ALG Transport and Environment Committee
– Urgency Report
APPENDIX C
ALG response to Defra’s consultation on the Item no: 21
review of the Air Quality Strategy for
England, Scotland, Wales and Northern
Ireland.
Report by:
Jared Boow
Date:
11 August 2006
Contact Officer:
Jared Boow
Telephone:
020 7934 9951
Summary:
Job title:
Email:
Principal Environment Policy Officer
[email protected]
Defra has invited responses to its consultation on the review
of the Air Quality Strategy for England, Scotland, Wales, and
Northern Ireland. The ALG’s response has been informed by
contributions from six London boroughs. The scope of
Defra’s review is broad but some of the opportunities to fully
link the emerging strategy with other key areas of policy such
as energy, land use planning and climate change have not
been fully exploited.
The deadline for responses was 11 July 2006, however due
to a low and late response from boroughs it was not possible
to complete a member-approved ALG response in time.
Defra have therefore allowed us an extension on their
deadline. A response (see Appendix 1) has been sent to
Defra with the understanding this has not yet been endorsed
by members and may be modified by elected officers.
Recommendations:
ALG TEC Elected Officers are recommended to:

endorse the response, attached as Appendix 1
Background
1. Defra launched a consultation in April 2006 on the revision of the Air Quality Strategy for
England, Scotland, Wales and Northern Ireland. The Strategy aims to map out, as far as
possible, current and future ambient air quality policy in the UK in the medium term; provide
the best practicable protection to human health and the environment by setting evidence
based objectives for the main air pollutants; and describe the air pollution climate in the UK
to provide a framework to allow all those who contribute to air pollution, who have a part to
play in its abatement, or are affected by it, to identify their role in improving air quality.
2. The Environment Act 1995 requires the UK Government and the devolved administrations
for Scotland and Wales to produce a national air quality strategy containing standards and
objectives for improving ambient air quality. There is equivalent legislation in Northern
Ireland. The full consultation documents and consultation letter can be found at:
http://www.defra.gov.uk/corporate/consult/airqualstrat-review/index.htm
3. ALG officers sent a circular to London boroughs on 11 May 2006 informing them of the
review and requesting comments to inform a London-wide response from the ALG. Only
one response was received by the requested deadline of 21 June 2006 (the Royal Borough
of Kensington & Chelsea). A further request was sent to boroughs after the initial deadline,
and five further responses were received. These were from the London Boroughs of
Camden, Tower Hamlets, Enfield, and Newham, and from the City of London. Defra have
granted the ALG an extension for the submission of a member endorsed response.
Summary of the National Air Quality Strategy and the proposed changes
4. The first evaluation of the 1997 Air Quality Strategy, published in 2005, indicated that,
between 1990 and 2001, policies have resulted in a marked decline in concentrations of air
pollutants, with an estimated reduction of more than 4,200 premature deaths and 3,500
hospital admissions per annum.
5. Furthermore, the evaluation showed that these policies have been cost beneficial with an
estimated £68 billion benefits generated across the UK, set against costs of £6 billion during
the 1990 to 2001 period. Preliminary indications are that in 2005 the UK met the Strategy
objectives for benzene, carbon monoxide, 1,3-butadiene and lead.
6. All of the Strategy objectives are or will be met on time in most parts of the UK. However,
for some pollutants and at certain locations, levels are not declining as fast as expected and
trends are flattening or even reversing. Even though further emission reductions are
expected (e.g., as new vehicles and fuels become cleaner and older more polluting vehicles
are replaced), projections show that there will still be exceedences of the objectives for
nitrogen dioxide, particulate matter and ozone well after their target achievement dates
of end of last year and 2010 in some of the UK’s major urban areas and alongside busy
roads. Furthermore, for pollutants for which no threshold for adverse health effects has
been identified, such as particulate matter, air pollution continues to have a significant
negative impact on people’s health even in areas that have already achieved the objectives.
