Written evidence submitted by Air Quality
Management Resource Centre, University of the West of England,
Bristol
This letter constitutes a response to the Environmental
Audit Committee's latest call for evidence on air quality. The
points made in our submission to the last call for evidence in
December 2009 still stand and this submission should be seen as
additional to those. The key points made in our response can be
summarised as follows:
— There
is an important relationship that needs to be maintained between
action to improve air quality at a national level and at a local
level. For a number of reasons this relationship has not been
sufficient so far to achieve the UK air quality objectives and
limit values, however we feel that that there is a real danger
that the government's current intentions with respect to the agendas
of "localism" and "deregulation" pose a significant
threat to the likelihood of achieving the air quality targets.
— There
is currently a great focus on the failure of EU vehicle emission
standards to have achieved good air quality for all. Whilst important,
this discussion distracts from the underlying cause of poor air
quality which lies with the unrelenting growth in traffic levels.
Whilst it is important that vehicles are as clean as possible,
there has been too great a reliance on technological solutions
rather than on addressing the wider transport problem itself.
Local action on air quality is never likely to be successful within
the context of national policies that allow, or even encourage,
continual growth in traffic.
— Air
quality has not been effectively integrated within policies concerning
transport, spatial planning or health at either local or national
levels and this has led to it failing to be given due regard in
these areas.
ABOUT THE
AIR QUALITY
MANAGEMENT RESOURCE
CENTRE AT
UWE, BRISTOL
1. The AQMRC is based at the University of the
West of England, Bristol and was formed in 1998. Between 1999
and November 2010, it held (in partnership with Air Quality Consultants
Ltd.) a contract with Defra (and formerly with DETR) for undertaking
management tasks in relation to the Local Air Quality Management
process. These tasks included:
— the
appraisal of local authority Review and Assessment reports;
— the
management of archives of reports and Air Quality Management Area
orders;
— the
maintenance of databases to record and track these documents and
other elements and indicators of progress within the LAQM system;
— the
operation of a telephone, email and internet-based helpdesk service
to help local authorities with their work; and
— support
in the writing and updating of official guidance for Defra and
the Devolved Administrations.
2. In addition to the LAQM contract with Defra
and the Devolved Administrations, AQMRC has also carried out a
wide-range of other LAQM work for UK local authorities. This has
included carrying out and providing assistance for review and
assessment work and air quality action planning, support and facilitation
for consultation and engagement exercises with the public and
other key stakeholders, and training provision to enhance capability
and capacity, specifically for LAQM but also in related areas
of air pollution, climate change, and land-use and transport planning.
AQMRC has a significant research background based on air quality
management funded by prestigious research organisations including
ESRC, NERC and EPSRC. This has generated an extensive peer reviewed
publications list, and has allowed the development of a renowned
track record in supervising and examining PhD students in the
field of LAQM. AQMRC was also instrumental in the design and development
of the Institute of Air Quality Management in order to promote
and support the increasing number of professionals working in
this field.
3. AQMRC are internationally recognised for their
leadership in the field and have been involved in a number of
major international projects. The group has also had significant
involvement in the promotion of the UK LAQM Framework as good
practice in a range of contexts, including the EU Framework V
INTEGAIRE (Integration of Environmental Governance and Air Quality
in Europe) project, the provision of support for the development
of air quality capacity in Bangkok Metropolitan Administration,
and in the development of the South African National Framework
on Air Quality (which used the UK system as a basic model).
4. The AQMRC is a part of the Institute for Sustainability,
Health and Environment (ISHE). This is an Institute comprising
a wide-range of research groups covering key areas of research
into: sustainable communities and the built environment; public
health and well-being; and environmental sustainability.
Causes of particulate and NO2 air
pollution in the UK and how these can be reduced most effectively
5. The cause of air pollution problems in the
UK are predominantly emissions of pollutants from road traffic
within environments where there is poor dispersion of pollution
and exposure of members of the public.
6. Efforts to reduce pollution from vehicle tailpipes
is not working, and is becoming increasingly ineffectual with
each new Euro Standard.
7. It is generally estimated that 50% or more
of PM10 related to vehicles is associated with resuspended
road dusts. Particularly as PM from exhausts, and tyre and brake
wear is reduced this will become a much more significant source.
Therefore measures to actually reduce road speeds and flows will
become more effective.
8. Problems with nitrogen dioxide are often
associated with very low flows of traffic (sometimes <5000
vehicles per day) in narrow streets in small urban locations.
9. Significant efforts need to be made to control
and reduce levels of motorised traffic in built-up areas; this
can only be done through aligned efforts at national and local
levels.
Impacts on health and the environment from particulate
and NO2 pollution, and how these should be measured
10. There is not necessarily a problem with how
impacts of air pollution are measured, so much as how the measurements
are reported. Despite increasing evidence regarding he impacts
of air pollution on health (which have shown previous estimates
of the impacts to be significant underestimates) there has been
little attempt to effectively engage the public over this issue.
11. Defra last asked a question on air quality
in their Quality of Life survey in 2001[33].
The response indicated that air quality was the most important
of the government's environmental indicators for sustainability
with 95% of respondents rating it as either Very or Fairly Important.
There is little evidence that the government has taken up this
opportunity for engaging the public.
