How satisfied are you that the proposed measures set out in this consultation will address the problem of nitrogen dioxide as quickly as possible?
Very dissatisfied, and disappointed.
As it stands, the draft UK Air Quality Plan is weak and incoherent, severely lacking in tangible actions and references to health. Furthermore, it fails to comply with the High Court order to reduce air pollution in the shortest possible time in the following ways:
- It does not make recommendations for Clean Air Zones (CAZs) that are based on the evidence presented in its own technical report.
- It does not mandate local authorities to create CAZs.
- It does not encourage interventions to improve air quality with the widest benefits to health.
- It does not address national policy measures driving continued demand for diesel and highly polluting vehicles, for example making diesel vehicles that exceed emission limits under real life conditions more expensive to run than less polluting equivalents via vehicle excise and fuel duty.
Doctors Against Diesel and Medact are pleased to take this opportunity to respond to Defra/DfT consultation on its Air Quality Plan for tackling nitrogen dioxide (NO2) emissions in the UK. However, we are very dissatisfied with the draft plan that has been put forward. The draft plan will not enable the government to meet its legal duty of ensuring that legal limits of NO2 are met in the shortest time possible. Therefore, the draft plan, if legislated, would lead to the unnecessary prolongation of levels of pollution that continue to threaten the health of everyone of all ages.
As is made clear in the technical report, poor air quality is the largest environmental risk to public health in the UK and disproportionately impacts vulnerable groups, including the elderly, children and people already suffering from pre-existing conditions. In their joint report ‘Every Breath We Take’ published last year, the Royal College of Physicians and the Royal College of Paediatrics and Child Health also highlighted that pregnancy, infancy and early childhood are critical times when many of the body’s systems are developing, and the heart, lungs, brain, immune, and endocrine systems are all at risk from pollution.
We are concerned that, unless the CAZs are based on the evidence set out in the technical report, they will be ineffective and that the label itself misleading to the public. The technical report highlights the fact that charging for entry into CAZs is the most effective intervention for the reduction of NO2 levels, with an average 18.3% reduction in mean NO2 concentrations in the first year, and 24% over ten years. Other measures such as retrofitting and scrappage schemes are relatively ineffective. They are estimated to have very minimal direct impacts on NO2 concentrations in the first year, and only slightly more impact over ten years, albeit they do play a role in increasing the feasibility of introducing a charging CAZ.
The technical report makes clear that charging for entry into CAZs is the fastest route to compliance with legal limits, which are achievable by 2021 if adopted by local authorities. If charging is the most effective route to compliance in the shortest possible time, it is concerning that the Plan asks local authorities to prioritise other options that are “at least as effective.” Charging zones are described as a final option, to be considered only if local authorities “fail to identify equally effective alternatives”. To appraise and cost all other options, when an effective one has already been researched and reported on, is a wasteful and resource intensive activity for local authorities that are currently over-stretched. This risks discouraging local authorities from submitting requests to the Government for a CAZ with a charging zone. The demand to demonstrate value for money and assess economic impacts will compound this, and if the government requires a comprehensive local impact assessment to be conducted they must make resources available to enable this.
Given the above and without a clear mandate requiring more than the current five UK cities to implement CAZs, improving air quality and reducing carbon emissions will not be achieved within the shortest time possible (if at all), resulting in needless excess mortality and morbidity, and additional costs to the NHS and to communities. This is particularly important, given that the technical report notes that introducing charging schemes will likely take “until the end of 2020”. The central projection in the modelling used by the technical report indicates that 27 CAZs are required to achieve the desired outcome. It is therefore critical that the final plan published in July includes a mandate for additional CAZs with charging zones in all the 27 cities identified.
In addition, the draft Plan identifies the role of the vehicle tax regime in worsening air quality by encouraging the increase of diesel vehicles, but no measure has been proposed and the matter has been left to the Treasury to explore at a later date.
Finally, the public health case for tackling air pollution by encouraging modal shift is overwhelming, enabling people to avoid or reduce the use of private vehicles in favour of cheaper and healthier transport modes such as walking and cycling. The benefits to health include both the reduced rates of stroke, heart disease, and chronic lung disease from improved air quality; and reductions in obesity-related diseases as a result of increased physical activity. Prioritising active forms of travel also promotes social connectivity and good mental health while helping to reduce noise pollution and traffic injuries. It represents a sustainable solution to addressing air pollution and climate change while maximizing benefits to people and the economy. However, there is no commitment to invest in walking, cycling and public transport infrastructure.
What do you consider to be the most appropriate way for local authorities in England to determine the arrangements for a Clean Air Zone, and the measures that should apply within it? What factors should local authorities consider when assessing impacts on businesses?
The technical report accompanying this consultation identifies charging CAZs as the most effective way to reduce levels of NO2 in the shortest time possible. In addition, the 2015 air quality plans identified mandated charging CAZs as more effective than voluntary CAZs. As stated above, it is therefore critical that the final Air Quality plan mandates the 27 non-compliant local areas to implement CAZs.
The UK government or devolved administrations, however, should also mandate the category of charging CAZs, based on the evidence, to include all the types of vehicles that make a significant contribution to the problem, including newer diesel vehicles that may meet the Euro-6 standard but which we now know, exceed it in real-world driving conditions.
Charging CAZs should be complemented by supporting measures to help individuals and businesses make cleaner transport choices whilst avoiding charges. People should be helped to switch to cleaner forms of transport. This could include a range of policies such as a targeted scrappage scheme, which incentivizes uptake of alternative forms of transport such as walking, cycling and using public transport.
