Air quality: a follow up report
Written evidence submitted by Environmental Protection UK
Summary of Our Views
Detailed Comment on the Enquiry Topics
We have detailed our comments below in each of the four areas requested by the Committee:
The causes of particulate and NO2 air pollution in the UK and how these can be reduced most effectively.
1. Emissions from road traffic are still the most significant source of air pollution in most parts of the UK. Emissions mainly arise from vehicle exhausts; however in the case of particulate matter contributions are also made from tyre and brake wear and through vehicles re-suspending dust deposited on the road surface. Road traffic is the key source of pollution due to the quantity of NOx and PM10 it emits and also due to the way in which traffic permeates our towns and cities. Pollution from vehicles is released directly into our streets at a low level (height), where it has little opportunity to disperse before being inhaled by those who live and work in heavily populated urban areas.
2. Measures to address emissions from vehicles tend to fall into two areas – technical ‘end of pipe’ solutions and non-technical measures. To date attention has focused overwhelmingly on technical solutions, with increasingly strict emissions standards set at European level. These have had some success in improving air quality; however since publication of the EAC’s last report evidence has come to light  that NOx abatement for diesel vehicles has had little impact in real world driving conditions. It is essential that these problems are rectified in the forthcoming ‘Euro 6’ emissions standards – but even if they are ‘Euro 6’ will have little impact on the immediate task of meeting European air quality targets as it will take many years for compliant vehicles to build to a significant proportion of the UK vehicle fleet. Some of the reasons that the NOx emission standards have been ineffective, such as 'cycle beating'  , also affect the PM emission standards.
3. Ten years ago new car registrations were dominated by petrol powered vehicles; today diesel cars make up nearly half of all new registrations  . This shift from petrol to diesel fuel has been driven by Government policies that link vehicle taxation to CO2 emissions: as diesel vehicles normally have lower CO2 emissions than equivalent petrol vehicles they benefit from cheaper Vehicle Excise Duty and (where applicable) Company Car Tax. Under the Euro standards diesel cars are allowed to emit more NOx and PM10 than petrol equivalents and also suffer from the poor real world performance highlighted in paragraph 2. This shift in the car market has had a marked impact on air quality – it is one of the main reasons why air quality has failed to respond to tighter vehicle emissions standards.
4. Measures to remove older vehicles (particularly older diesel vehicles) from the roads can be effective in reducing emissions of NOx and PM10. Whilst it had no environmental objectives, the previous Government’s scrappage scheme was still effective at replacing older vehicles with modern, small petrol powered cars (more than 82% of cars bought through the scrappage scheme were petrol-powered). A new scrappage scheme aimed at replacing elderly, diesel powered vehicles with modern low emission (air pollution and CO2) vehicles would improve air quality and also assist an industry still badly affected by the economic downturn.
5. Older vehicles can also have their emissions performance improved via retrofit of emissions abatement equipment. This is a particularly good option for large diesel vehicles – retrofit equipment does not have to simply follow Euro emissions standards and can be tuned to deliver good ‘real world’ performance, particularly if a vehicle has a known end use (e.g. predominantly urban driving, motorway use, etc). Vehicle owners need to be incentivised to retrofit their vehicles however, either through ‘carrots’ (for example lower vehicle taxes) or ‘sticks’ (Low Emission Zones or licensing for taxis, etc).
6. Little attention has been given to non-technical measures: those that aim to reduce traffic in our urban centres, shift journeys from private vehicles to (clean) public transport and promote active transport. These measures do not just help to improve air quality, they also fit with the Government’s ambitions to reduce carbon emissions and promote healthy lifestyle choices. Pilot projects in this area such as the Sustrans Travel Smart  initiative have demonstrated that significant modal shifts are possible through a ‘nudge’ style process, but despite some consideration in the recent Local Transport White Paper the Government is yet to show any significant support for these types of interventions.
The impacts on health and the environment from particulate and NO2 pollution, and how these should be measured.