12. Within public engagement work done by AQMRC
it is common to find air quality rated higher than climate change
as a priority amongst local people, yet this is rarely reflected
in messages from national government. This is something that potentially
endangers the ability to take effective action on both issues.
13. One problem that is apparent in the recording
and reporting of pollution is the discrepancies between modelled
pollution concentrations as calculated by Defra for the purposes
of EU reporting, and the extent of problems evidenced through
the LAQM process. Particularly with regard to PM10
the national modelling appears to significantly underestimate
the scale of the problem in the UK with 59 local authorities in
England alone having declared Air Quality Management Areas for
PM10.
The effectiveness of the Government's strategy
for improving particulate and NO2 air quality, and
how that might be improved
14. The Local Air Quality Management process
as set out and developed by the 1995 Environment Act, 1997 Air
Quality Strategy, and successive guidance and strategy revisions
has been unsuccessful at delivering the necessary reductions in
air pollution to meet domestic objectives and EU limit values
because it was never designed to meet the eventual challenge.
15. In the mid-1990s, following very successful
reductions in pollution emissions from industry, through significant
regulation, and from transport through the introduction of catalytic
convertors, it was widely anticipated that future measures at
a national level would be sufficient to ensure that air quality
met necessary standards in all but a handful of locations.
16. The Local Air Quality Management process
can be divided into 2 parts: Review and Assessment and Action
Planning. The Review and Assessment process was very successful
in terms of identifying air quality problems in over 60% of Local
Authority areas. A far greater problem than had ever been envisaged
when the process was established.
17. The current framework for action planning,
where LAs are given the responsibility for devising an action
plan and implementing it in relative independence from national
government, and with no clear penalties for not achieving objectives,
was never devised for a situation where air quality problems were
so widespread, and is now out of date.
18. With such extensive problems occurring, it
is obvious that the problem, to some extent, exists at a national
level and there is therefore a need to pay much closer attention
to the interaction between national policies and local problems.
One example of this is from the findings of the Sustainable Travel
Town Demonstrations[34]
that showed that whilst local efforts to reduce traffic might
achieve a 9% reduction in trips by local residents, when overall
traffic flows were examined, this was reduced to a reduction of
only 2% in traffic flows due to the impact of non-local traffic.
19. The LAQM Framework was developed at a time
when there was a strong intention to try and tackle growth in
road traffic (c.f. The 1997 Road Traffic Reduction Act, 1998 New
Deal for Transport White Paper[35],
and 2000 Ten Year Transport Plan). If these intentions had been
successful there would have been much less difficulty for Local
Authorities in developing and implementing effective local Air
Quality Action Plans. However, in the context of national policies
failing to effectively limit (and arguably encouraging) growth
in transport, the ability of LAs to reduce air pollution is significantly
constrained.
Potential effects of the Government's localism
agenda and proposed reforms of public health provision on local
authorities' capacity for tackling poor air quality
20. As described above, we believe that the failure
of UK air quality policy in achieving the UK objectives and EU
Limit Values lies largely with national government and not local
government. Whilst more power and influence at a local level is
a good thing, a number of key issues need to be addressed:
21. There must be sufficient statutory obligation
on local authorities to tackle air quality to ensure that they
prioritise it sufficiently to contribute effectively to the meeting
of national targets, and to ensure that environmental protection
doesn't become an option, leaving the protection of the health
of the most disadvantaged to the chances of a postcode lottery.
Local political priorities are rarely decided by the disadvantaged
who most often suffer the ill-effects of air pollution.
22. Local action must take place in the context
of national policies that support local action and work in the
same direction. It is no good cutting local authorities loose
and expecting them to tackle the problems caused by a national
failure to control road traffic growth.
23. Local authorities need to be adequately resourced
in order to carry out effective work in their areas. The first
year of the new administration has seen swingeing cuts in local
authority budgets that have resulted in a large number of air
quality staff being made redundant. We consider it highly unlikely
that this will lead to sufficient capacity in local authorities
to undertake efficient action on air quality.
24. Whilst much is being made of the proposed
move of Public Health from the NHS to Local Authorities, particularly
in respect of the potential for linking to environmental health
issues, there are some significant problems to be overcome. The
greatest of these is the issue of the two-tier Local Authority
system in England. Over 50% of English LAs are district authorities
rather than unitary, and therefore the proposed health service
reforms will establish public health responsibilities at a county
level, in a different organisation to environmental health which
resides at the district level. Although there is some rhetoric
regarding the fact that this will not be a problem and will in
fact encourage cross-organisation working, current experience
of working with local authorities at the district level suggests
that pressures on staff and resources are so tight (resulting
in the departure of many members of staff) that it is very hard
to envisage how district environmental health departments will
be able to actively engage with county level public health teams
without clearly ring-fenced resources being allocated to them.
25. AQMRC has been involved in a wide range of
research and consultancy work that has involved examining or working
across the cross-tier divide between air quality and transport
officers, and the experiences generally indicate that inter council
communication can form a serious hindrance to the development
and implementation of effective policy.
3 June 2011
33 http://www.defra.gov.uk/statistics/files/pas-survey2001.pdf Back
34
http://www.dft.gov.uk/pgr/sustainable/smarterchoices/smarterchoiceprogrammes/ Back
35
Launched by John Prescott stating "I will have failed if
in five years time there are not fewer journeys made in a car" Back
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