An initial response from the Air Quality Management Resource Centre, UWE Bristol
On 26th July 2017, the Environment Secretary and Transport Secretary launched the new UK plan. After a short period of consultation, several court cases and various iterations of a plan we can now see the direction and rate of travel towards compliance with EU limit value for nitrogen dioxide (NO2). The questions that need to be addressed are does it do this effectively, efficiently and in a timely fashion? Does it recognise the importance of protecting public health and give sufficient attention to health protection measures? We know from experience that air pollution can be managed when there is a political will to act but is there a political will to act decisively now?
The high-level aim of the plan is to achieve compliance with the nitrogen dioxide limit value and to do this it sets out a range of measures to reduce the impact of diesel vehicles and accelerate the move to cleaner transport. Local authorities will be expected to develop new and creative solutions to reduce emissions as quickly as possible, while avoiding undue impacts on the motorist.
So why is a plan needed? Well essentially it is to avert the ongoing public health impact of nitrogen dioxide emissions from road transport. It is estimated that the effects of NO2 on mortality in the UK are equivalent to 23,500 deaths annually. Many of the sources of NOx (NO2 and NO) are also sources of particulate matter. The combined impact of these two pollutants on mortality may be as many as 40,000 early deaths per year and tens of thousands of cases of illness. This represents a significant public health challenge.
AQMRC responded to the Government’s consultation on this plan and in answer to the question “How satisfied are you that the proposed measures set out in this consultation will address the problem of nitrogen dioxide as quickly as possible?” AQMRC replied “Very dissatisfied”. You can read the full AQMRC response here.
So why were we so dissatisfied? We take the view that a primary responsibility of the government is the protection of public health. In this instance, we consider the government has been derelict in its duty to protect public health from the effects of NO2. The government has known since 2005 that NO2 was not responding to the actions taken under the Air Quality Strategy and the Local Air Quality Management work of local authorities. An annual mean objective of 40 µgm-3 NO2 had been set in the Air Quality Regulations and it was planned that this would be achieved across the UK by 2005. Unfortunately, the problem was much more acute and widespread than expected and was unresponsive to the management options available to local authorities. The main source of emission is road transport and so the management of the problem must address this source. So, is the new plan going to make a difference? The headline is of course that diesel and petrol cars will be banned by 2040. Well, good but that is 23 years away and hardly represent an urgent response to a public health emergency. Of course, the motor industry will need time for research and development and to retool manufacturing plant to deliver electric vehicles at the scale anticipated but the timescale seems very generous indeed. However, we should acknowledge and welcome the commitment, even if the policy isn’t actually new. The question now is how do we bring the deadline forward from 2040?
We recognise that this plan only tackles nitrogen dioxide and thus is responding to the Limit Value, the legal target for nitrogen dioxide, set under the European Air Quality Directive rather than seeking to improve overall air quality. We are pleased to see a commitment to publish a new Clean Air Quality Strategy by 2018. The last Air Quality Strategy was published in 2007 and we have been calling for a new one for many years! It is important that the broad range of pollutants that affect human health and their diverse emissions sources are considered together in this new and overarching strategy.
The new plan describes £2.7 billion of funding for air quality improvements, not all of which appears targeted at nitrogen dioxide and in many cases, this appears to have been spent or committed so cannot be considered new money. Interestingly this sum is equal to the £2.7 billion annual productivity costs calculated from estimates of the impact of air pollution on chronic and acute illness in the workforce, morbidity in the workforce and absence in the workforce due to morbidity in dependents.
We are surprised that the onus continues to be placed upon local authorities without the concomitant national policy framework to support their work. The plan identifies 81 major roads in 17 towns and cities where urgent action is required, the majority of these roads are in London. We think this is a gross under estimate of the scale and persistence of the problem. The funding package includes £255m for local authorities to accelerate their remedial actions. The plan identifies changing road layouts, removing speed bumps to smooth traffic flow, reprogramming traffic lights and retrofitting buses as the key actions to be taken by the local authorities. We are not convinced that these are the most important or immediate actions that need to be taken. Relevant councils must develop a local plan by March 2018 and, following government consultation, confirm its scope by the end of the year. The intention (and hope) of the government’s plan is that local authorities will implement these low impact measures and achieve compliance with the limit value rather than develop a charge based Clean Air Zone (CAZ). All the evidence suggests charge based CAZs will achieve the limit value much sooner. We are concerned that the timescale set out in the plan is unambitious and will make it very challenging for local authorities to deliver improvements to NO2 as quickly as possible.
Local authorities that require CAZ action plans by March 2018 are identified by nationally modelled exceedences relevant to the limit value in 2021 and do not take into consideration locally assessed exceedences of NO2. Over 260 local authorities have one or more Air Quality Management Areas (AQMA) because of traffic derived NO2. We are surprised and perturbed that addressing this widespread spatial delineation of NO2exceedence is not part of the national plan. We think this needs urgent reconsideration or, at least, an adequate rationale provided for the exclusion of AQMAs from the plan.
We expected, or hoped at least, that a scrappage scheme would be announced in the plan and that this would support the introduction of charge based CAZs. However, this opportunity has not been taken probably for reasons of cost and the avoidance of political damage. This shows a lack of political courage and a failure to recognise the urgency of the public health crisis. It is unclear whether the health and productivity costs of delayed compliance have been properly assessed in any cost-benefit modelling. We think that as a minimum scrappage schemes should be reconsidered for low income households who are likely to suffer the highest health impacts from the pollution emitted by others.
We acknowledge that the plan does recognise the health impact evidence that has built up steadily over recent years however given that the evidence base on health effects is increasing we think it would be prudent to treat associated health cost estimates as conservative.
We are pleased to see that the plan includes a revision to the rate of diesel taxation and that the new monies raised will be used support air quality improvements. However, the detail requires much further scrutiny to judge the likely scale and impact of the proposal.
Overall, we feel that the plan does not provide sufficient confidence to demonstrate that the urgency of the challenge has been recognised. The measures in the plan are unambitious and lack certainty. Indeed, many if not most of the measures proposed are already available to local authority air quality managers. The delay in producing a workable and effective plan over the last few years highlights the lack of urgency that the government has afforded to the protection of public health.
In answer to the questions about the plan that we set out above we are not convinced that the actions and the timescales proposed properly respond to the scale of the problem. We do not consider them to demonstrate the urgency required to address the challenge as quickly as possible. We are unconvinced about their likely effectiveness and uncertain about their efficiency. Will they work? Only time will tell but the impacts of NO2will continue to be felt whilst the planning process moves into implementation and it will be some time before the UK can claim compliance with the limit value for nitrogen dioxide. In the meantime the public health impacts will continue.
The long-term solutions to air pollution lie in land use planning and transport infrastructure planning. The plan has little to say about these long-term processes perhaps because the beneficial impacts arising from these planning processes are long term whilst the problems of air pollution are immediate and near term and consequently there is a disconnect between the immediate resource requirements and the health benefits.
Are people willing to make changes that will improve the health and wellbeing of citizens? We think we need less road space devoted to cars, better public space, localised facilities and better public transport in order to maximise public health benefits not just cleaner vehicles. In order to find out what the public think ClairCity is engaging thousands of people in cities across Europe to identify the best local options for a future with clean air and lower carbon emissions. You can read about the European Union funded project and contribute your ideas about how air pollution can be managed.
Professor Jim Longhurst, Dr Jo Barnes, Dr Tim Chatterton, Associate Professor Enda Hayes, Dr Emily Prestwood, Dr Laura de Vito & Dr Ben Williams.
Air Quality Management Resource Centre