Improving air quality Contents

4Evaluating the Government’s approach to air quality

Overview of 2017 plan proposals

35.The Government published its 2017 air quality plan for tackling roadside NO2 concentrations on 26 July 2017.82 The 2017 plan identified 68 local authorities83 (in addition to London and the five cities included in the 2015 plan)84 with NO2 breaches forecast to remain above legal limits unless additional measures are taken.85 Of these, 23 councils were classified as representing “the greatest problem with exceedances projecting beyond the next 3–4 years”.86 These 23 local authorities were directed to carry out feasibility studies on measures that would reduce roadside NO2 concentrations as quickly as possible. They were required to submit draft clean air plans to Government for appraisal by March 2018, to be followed by final plans by December 2018.87

36.From a national point of view, there has been a long-term decline in overall emission levels since 1970 due to a variety of industrial and legislative changes, including the closure of coal power plants.88 However, emissions concentrations in particular areas remain a growing concern.

Figure 1: Trends in UK sulphur dioxide, nitrogen oxides, non-methane volatile organic compounds, ammonia and particulate matter (PM10, PM2.5) emissions 1970–2016

Source: Defra, Emissions of air pollutants in the UK, 1970 to 2016, 15 February 2018

37.The 2017 plan suggested local air quality improvement measures could include: changing road layouts; reducing congestion; encouraging active travel and public transport use; encouraging Ultra Low Emission Vehicle (ULEV) uptake; and retrofitting existing vehicles.89 The plan further proposed the introduction of charging Clean Air Zones, in which vehicle owners would have to pay to enter or move around the designated area if their vehicle did not meet a required emission standard. The plan was clear that charging Clean Air Zones may be established only if others measures were “not sufficient”.90

38.The plan confirmed the Government’s commitment to ending the sale of conventional petrol and diesel cars and vans by 2040 and promised a consultation on a vehicle scrappage scheme. This consultation was published on 22 November 2017.91 The plan further identified a number of existing funding schemes from across Government that could bring air quality benefits, including £1 billion for ULEVs and £1.2 billion associated with the Cycling and Walking Investment Strategy. A wider strategy on air quality is expected in 2018.

Adequacy of the latest plan

39.The 2017 plan received significant criticism for failing to address the magnitude of the challenge. The High Court recently declared it “unlawful” as it did “not contain measures sufficient to ensure substantive compliance” among 45 local authority areas.92 Following the ruling, ClientEarth said that “For the third time in the space of three years, the courts have declared that the Government is failing in its obligation to clean up the air in our towns and cities … The problem was supposed to be cleaned up over eight years ago, and yet successive governments have failed to do enough”.93 The UN Special Rapporteur Baskut Tuncak also criticised the adequacy of the plan, saying:

The new 2017 Air Quality Plan fails to bring the necessary urgency and concrete commitment to improve air quality and reduce emissions of hazardous air pollutants as quickly as possible … The UK has an obligation to protect its population from exposure to health hazards, including air pollution, and to ensure effective remedies when violations occur.94

40.Our evidence highlighted a range of concerns over the plan, including:

41.We asked Ministers what was being done to tackle air quality as quickly as possible, and whether the 2017 plan would deliver on its targets. Dr Coffey defended the speed of action and stressed that Defra was working with “greater urgency” than previously.104 She noted that progress had been slower than hoped among the five cities required to develop clean air strategies under the 2015 plan,105 but hoped Defra could “work with them to make good progress”.106 Dr Coffey acknowledged the importance of protecting public health, and said that whilst Defra had been “focus[ing] [its] efforts on delivery of this NOx plan”, the Department “will be updating [its] clean air strategy” in 2018 and would “work across Government in a co-ordinated way” to deliver it.107

42.We do not believe the latest air quality plan will deliver improvements at a pace and scale proportionate to the size of the challenge. The High Court agrees. Significant improvements to the plan, and to the Government’s wider approach to air quality, are needed to protect the public from toxic air. Defra’s latest plan also focuses largely on achieving legal compliance. Whilst we appreciate the necessity of this, we believe the Government should move from this narrow focus on technical infringements towards a long-term holistic strategy which prioritises environmental and health benefits.