7. Defra’s assessment estimates that if no further measures in addition to those already
agreed are implemented, man-made particulate air pollution in the UK will continue to
reduce average life expectancy by up to about 5.5 months even by 2020. This health
impact in 2020 is estimated to cost up to £6.6-15.4 billion p.a. In addition, a large part of
the UK’s ecosystems will continue to exceed critical loads for both nutrient nitrogen and
acidity even in 2020.
8. Defra’s consultation seeks stakeholders’ views on a number of potential additional policy
measures to further improve air quality. The additional policy measures assessed are for
implementation at international (European Union and beyond), national and local level.
They include technological measures (e.g., fitting pollution abatement technologies to road
vehicles and industrial processes) and measures designed to change behaviour (e.g., traffic
management measures, incentives for cleaner vehicles, road pricing and a range of
techniques called “smarter choices”). The assessments presented in the review estimate
the impact of the potential additional policy measures on: people’s health; the environment;
meeting air quality objectives; costs and benefits; competitiveness; socially deprived areas
and emissions of greenhouse gases.
Key Issues
9. Although the scope and vision of the review is broad, more could be done to reflect and
strengthen the links between air quality and energy efficiency, sustainability and climate
change. Climate change in particular, has moved significantly up the political agenda and
this issue could have been given more emphasis in the assessment of additional policy
measures.
10. The consultation gives insufficient consideration to the future of aviation and the impact of
this industry on air quality given the proposed expansion of airports to meet projected rises
in demand. The aviation sector is one of the fastest growing transport sectors globally and
the location and operation of airports have significant impacts on local air quality and this
issue deserves stronger recognition within the strategy.
11. Some boroughs have expressed only cautious support for Defra’s proposals for an
‘exposure-reduction approach’ to monitoring for non-threshold pollutants such as
particulates, for which there are no safe levels. Defra’s key justification is that it has a costbenefit advantage over the current objective/limit value approach and offers a more efficient
and effective way of maximising health benefits. Boroughs however argue that the new
approach may increase the exposure of people living in ‘hotspot’ areas. There is also some
uncertainty about the cost to local authorities if they are required to maintain high quality
urban background monitoring equipment.
Financial Implications
12. The partial Regulatory Impact Assessment (RIA) looks at a number of options singly and in
combination. It is therefore too early to gauge the financial impact of the measures until the
Government’s intentions with regards to each of the options are clearer.
Legal Implications
13. None.
Equalities Implications
14. An exposure–reduction approach to monitoring for some pollutants may lead to an increase
in the exposure of London’s residents already experiencing the highest pollution levels. An
overall reduction in background concentrations does not necessarily lead to reductions at
the roadside, leaving many people, especially the most vulnerable groups who often live in
areas with the poorest air quality, relatively unprotected by the air quality management
process. Defra’s final proposals will therefore require further detailed assessment.
Recommendation
15. ALG TEC Elected Officers are recommended to endorse the response, attached as
Appendix 1, for submission to Defra.
Appendices
16. Appendix 1: Defra’s Consultation on the Air Quality Strategy for England, Scotland, Wales
and Northern Ireland – the ALG’s Response.
Appendix 1: ALG Response to Defra’s consultation on the review of the National Air
Quality Strategy.
Eko Deinne
Air and Environmental Quality Division
Defra
Zone 7D/13
Ashdown House
123 Victoria Street
London
SW1E 6DE
Contact:
Direct Line:
Fax:
Email:
Jared Boow
020 7934 9951
020 7934 9950
[email protected]
Our Reference:
Your Reference:
Date:
ALG response to AQS consultation
10 July 2006
Dear Sir / Madam,
Re: Defra’s Consultation on the review of the Air Quality Strategy for England, Scotland,
Wales and Northern Ireland.
1. The comments below represent ALG officers’ views on key themes from the review of the
air quality strategy common to London boroughs. Many of the London boroughs will also be
responding to the consultation individually, and will likely also focus on more boroughspecific issues as well.
2. This document represents an officer response to the consultation. We will seek
endorsement from members of the ALG Transport & Environment Committee and forward
an endorsement or amendments as soon as possible.