7. Government documents and statements have consistently downplayed the health impacts of air pollution. Oft repeated quotes from the current UK Air Quality Strategy include ‘99% of the UK meets European air quality standards’. This statistic is for geographical area rather than the percentage of the population affected – the 1% of the UK that does not meet the standards represents some of our most densely populated urban areas, whilst much of the 99% that is ‘clean’ is sparsely populated countryside. Another commonly repeated statistic is that ‘Air pollution is currently estimated to reduce the life expectancy of every person in the UK by an average of 7-8 months’. This suggests that the impacts are small and distributed evenly across the whole UK population, when in fact the impacts are concentrated in the most polluted urban areas and the health impacts for those that live and work there are actually very large.
8. The health and other environmental risks associated with poor air quality have been explored by bodies such as the Committee on the Medical Effects of Air Pollutants (COMEAP). COMEAP have updated their assessment of the health impacts of long term exposure to air pollution  since the last EAC report.
9. EPUK believes that the most engaging and hard hitting metric is premature deaths due to poor air quality. The aforementioned COMEAP report provided a figure of 29,000 UK premature deaths in 2008 due to long term exposure to PM2.5, whilst the Mayor of London settled on a figure of 4,300 premature deaths in London in a health study accompanying his recent Air Quality Strategy  .
10. It is also important to use comparisons with other, higher profile, health issues – health statistics can be difficult to comprehend in isolation. The graph below showing the comparative impacts of PM2.5 pollution, passive smoking and vehicle accidents is one example of how this can be done.
Source – Institute of Occupational Medicine, ‘Comparing Estimated Risks for Air Pollution with Risks for Other Health Effects’, March 2006. Graph shows estimated gain in life years in England and Wales from 2005-2110 for the whole population (including people born during that time) that could be achieved by eliminating each health hazard.
11. Statistics on the local impacts of poor air quality are not available in most parts of the UK. Statistics on local health impacts need to be produced urgently and communicated in an engaging way – this would help raise community awareness and put pressure on local politicians to address the issues. Local health statistics would also help local authorities to compare air quality impacts with other areas of public health concern, and decide where local public health funding was best spent.
The effectiveness of the Government’s strategy for improving particulate and NO2 air quality, and how that might be improved.
12. Environmental Protection UK welcomes the Government’s commitment to ‘work toward European air quality standards’ contained within the Coalition Agreement, however we are concerned that ‘work towards’ in no way commits the Government to meeting these legally binding, health based air quality standards.
13. The primary purpose of air quality legislation is to protect public health; however there is an increasing tension between the public health and legal compliance agendas, and a significant risk that the actions to achieve air quality improvement for public health benefit will be subsumed by the process of avoiding legal penalties. This tension is occurring because of the Government’s increasing use of overly optimistic monitoring and modelling techniques to prove compliance (see paragraph 16). It is also due to the current exclusive focus on meeting nitrogen dioxide limit values to the detriment of action on PM2.5, which is understood to be the pollutant with the greatest impact on our health (see paragraph 18).
14. The previous Government’s strategy for improving air quality was essentially waiting for progressively tighter European emissions standards for road vehicles to impact on air quality. This strategy has not worked as well as intended, due to traffic growth cancelling out some of the improvement in emissions from individual vehicles and the poor performance of vehicles in ‘real world’ driving conditions (see paragraph 2).
15. The EAC ‘Air Quality’ report released in 2010 made a number of practical and well reasoned recommendations; however there is little evidence that the recommendations are being implemented. The Government Response to the report (released as a Command Paper under the current Government) simply made a re-statement of existing policy rather than initiating the major changes to air quality policy that the EAC recommended. The current Government is yet to release any substantially updated strategies for air quality, and the ineffective 2007 Air Quality Strategy for England, Scotland, Wales and Northern Ireland is still the pre-eminent document for UK air quality policy.
16. In 2010 the UK applied to the European Commission for a time extension for meeting the daily PM10 limit value in London, and earlier this year was awarded a ‘temporary, conditional time extension’. The UK’s time extension application proposed little in the way of new action but used monitoring and modelling processes and (allowable) tweaks such as deductions for naturally occurring sea salt to prove that London would be compliant after June 2011. This process of ‘compliance by computer’ provides no real world health benefits and the over optimistic assumptions it makes run the risk of being undermined as real world monitoring data becomes available. The high PM10 concentrations observed in London  during the first part of this year give weight to this latter point, and the Government’s assertions that London will be compliant after June 2011 are now under serious doubt.
