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:
- Speed of action: many evidence submissions argued the plan was too slow and would not deliver air quality improvements in the shortest time possible.95
- Prioritisation of compliance over public and environmental health: several stakeholders felt the 2017 plan failed to advance a more joined-up strategy which moved away from narrowly demonstrating compliance with EU legislation and prioritised the protection of public and environmental health instead.96 The National Centre for Atmospheric Science cautioned that “too great a focus on a rather narrow set of technical infringements may result in national policy losing sight of the much more important aim of improving air quality wherever possible for the whole population”.97
- Lack of clarity: witnesses said the 2017 plan offered unclear messaging, contained contradictions between technical findings and policy recommendations, and offered insufficient detail on the operation and local impact of charging zones.98
- Insufficient emphasis on public transport: others were sceptical about the Government’s overall approach to air quality, highlighting the Government’s reliance on technological improvements and new emissions standards to deliver gradual improvements when these have failed to deliver the expected benefits in the past.99 Policy Connect argued that reducing traffic would be the fastest way to cut air pollution, and said the Government needed to focus on making public transport “accessible and affordable”.100
- Inadequate support for local authorities: many councils believed that the level of funding, guidance and technical support available to local authorities fell far short of what was needed to tackle air quality effectively.101
- Joined-up action: existing mechanisms to encourage Departments to collaborate effectively over air pollution were said to be inadequate.102 Policies across health, climate change, urban planning and fiscal incentives were identified as key areas where joined-up thinking over air quality was needed.
- No clear future roadmap: many of the key proposals, such as fiscal reform, a scrappage consultation, vehicle ban, encouraging ULEV uptake, and modal shift, were thought to be too vague, lacked a clear roadmap for effective delivery, and contained distant targets delivering benefits too far in the future to be pertinent to tackling the current crisis.103
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:
- Overly focused on demonstrating compliance: As previously indicated, air quality experts told us that the UK’s current approach to modelling and monitoring is largely focused on demonstrating compliance with EU limit values. Whilst this was said to be important and provided crucial insight into the UK’s overall air quality performance, the National Centre for Atmospheric Science (NCAS) believed that “some rebalancing of local and national resources away from compliance monitoring and towards the surveillance of more appropriate metrics such as emissions measurement at source, would greatly improve the evidence base to underpin future action”.108
- Underestimating the size of the challenge: The Royal Academy of Engineering (RAE) said it was possible to identify cities publishing monitoring data significantly exceeding compliance levels, yet these jurisdictions were not designated in the 2017 plan, nor did they appear on the lists for councils which were acknowledged to be exceeding limits but were not required to produce clean air plans. The RAE concluded it was possible that the basis on which action plans were being produced was “seriously underestimating the number of areas requiring action”.109
- Disparity between local and national data: Local authorities criticised the disparity between data collected locally and the data used to inform Defra’s national plan. Liverpool City Combined Regional Authority told us it was “difficult to argue that the measures are likely to be effective or proportionate when they are based on relatively coarse information that is often inconsistent with local authority data”.110 City of Cardiff Council likewise expressed concerns that local authority data was not being sufficiently taken into account in national policy formation.111
- More accurate forecasts needed: More detailed data are required to support accurate forecasting. A group of researchers recently argued it was possible the UK might meet NO2 standards faster than originally thought, due to potential emission variances over a vehicle’s lifecycle.112 The authors stressed however that the Government was lagging on NO2 targets regardless of the potential adjustment.
- Expand aim of monitoring: Cranfield University highlighted the importance of expanding the aim of monitoring, saying that models and assumptions needed to be systematically checked against local level developments to determine the effects of air quality interventions or technological changes. This would be particularly useful when assessing whether interventions actually reduce pollution or merely move it elsewhere.113
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
85 Defra, UK plan for tackling roadside nitrogen dioxide concentrations - detailed plan, July 2017, p.85–87
86 Defra, UK plan for tackling roadside nitrogen dioxide concentrations - detailed plan, July 2017, para 93
87 Defra, UK plan for tackling roadside nitrogen dioxide concentrations - detailed plan, July 2017, paras 93 – 94
88 Defra, Emissions of air pollutants in the UK, 1970 to 2016, 15 February 2018
89 Defra, UK plan for tackling roadside nitrogen dioxide concentrations - an overview, July 2017, para. 18
90 Defra, UK plan for tackling roadside nitrogen dioxide concentrations - an overview, July 2017, para 18
91 Defra, Air Quality: Additional measures to support individuals and businesses affected by local NO2 plans, November 2017
92 High Court of Justice, ClientEarth No.3 v Secretary of State for Environment, Food and Rural Affairs & Ors [2018] EWHC 315 (Admin), 21 February 2018, Para 104
93 ClientEarth, UK Government loses third air pollution case as judge rules air pollution plans ‘unlawful’, 21 February 2018
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
96 Birmingham City Council (IAQ0094) para 3.1, National Centre for Atmospheric Science (IAQ0045) para 19
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
112 Grange et al, Lower vehicular primary emissions of NO2 in Europe than assumed in policy projections, 2017, Nature Geoscience
114 Q175
115 Q165
116 Q202
Published: 15 March 2018