3. Many of the proposals to introduce additional national policy measures are welcomed, as
there is clearly need to improve performance on certain pollutants. The comments below
are generally framed around the questions outlined in the consultation document.
ALG comments on Defra questions:
Are you satisfied with the scope and vision for this review summarised in Chapter 1?
4. The scope and vision of the review is broad and welcomed. However, whilst linkages
between the Strategy and the Government’s climate change programme are made, more
needs to be done to strengthen the links between energy efficiency, sustainability, climate
change issues, and air quality. There is ample scope to tackle energy efficiency for
example, as the Strategy outlines policy to 2020.
5. Climate change has recently moved significantly up the political agenda. Due to its close
relationship with air quality issues, it could have been given more emphasis in the
assessment of additional policy measures. Both the main greenhouse gases and air
pollutants are predominantly released from combustion sources related to power
generation, industry and transport and as a result, pollution control measures should be in
place that deal with both issues. The connection between transport modes and the impacts
on air quality and climate change could also be better addressed. Therefore a stronger
focus on the need to integrate climate change and air quality measures should be a top
priority in the Strategy review.
6. Consideration should also be given to the future of aviation and the impact this has on air
quality. The Strategy recognises the impact of the aviation industry on both air quality and
climate change (this is particularly so in and around London) but then fails to substantially
address it.
7. There should also be a greater recognition of the work carried out by local authorities
through the Local Air Quality Management process. Further consideration should be given,
and information provided on how this links with the national policy measures considered.
Do you agree with the assessment and projections presented for the pollutants in the Air
Quality Strategy?
8. Boroughs tend to agree with the assessment and projections presented for the pollutants
covered. However, there is concern regarding NO2 projections. The projections for NO2
concentrations to 2020 are likely to underestimate the actual value, particularly at roadsides.
This is because of recent evidence that suggests that whilst emissions and concentrations
of total NOx has declined, the amount of NO2 in the ratio of NO2 to NOx being emitted has
actually increased. This appears to be due to both newer vehicles with higher Euro
standards emitting a higher amount of NO2, and the increased use of certain types of diesel
particulate filters fitted to buses to reduce PM10 that increase the amount of NO2 being
emitted. The projections for NO2 concentrations to 2020 presented may therefore need to
be revised in light of these findings. This issue is also raised in paragraph 18 of this
response.
What policy measures in addition to those in Chapter 3 do you think the UK
Government and the devolved administrations should assess?
9. Defra suggest the use of the proposed national road pricing scheme as an air quality
improvement measure. However, the policy itself is not for the purposes of improving air
quality, and the assertion that the scheme would have a significant impact upon air quality is
not certain, since it would not necessarily draw the public away from their vehicles and onto
public transport. This would be more likely however if public transport was at the same time
improved, but it is not clear whether money generated from the scheme would be ringfenced for such purposes? (as has occurred, for example, with the central London
congestion charging scheme).
10. The consultation document does not emphasise emissions from aviation sufficiently. It is
one of the fastest growing transport sectors worldwide and in areas where airports are
based they have a major impact on local air quality. Given the current debate on proposed
expansion of airports to meet the expected future demand, this should be recognised and
more discussion should be devoted to this topic within the Strategy.
11. Although more beneficial in terms of climate change, diesel vehicles appear to be the cause
of the increased roadside NO2. As discussed previously, similar drivers impact on climate
change and air quality, but priorities for action may lead to conflicts (addressing one may
impact negatively on the other), so clearer, more integrated guidance from Defra would be
useful.
12. The use of the planning process to improve air quality is not covered sufficiently. This is a
major area of work for local authorities. Defra could work with DCLG to produce clearer,
more consistent planning guidance on how best to assess and mitigate emissions produced
by the construction and operation of developments, to reduce inconsistencies in the way
developments are dealt with. For example, an increasing concern is the way mechanical
ventilation is often proposed as a way of dealing with air quality problems in high density
residential developments proposed in areas of poor air quality. This is at odds with efforts
that are being made to reduce energy use and create more sustainable buildings. This
relates to other comments in our response regarding the need to integrate air quality and
climate change.