17. As one of conditions for the extension, the Commission required a document on additional PM measures to be submitted to the Commission by the end of June. We also understand that Defra will be consulting imminently on an action plan for NO2 (this will form part of the UK’s application to the European Commission for a time extension for meeting nitrogen dioxide limit values). It is essential that both of these documents contain new, robust measures for reducing PM10 and NO2 concentrations if the UK is to avoid infraction action by the European Commission.
18. To date little attention has been given by the Government to 2020 targets for fine particles (PM2.5). The recent report ‘PM2.5 in the UK’  by the Scottish and Northern Ireland Forum for Environmental Research (SNIFFER) indicated that the challenge of meeting PM2.5 targets is greater than previously anticipated, and also that control strategies for PM2.5 will need to be significantly different to those used for PM10. More research and attention is needed for this area as soon as possible so that any control measures needed can be introduced with reasonable lead in times to meet the 2020 deadline.
19. We have covered some of the actions that could be taken to improve air quality in paragraphs 4-6. In addition to this we understand that the Government is looking to increase their support for Low Emission Zones (LEZs), where local authorities feel they should be established. Experience from Europe suggests that LEZs can be a very successful tool for improving air quality, particularly if a national LEZ framework is established to help local authorities establish them  . In light of the ‘real world’ performance of some diesel vehicles (see paragraph 2) the LEZ framework criteria should encourage vehicles and technologies that demonstrate real world emissions reduction.
20. Alternatively fuelled vehicles have the potential to effect large improvements in air quality over the medium to long term; however the Government’s support for these vehicles currently rests almost entirely with a single technology – battery electric vehicles. Whilst these vehicles are very good for air quality (they have zero tailpipe emissions), short ranges, long recharging times and high costs will confine them to niche markets for the foreseeable future. Other alternative fuels, however, are currently almost entirely unsupported. We would like to draw attention in particular to gas (compressed natural gas or biomethane) powered vehicles. This is an inherently clean technology and tailpipe emissions of particulate, NOx and CO2 are very low  . Gas buses can be run on biomethane – natural gas produced from the decomposition of organic waste – which results in extremely low ‘well to wheel’ CO2 emissions. This technology is mature and many countries have large gas vehicle fleets  (with several using biomethane). However, in the UK the technology is largely unsupported and unrecognised by the Government.
21. Harmonisation of air quality and climate change policy is key to improvements in air quality: both policy areas are aiming to address the same combustion processes. There are many opportunities to improve both climate change and air quality, such as heat and energy efficiency and promoting smaller, more efficient vehicles. Coordinated policy can lead to lower overall costs, whilst un-coordinated policy can cause unintentional trade offs. The benefits of integrated policy have been explored in Defra’s ‘Air Pollution: Action in a Changing Climate’  document for the national level, and our own ‘Air Quality and Climate Change: Integrating Policy in Local Authorities'  at the local level.
22. DECC currently pay almost no attention to air quality as an issue, and often seems to regard air quality and other local environmental issues as barriers to be overcome rather than important issues to be integrated into its policy delivery. As a result win-win measures between climate change and the natural environment (including air quality) are not being identified and fast tracked, whilst the potential negative effects of climate measures are not being fully identified before implementation.
23. Some combustion based renewable and low carbon technologies have the potential to impact negatively on air quality. In particular biomass technologies (such as wood burning), which will soon be supported by the Government’s Renewable Heat Incentive (RHI). Commitments to include strict air quality standards in the RHI for supported biomass equipment have been progressively watered down throughout the development process, and the scheme will be launched with only a vague commitment to introduce air quality standards in 2012. Biomass is an inherently dirtier technology (for air quality) than the natural gas boilers that currently provide most of the UK’s heat needs, and modelling for the 2009 UK Renewable Energy Strategy  confirmed that the air quality impacts of a large, unmanaged expansion in biomass combustion would be very significant.