43.Defra’s forthcoming Clean Air Strategy must ensure that public health and environmental protection are at the forefront of Government thinking. The strategy must ensure measures are considered and implemented as a suite of complementary packages rather than in isolation, as has previously been the case with NO2. Improving public transport and providing incentive packages that reduce the need for private vehicles must form a key part of this approach. This national action plan must also ensure air quality policies are properly aligned with public health and climate change goals.

Improvements to monitoring and modelling

44.National and local air quality action plans must be based on the most accurate obtainable data. Witnesses identified several deficiencies in Defra’s current approach to monitoring and modelling that may be hindering more effective action:

45.We asked Ministers whether the current approach to monitoring was adequate, and whether the UK should take a more targeted approach that aims to capture and use greater amounts of local level data. Dr Coffey denied that Defra’s modelling takes insufficient account of local authority data,114 and maintained that that Defra’s approach “fulfils the requirements of how we are required to report all this different data, and [Defra creates a] model on that basis”.115 Regarding the UK’s departure from the EU, she acknowledged that “there are opportunities to reconsider in the future how we get more targeted, focused monitoring and measuring in order to really tackle this issue”.116

46.The current approach to monitoring and modelling is not operating at its full potential and is overly focused on demonstrating compliance. The modelling process is subject to substantial (+/-29%) uncertainty. Defra has directed 23 local authorities to take action, based on a central forecast that 25 of the UK’s 43 reporting zones would otherwise not comply with NO2 limits by 2021. Given the model’s level of uncertainty, however, the low and high scenarios show that as few as 1 or as many as 37 reporting zones could be non-compliant in 2021 if no additional action is taken. Direct measurement of air pollution is much more accurate than estimation and modelling is likely to be. The Government should work with local government to obtain these more accurate measurements. These actions should be supported by real world vehicle emissions testing and support for local authorities to acquire and use technology to monitor live emission levels. More detailed information on the impacts of individual policy interventions is required to enable councils to tackle air quality as efficiently as possible. Improved oversight of local monitoring stations by the responsible bodies is also needed to ensure they are properly sited and functioning.

47.National action frameworks should take greater account of local authority data. The overall approach to air quality monitoring needs to be expanded to capture more useful local data and ensure this is used effectively to inform appropriate policy action. This will require greater investment in existing and emerging local surveillance capabilities. Defra should conduct an evidence review; investigate the steps needed to undertake such an expansion; and develop a pilot project by December 2018. Defra should provide a progress update in response to this Report.

83 Excluding those where Devolved Administrations have policy responsibility

84 Birmingham, Derby, Leeds, Nottingham and Southampton

94 United Nation Human Rights Office of the High Commissioner, Brexit puts UK at risk of worsening pollution and lower environmental standards, UN rights expert warns, September 2017

95 See for example Southwark Council (IAQ0128) and ClientEarth (IAQ0162)

96 Birmingham City Council (IAQ0094) para 3.1, National Centre for Atmospheric Science (IAQ0045) para 19

97 National Centre for Atmospheric Science (IAQ0045) para 19

98 ClientEarth (IAQ0162)

99 Sustrans (IAQ0137), Institute of Air Quality Management (IAQ0062)

100 Policy Connect (IAQ0151) p.1

101 Mayor of Greater Manchester (IAQ0180), Southwark Council (IAQ0128)

102 Royal College of Physicians (RCP) (IAQ0031)

103 ClientEarth (IAQ0162), Greenpeace (IAQ0184), Sandwell Metropolitan Council (IAQ0113), Local Government Association (IAQ0070), City of Cardiff Council (IAQ0150)

104 Q131

105 Q133

106 Q156

107 Q134

108 National Centre for Atmospheric Science (IAQ0045) para 58

109 Royal Academy of Engineering (IAQ0177) p.1

110 Liverpool City Region Combined Authority (IAQ0089) para 3.2

111 City of Cardiff Council (IAQ0150)

113 Cranfield University (IAQ0018)

114 Q175

115 Q165

116 Q202

Published: 15 March 2018