Air Quality Strategy
In 1997, the UK became the first country in Europe to develop an air quality strategy, following lobbying from Environmental Protection UK (formerly NSCA). The Strategy sets out the air quality issues facing the UK, the targets which the Government has set, and policies in place to attempt to achieve those targets.
The Strategy has undergone a series of reviews – the National Air Quality Strategy was last updated in 2007 – Air Quality Strategy for England, Scotland, Wales and Northern Ireland. It is now out of date and lacks ambitious targets and actions to tackle air pollution problems.
Air Quality Standards
The Strategy includes UK air quality standards and objectives for reducing levels of health-threatening pollutants. These include benzene, 1,3-butadiene, carbon monoxide, lead, nitrogen dioxide, particles, sulphur dioxide, ground level ozone, and PAH. The levels of reduction have been set on the basis of scientific and medical evidence on the health effects of each pollutant, and according to practicability of meeting standards. All of these standards, except those for ozone and PAH, are subject to regulations made under the Environment Act 1995, and many are the result of UK incorporation of European law. Click here to view a summary table showing all the objectives.
Objectives set by EU directives are legally binding, and the European Commission is able to take action against the UK Government if standards are not met. Some of the objectives are given legal status through the Air Quality Regulations 2000 or within the Local Air Quality Management regime, however Local Authorities are not held responsible by the law if objectives are not met in their area. The original intention behind this was to avoid placing blame on local authorities when exceedences arose from activities and sources beyond their control, however in practice is has also meant that direct responsibility for achieving the objectives is shared and diffuse.
The 2007 Strategy introduced a new exposure reduction regime for PM2.5, tiny particles associated with respiratory and cardiovascular illness and mortality which have no known safe limit for human exposure. The new regime will, for the first time, attempt to reduce the exposure of all urban dwellers, alongside the existing method of reducing hotspots of PM exposure. This approach will help to improve human health across our towns and cities and is now replicated in European legislation by the Ambient Air Quality Directive.
The Strategy also makes links between air quality and climate change, incorporating the recommendations of the Air Quality Experts Group report on the subject. There are also policy links with the work of the Committee on the Medical Effects of Air Pollutants (COMEA
P) and evidence of links to the recent Royal Commission on Environmental Pollutants report “The Urban Environment” .
However, Environmental Protection UK were disappointed that the proposals for PM2.5 were not more challenging. We firmly support a 20% reduction cap in concentrations of PM2.5 with a concentration cap of 20 µg/m3, as opposed to the 15% reduction and 25 µg/m3 cap in the final strategy. We also hope that the Strategy will encourage Government to adopt a more joined up approach for air quality and climate change.
Local Air Quality Management
One of the main components of the UK Air Quality Strategy is Local Air Quality Management (LAQM). Since 1997, all local authorities have been assessing the air quality in their area and, where a problem is found, action plans have been developed to address the situation.
The LAQM framework is currently under review by the UK government. Environmental Protection UK are lobbying for an effective system to improve air quality and protect human health, and have responding to the three rounds of consultation with robust responses. Details of the consultations and our responses can be found under Air Pollution Laws.
Under LAQM, local authorities must investigate the levels of pollution in their area. The most obvious method is to measure concentrations of pollutants directly. However monitoring equipment is often expensive and, and in order to obtain good quality data it usually needs to stay in place for long periods of time. This means monitors cannot give a complete picture of an area, so mathematical models are used to predict what the air quality would be like in other areas, based on measurements and known sources of pollution, such as roads and industrial plant.
Models are also used to predict trends in pollution levels, effects of weather conditions and source activity patterns, such as traffic levels, vehicle types, etc. Models can therefore be used to assess whether National Air Quality Objectives are likely to be breached in their target year. This process of monitoring, data collection and predictive modelling is known as “review and assessment”.
If, after carrying out review and assessment, a local authority finds that one or more of the National Air Quality Objectives is likely to be breached, it is obliged by law to declare an Air Quality Management Area. Over 200
local authorities have declared an Air Quality Management Area and the majority of these are for NO2 or PM10 .
Once an Air Quality Management Area is declared, the local authority must develop an Action Plan which sets out how it will use the powers at its disposal in pursuit of the National Air Quality Objectives. However, local authorities are not obliged to achieve the objectives, as they do not have sufficient control over all of the sources which could potentially give rise to the breach. For example in England, major roads and motorways are usually under the control of the Highways Agency, and large industrial processes, including power stations, are regulated by the Environment Agency. The great majority of Air Quality Management Areas have been declared because of emissions from road transport.
Guidance on LAQM
Environmental Protection UK (formerly NSCA) has produced six guidance notes for local authorities on Local Air Quality Management; these are intended to supplement and extend the Statutory Guidance published by the Government. One of these, on Air Quality Management Areas, was revised in the light of the first round of local authority air quality review and assessment studies. The six notes are:
- Consultation for LAQM: The How To Guide
- Air Quality Management Areas: Turning Reviews into Action
- Air Quality Management Areas: A Review of Procedures and Practice for Local Authorities
- Air Quality Action Plans: Interim Guidance for Local Authorities
- Air Quality: Planning for Action
- Development Control: Planning for Air Quality (2010 update), which has since been updated here.