13. A policy measure that looks at enhancing the development and uptake of low carbon fuels
for transport in the future could be included as a longer term goal for pollutant reductions.
Hydrogen and biofuels offer significant benefits in terms of improving air quality. This would
help to integrate air quality issues with energy issues and climate change.
What are your views on the assessment carried out?
14. The impacts of the additional policy measures have been effectively assessed with an
impressive cost-benefit analysis. However, several of the measures suggested appear
rather ‘radical’ in their approach if they are actually to be rolled out UK-wide, and not just for
example, as small-scale incentive schemes. It would be interesting to know what support
these proposals have across wider Government beyond Defra.
15. In the light of previous comments regarding the effect of using diesel particulate filters on
direct emissions of NO2, Measure H may need to be re-assessed.
Do you agree that monetary costs and benefits (including impacts on public health);
impact on the ecosystems and habitats; impact on exceedences of objectives; and
qualitative assessments; are the right criteria to be considering? Please state your
reasoning.
16. The four criteria above are generally considered appropriate for the analysis of policy
measures discussed in the review of the Air Quality Strategy. However, the impact on
climate change should have been given more emphasis and included as one of the
parameters in the qualitative assessment for reasons already alluded to.
Do you agree that we should retain the existing objectives for NO 2, PM10, Ozone (for
human health), PAH, SO2, Pb, Benzene, 1,3 – Butadiene?
17. Yes, these pollutants need to remain on the air quality agenda. As previously mentioned
however, there is also concern regarding meeting NO2 objectives. There is also concern
that PM10 may be being prioritised at the expense of NO2. More serious consideration
therefore needs to be given to how to achieve the NO2 objectives, given the huge
exceedences of the annual average objective in central London and the increasing
exceedences of the hourly average objective.
Do you agree that we should begin to move the policy framework to include exposure
reduction type of objectives for non-threshold pollutants such as particulates? Please
specify why.
18. Several boroughs voiced concern regarding the proposals for an exposure reduction
approach. Defra have stated that this would be the most effective and efficient way to
maximise health benefits for non-threshold pollutants, such as particulates, as it would
ensure an overall reduction in exposure of the general population. They also argue that
most hotspot areas are around busy roads where fewer people are exposed over the
relevant averaging periods of the objective, and therefore it would be better to see smaller
reductions over wider areas where more people are affected and would benefit. However,
there are many roads in London which are densely populated and also exposed to high
levels of air pollution. Therefore, an exposure reduction approach must not allow such hot
spots to be ignored or get worse, to the expense of those residents experiencing the
highest pollution levels. An overall reduction in background concentrations does not
necessarily lead to a roadside reduction, which can leave many people, especially the most
vulnerable groups in society (who often live in areas with the poorest air quality and mostly
heavily trafficked roads) relatively unprotected by the air quality management process.
Defra should also keep in mind that the LAQM process already takes account of relevant
public exposure.
19. The role of local authorities under an exposure reduction approach also needs to be made
clear. Boroughs have concerns regarding whether this approach is practical for local
authorities because of the cost of maintaining high quality urban background monitoring and
a reduction in the importance given to ‘hot spots’ could be seen as a reduction in the role of
local authorities.
What do you think the role of the devolved administrations and local authorities should
be under this new framework?
20. National and international policies will drive the main aspects of the Strategy. However,
local authorities still have an important role to play in air quality management through the
planning process, Local Transport Plans (or LIPs), control of pollution from construction
sites, smoke control areas and exposure reduction policies. The strategy should emphasise
the role that local authorities play in delivering better air quality.
Do you agree that the exposure reduction approach should be pursued at a UK level first
and that the possibility of moving to a devolved administrations level should be
considered at a later stage? Please specify why.