Local authorities should also be encouraged to consider the role of procurement and staff travel in contributing to local pollution. Schemes to reduce deliveries should be encouraged both as air quality improvement and cost efficiency measures.
With respect to the factors that local authorities should consider when assessing impacts on businesses, the costs of inaction must also be assessed. Defra’s own modelling estimates the costs to society of air pollution to be over £20 billion annually, and the costs to health and health services should also be considered.
How can government best target any funding to support local communities to cut air pollution?
What options should the Government consider further, and what criteria should it use to assess them? Are there other measures which could be implemented at a local level, represent value for money, and that could have a direct and rapid impact on air quality? Examples could include targeted investment in local infrastructure projects. How can government best target any funding to mitigate the impact of certain measures to improve air quality, on local businesses, residents and those travelling into towns and cities to work? Examples could include targeted scrappage schemes, for both cars and vans, as well as support for retrofitting initiatives. How could mitigation schemes be designed in order to maximise value for money, target support where it is most needed, reduce complexity and minimise scope for fraud?
As the technical report makes clear, charging zones are the most effective measure that will help local authorities reduce both air pollution levels and greenhouse gas (GHG) emissions. Charging zones should therefore be recommended to local authorities as a cost-effective measure that will protect health from the joint challenges of climate change and air pollution. These should be complemented by measures to help individuals and businesses move to cleaner forms of transport.
Targeted investments in scrappage schemes, for both cars and vans, as well as support for retrofitting initiatives will have a smaller direct impact on air pollution, but will have a greater indirect benefit by making charging zones publicly acceptable. The Government must ensure that any diesel scrappage scheme is available to all car-owning individuals and businesses in high pollution areas – as we know that the amount of NO2 produced by a car depends more on the model than the age or Euro-standard of the vehicle.
As previously stated, the greatest health gains will be achieved with more investment in public transport, and walking and cycling infrastructures. Uptake of modal shift could be incentivized with a scheme that offers vehicle exchange in return for help with the cost of an ultra-low or zero-emission vehicle, subsidised car club membership, free public transport season tickets or e-bike purchase loans, as has been proposed by the Mayor of London.
We would also like to see the government produce a comprehensive cross-departmental analysis of the policies that have contributed to the current problem. For example, vehicle excise duty could be optimized so as to promote low emission vehicles, rather than the current blanket rate applying to all but the very lowest emission cars available. This would benefit air quality around the UK, and not just in targetted hotspots. This would help ensure that local problems don’t develop in previously less polluted areas.
Retrofitting schemes should be widely publicised through the Office for Low Emission Vehicles (OLEV). The public sector, including the NHS, should set a high and visible standard with its own transport fleet.
We also want to see greater pollution monitoring and reporting, particularly around the public sector, including school and health service buildings. This is in order both to raise awareness of the necessity of CAZs, and to ensure people with chronic conditions are aware of the recommended safe level of activity on any given day.
We also support the call for a national public health awareness campaign, building in particular on National Clean Air Day on June 15.
How best can governments work with local communities to monitor local interventions and evaluate their impact?
Citizen science should be encouraged so that people and/or organisations can monitor themselves and then use that information to plan local interventions.
Partnering with academia should also be encouraged to evaluate the impacts using standardised and reproducible methods. The evaluation of complex interventions that benefit both the environment and health through, for example, acting to increase active travel and reducing dependence on private motorized vehicles, needs to be prioritized. We also wish to highlight the need for research and evidence to be translated into policy.
Which vehicles should be prioritised for government-funded retrofit schemes?
Vehicles which do not meet emission testing standards in real word driving conditions.
What type of environmental and other information should be made available to help consumers choose which cars to buy?
Doctors Against Diesel believe that more transparent comparisons between different models will enable consumers to make a more informed choice about which vehicle they buy, and given rising awareness of the health impacts of diesel will help accelerate the transition to lower emission vehicles. We are concerned that the answer to diesel is not to encourage increased petrol car sales, as these are clearly a major source of greenhouse gas emissions and would compromise our ability to meet the UK commitments under the Climate Change Act. Clearer consumer labelling should include measures of particulates, carbon dioxide and NO2 to give an accurate picture of the overall pollution impact of a vehicle.
Consumers should be provided with the information that assures them that the vehicles they purchase are as clean on the road as the legal limits allow in the laboratory tests. The information should help the consumer understand how well the vehicle performs in the real world for both air pollution and climate change emissions, compared to other similar vehicles. The information should also help consumers understand whether their vehicles comply with air pollution measures, such as Clean Air Zones and any future changes to the vehicle tax regime.
Anticipated changes to vehicle taxation, fuel duty or charging zones should be signaled to the public as early as possible. This is particularly relevant to the question of devolving decision making to local authorities: a more coherent national coordinated plan to reduce emissions will do a lot to reassure the public that interventions will not be patchy and unpredictable, in order to help drive consumer choice.
How could the Government further support innovative technological solutions and localised measures to improve air quality?
As well as supporting the uptake of active travel, the government could support advances in technology that enhance public transport information and payment systems, for example, real-time bus arrival updates and initiatives like the oyster card.
Steps should also be taken to encourage the use of greener construction machinery by developers, e.g. hybrid generators and lighting rigs powered by hydrogen fuel cells.
Do you have any other comments on the draft UK Air Quality Plan for tackling nitrogen dioxide?
This is an opportunity to improve the air quality of the streets where we all live, work and play. This would have significant benefits for the health and wellbeing of all the people of the UK. At present, the draft plan falls far from capturing this positive and achievable opportunity. A plan that will ultimately tackle air pollution is a plan focused on people.
With input from members of Doctors against Diesel
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