24. EPUK advocates a location based approach to renewable energy deployment. This would target renewable technologies with significant air quality impacts towards suburban and rural areas where air quality is good, and limit their deployment in polluted urban locations. Conversely renewable technologies with positive air quality impacts (such as solar thermal) would be strongly encouraged in urban locations with poor air quality. Such a strategic approach is currently not part of Government policy, and the ability of local authorities to implement a location based approach may be undermined by Government plans to allow greater permitted development rights for small scale renewables.
25. The culture of other Government departments, in addition to DECC, is to show at most a limited engagement with the air quality issue. DfT have shown a degree of increased willingness to engage on air quality – generally, however, air quality is still siloed within Defra. Whilst DfT and Defra share responsibilities for air quality, Defra are effectively the lead department and the policy responsibilities for most measures that can improve air quality lie outside of their remit.
26. The 2007 air quality strategy is increasingly dated, and is not focused on either compliance with EU limit values or maximising health benefits. A new, cross-Government, air quality strategy should be urgently developed. This should have the aim of re-focusing objectives, aligning policy on air quality and climate change, and perhaps most importantly sharing the responsibility for meeting targets amongst all appropriate Government departments.
The potential effects of the Government’s localism agenda and proposed reforms of public health provision on local authorities’ capacity for tackling poor air quality.
27. The localism agenda puts UK air quality policy in a quandary: to effectively tackle poor air quality local authorities need to do much more, but localism means that Government’s ability to force local authorities to take action is being reduced. We believe the solution to this problem is to raise the profile of air quality as a local issue, so that it is seen to be a priority area by communities and local politicians.
28. The Government’s plans to devolve public health functions to local authorities could potentially provide both a greater remit and more funding to tackle poor air quality. However, in two-tier local authority arrangements air quality (through the Local Air Quality Management regime) is currently the responsibility of district/ borough level authorities, whilst public health responsibilities and funding will go to the county authorities. There is a parallel here with existing transport responsibilities and air quality – in practice the degree of co-operation between air quality functions (at the district level) and transport authorities (at the county level) has often been poor. Better links need to be drawn between the two tiers of Government with respect to the new health responsibilities to avoid these problems of split responsibilities being repeated.
29. Local authorities are now making significant cuts to their budgets, and many report that their capacity to manage air quality is being significantly reduced. The new public health responsibilities and funding are not due to be implemented until 2012 leaving a funding ‘gap’ for areas such as air quality. If local authorities are to take a more active role in improving poor air quality then an expensive and time consuming rebuilding of capacity may have to take place once the public health and well-being responsibilities are implemented.
2 June 2011
 ‘Trends in NOx and NO2 emissions and ambient measurements in the UK’ http://uk-air.defra.gov.uk/reports/cat05/1103041401_110303_Draft_NOx_NO2_trends_report.pdf
 ‘ Cycle beating ’ can result in vehicles which meet stricter emission standards by having lower emissions in the steady state (motorway) portion of the test cycle, and unimproved (or even increased) during the urban portion of the test cycle.
 ‘Motor Industry Facts 2011’, Society of Motor Manufacture r s and Traders www.smmt.co.uk/download/?product_name=TW90b3IgSW5kdXN0cnkgRmFjdHMgMjAxMQ==&product_id=ODQ=
 See www.sustrans.org.uk/assets/files/travelsmart/behaviour_change_ff36.pdf
 See http://comeap.org.uk/component/content/article/28-page-linking/128-the-mortality-effects-of-long-term-exposure-to-particulate-air-pollution-in-the-uk.html
 See www.london.gov.uk/publication/mayors-draft-air-quality-strategy
 See www.environmental-protection.org.uk/news/detail/?id=2801
 See www.sniffer.org.uk/Webcontrol/Secure/ClientSpecific/ResourceManagement/UploadedFiles/PM25%20Report%20Final%20%2820Dec10%29.pdf
 See ‘Low Emission Zones in Europe’ for examples - www.lowemissionzones.eu
 See www.biogasmax.eu/media/5t4_manuel_lage__073402300_0657_30092009.pdf
 For example the Los Angeles (USA) bus fleet is almost entirely fuelled by CNG, see http://articles.latimes.com/2011/jan/13/local/la-me-buses-20110112
 See www.defra.gov.uk/publications/files/pb13378-air-pollution.pdf
 See www.environmental-protection.org.uk/aqclimate/
 See page 121