UWE response to the Defra Air Quality Plan consultation

Dr Ben WilliamsAir Quality Management Resource Centre, UWE

Ben3.williams@uwe.ac.uk12th November 2015

Outline

• General Comments• Model Assumptions• Clean Air Zones• National Responsibilities• Points of Clarification

General Comments• Disappointed that despite a public health crisis we still haven’t achieved

compliance within legally defined timeframes.

• This plan represents the national government’s interpretation of the Supreme Court’s judgement of “…the need for immediate action”.

• Disappointed with the lack of clarity and lack of national government action within the plan.

Model Assumptions• Data used in COPERT 4 (v11) are not thought to be representative of real-world

emissions but are the basis for the modelling undertaken in the proposed Plan.

• Literature suggests real-world emissions are somewhere between 4 and 7 times type-approval limits1.

• Alternative scenario seems more realistic, but needs to be properly assessed when data and assumptions are made available.

• On the basis of the alternative scenario 30 zones and agglomerations would be non-compliant by 2020.

1 http://europa.eu/rapid/press-release_IP-15-5945_en.htm

Clean Air Zones• Unclear how many of the six local authorities have stated their desire to implement

CAZs.

• How will local authorities fund the scoping, development, implementation and management of CAZs?

• If local authorities decide not to implement CAZ then the modelled outputs won’t be appropriate for that area. Is there a plan B?

• If local authorities don’t take up CAZs will they be held accountable for national government’s failure to comply with the Ambient Air Quality Directive?

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/311449/Annex_A_Letter_to_LAs_on_NO2_infraction.pdf

National Responsibilities• National government bears responsibility for complying with the Ambient Air Quality Directive.

• The national government needs to develop an air quality plan that actually addresses the problem instead of masking it with model outputs.

• The national government needs to make clear that it will support stronger planning decisions by local authorities that seek to reduce or limit air pollution emissions.

• The national government has to support the implementation of more stringent testing regimes and ongoing testing of in-service vehicles to ensure standards are met during the lifetime of the vehicle.

• Do proposed amendments to type-approval testing cycles go far enough?

Points of Clarification• Which aspects of SL-PCM have been streamlined and how does this differ from the standard

PCM model?

• Clarification as to the basis of any conformity factors used.

• The data and assumptions used in calculating the “alternative scenario”.

• Have Defra undertaken a survey of local authorities to determine the likelihood of CAZ uptake? If so, we would expect these data to be made publicly available.

• Under what circumstances, if any, will local authorities bear the cost of any fines imposed as a result of non-compliance?