· Putting 300 hybrid buses into service by the end of 2012.

· Retrofitting older buses so that they meet the Euro IV for NOx standard by 2015 (subject to Government funding).

· Including larger vans and minibuses in the LEZ from 3 January 2012, with a Euro 3 standard.

· Tightening the LEZ standard for HGVs, buses and coaches to Euro IV for PM from 3 January 2012.

· Including a NOx standard in the LEZ from 2015.

· Emissions standards for new biomass boilers and CHP.

· Updating construction and demolition best practice guidance and making it Supplementary Planning Guidance.

14. The Strategy also includes local measures for the small number of locations in central London that modelling shows would be at risk of exceeding PM10 limit values in 2011. Already TfL has undertaken a trial of dust suppressant technology in central London, the results of which will be published in the summer. TfL has also ensured that the cleanest buses are routed along roads in air quality hotspots.

15. The Department for Transport (DfT) has recently provided a £5m Clean Air Fund to TfL to extend the local measures approach. Measures that will be implemented through this fund include:

· Measures to reduce vehicle idling, targeting coaches, buses and taxis, and including taxi management, awareness raising, signage and enforcement (where necessary).

· Power cleaning of flyovers, underpasses and other priority locations.

· Extension of dust suppressants (depending on results of trials).

· Retrofit of buses using Upper Thames Street, Marylebone Road and Park Lane.

· Installing green infrastructure, including green walls and vegetated barriers.

· Working with businesses to reduce their air quality footprint.

16. At the end of the year-long programme, TfL will produce a report on the implementation and effectiveness of these measures that will be shared with DfT. It is hoped that this will inform the application of local measures elsewhere in the UK.

What the Mayor’s Strategy will achieve

17. The measures in the Mayor’s Strategy, along with natural fleet turnover is expected to reduce PM10 emissions in central London by around 13 per cent by 2011 and by about a third by 2015, providing increased confidence of long-term compliance with PM10 limit values.

18. Modelling shows that NOx emissions in Greater London will fall from 56,000 tonnes in 2008 to 45,000 tonnes in 2011 and 36,000 tonnes in 2015 as a result of the measures in the Mayor’s Strategy and natural fleet turnover. This amounts to a reduction in NOx emissions across London of 35 per cent by 2015 compared to levels in 2008. However, even this scale of reduction will not prevent some roadside locations in inner London, along with roadside areas near Heathrow Airport, from exceeding NO2 limit values in 2015

The Government’s Strategy for improving air quality

19. Measures to be implemented by the Mayor alone will not be sufficient to meet NO2 limit values by 2015. A number of other urban areas across the UK are also currently exceeding NO2 limit values. It is therefore clear that the Government needs to implement national measures.

20. The Mayor welcomes the Government’s commitment in its Coalition Agreement to ‘work towards European air quality standards’. However, as yet there have been few actions taken to meet NO2 limit values. It is understood that Defra will shortly be consulting on its action plan for NO2. This is an opportunity for the Government to set out clearly the steps that will be taken to reduce NO2 concentrations across the UK, including in London. Measures that the Mayor is seeking to be included in the national action plan include:

· A certification scheme for NOx abatement equipment, to allow Low Emission Zone schemes across the country to include a NOx standard.

· An accompanying national framework for Low Emission Zones, to reduce the administrative burden on local authorities that want to implement schemes.

· Scrappage schemes for LGVs, vans, minibuses and taxis to encourage the uptake of the newest, cleanest vehicles.

· Incentives or grants to encourage NOx retrofit of older heavy duty vehicles.

· Tax incentives to incentivise the uptake of new Euro 6/VI vehicles.

· Amendments to the VED regime so that it recognises air quality emissions as well as CO2 emissions.

· Increased funding for technological development of low-emission vehicles.

· Restructuring of funding for energy efficiency schemes.

21. However, a full review of the Government’s overall air quality strategy is overdue. It is welcome that DfT is increasingly considering air quality impacts in policy decisions. However, other Government departments with a role in air quality management, including DECC and DH, have shown little interest in emission reduction policies.

22. A cross-departmental strategy would help to maximise benefits across different policy objectives (eg. low emission technology, behaviour change, health awareness) while addressing potential conflicts (eg. increased numbers of biomass boilers, perverse incentives for diesel cars).

23. A new strategy would also provide an opportunity to provide guidance to local authorities on local air quality management. The Mayor welcomes the efforts made by Defra to engage with local authorities and encourage the spread of best practice. However, the Government needs to make clear to local authorities the benefits of specific measures and advice on implementation. This would help local decision-makers to identify the most cost-effective policy interventions at a time of scarce resources.

The impacts on health of air pollution

24. The Mayor welcomes the recent assessment of the health impacts of long term exposure to air pollution by the Committee on the Medical Effects of Air Pollution (COMEAP) [3] . This concluded that poor air quality contributed to 29,000 premature deaths in the UK in 2008, which is consistent with the results of a study commissioned by the GLA that estimated that poor air quality in London contributed to around 4,300 deaths in 2008. Such figures are useful when communicating to the public and policy-makers the need for air quality improvement measures.

25. The impact of air quality on premature deaths is, however, only part of the picture. There is still no clear evidence of the health costs that would be avoided by improvements to air quality. The Mayor therefore calls on the Government to undertake further research to assess the morbidity impacts of poor air quality, including costs of treatment and absence from work.

26. The majority of research into the health impacts of poor air quality focuses on fine particulate matter (PM2.5). At a time when all levels of government are being required to address concentrations of NO2, further research needs to be undertaken that would help to justify expenditure on NO2 reduction schemes.

The localism agenda and public health reform

27. Air quality is a highly technical subject and it is sometimes difficult to engage people in the topic. The Mayor therefore supports awareness-raising programmes at all levels of Government that would help raise the profile of air quality as a serious public health issue. This would help communities to get involved in air quality improvement schemes and to register their concerns with local politicians.

28. The Marmot Review [4] highlighted the considerable economic and social benefits that would result from reducing health inequalities. Disadvantaged communities tend to live along major roads which often experience poor air quality, so improving air quality could contribute greatly to reducing health inequalities.

29. The devolution of public health functions to local authorities provides an opportunity for better integration of air quality and health improvement schemes. The inclusion of an air quality public health indicator in the Government’s proposals should help to ensure that local authorities consider air quality improvements in developing health policies, in the same way that air quality is increasingly integrated into transport policies at London borough level, due to the inclusion of air quality advice in guidance for Local Implementation Plans. However, the devolution of public health responsibilities to local authorities must be accompanied by the provision of appropriate resources, including resources for local air quality management.

30. The Localism Bill includes provision for EU fines, including potential air quality fines, to be passed on to local authorities. The Mayor is concerned about the concept of delegating fines without also delegating the funds, resources and powers to take the steps necessary to avoid the fines. He is therefore committed to working with Ministers to develop a methodology that ensures that any allocation of fines takes into account resources and responsibilities.

8 June 2011

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Prepared 17th June 2011