21. Boroughs cautiously welcome the exposure reduction method, as long as it is not at the
expense of those issues raised above in point 21. We therefore suggest that both the
exposure reduction method and the objective level approach be operated simultaneously, at
least for the time being, since this will ensure continuity in the monitoring of particulate
matter and a better understanding of the effectiveness of both local and national measures
being undertaken to reduce levels under the exposure reduction approach. Please also see
earlier comments on this issue.
What are your views on moving the policy framework to include PM2.5 as well as PM10?
22. The inclusion of PM 2.5 in air quality policy is relevant for the protection of human health, as
there appears to be a large association between mortality and long-term exposure to PM 2.5
concentrations. PM10 should continue to be included in the policy framework, as exposure
to coarse fraction particles is not considered harmless. It would be advisable to retain
existing PM10 monitoring to maintain the long term data set already established and to add
to our knowledge of the relationship between the different particle size fractions. Monitoring
both pollutants will enable the effectiveness of both local and national measures
implemented to be assessed. In terms of Local Air Quality Management, it would be very
difficult to meet an objective for PM2.5, so a national exposure reduction approached is
supported.
Should the UK Government and devolved administrations wait until a European
exposure reduction objective is finally agreed in Europe before adopting a new national
objective for particles?, or should the UK Government and devolved administrations
adopt new exposure reduction and concentration cap objective for PM2.5 now and
review them after final agreement has been reached in Europe?
23. Yes, it would seem sensible to wait until a new exposure reduction objective is agreed in
Europe. Any decision regarding whether to adopt new measures for PM2.5, prior to
European Union requirements for action on this, must take account of any consequences
for the economy as a whole and for EU. Boroughs are keen to ensure any further
monitoring burdens placed on local authorities are at the same time met with improved
resourcing.
What are the priorities for future work?
24. Much of this has been covered in our earlier comments, regarding the adequacy of the
review. Possible key areas for future work include: focusing on energy reduction in
commercial buildings and improving the link between energy efficiency and air quality;
improvements in modelling pollutants to reduce uncertainties in predictions, especially
directly emitted NO2; further clarity of the role that local authorities have and the measures
they can implement; investigation of transport demand management, technological
solutions and social drivers to develop options and solutions for reducing pollution; and
understanding the synergies between air quality and climate change issues.
Do you agree that the UK Government and the devolved administrations should design
policies to ensure the optimal improvements for both air quality and greenhouse gases
(climate change)?
25. We agree, and we also refer you to our earlier comments on this issue. It is essential that
policies to deal with climate change do not conflict with improving local air quality, so
ensuring optimal improvements and avoidance of contradictory policy is essential. Local
authorities do not want to be in a situation whereby they are legitimately pursuing actions
required for air quality measures that conflict with climate change goals.
Yours faithfully,
Nick Lester
Director, Transport, Environment and Planning
Association of London Government
Appendix 2: ALG response endorsed by TEC Elected Members
Ekoere Deinne
Air and Environment Quality Division
Zone 7D/13
Ashdown House
123 Victoria Street
London SW1E 6DE
Contact:
Direct Line:
Fax:
Email:
Jared Boow
020 7934 9951
020 7934 9950
[email protected]
Our Reference:
Your Reference:
Date:
ALG AQS response
21 August 2006
Dear Madam,
Re: The Association of London Government’s response to Defra’s consultation on the
review of the National Air Quality Strategy.
As you will be aware, the ALG recently sent a response to Defra regarding its consultation on
the review of the National Air Quality Strategy. This response has now been endorsed by
elected members of the ALG Transport & Environment Committee (TEC), but with the following
additional point:

The government analysis shows that policy option G, to apply a Low Emission Zone
(LEZ) on a national basis, is not expected to be beneficial to society as a whole and
will generate some negative net present values. This is a concern that the ALG has
with the Mayor’s proposal to introduce a London-wide LEZ. We believe that the
marginal benefits offered, compared with the improvements that TfL predict will
occur without an LEZ, make it difficult to justify the significant costs to vehicle
operators.
Yours faithfully,
Nick Lester
Director- Transport, Environment and Planning
Association of London Government