Response to National Plan consultation

Sarah Legge

Chair of the Air Quality Committee Environmental Protection UK

Evidence• Without the evidence we cannot see the size of the

problem, or the scale/ambition needed for actions.• Issues with COPERT emission factors, evidence suggests

these underestimate urban emissions by factor of 5-7 for diesel cars. • If emission factors are optimistic, an extra 22 zones will be

non compliant (and 8 zones have bigger problem). But where are the measures set out for these?• We can’t make the same mistake as the 1990s, and not take

action because the emission factors say there is no problem. • No data on model, no data on primary NO2, used low

mortality factor.

National Action• The National Plans lack actual national government action. • There were missed opportunities for air quality

improvements for departments other than Defra. • The plans fail to adequately harness the potential for air

quality benefits (and focus these where most needed) from other government initiatives, such as • DfT’s low emission vehicle programmes, • DECC’s energy and heat efficiency initiatives • HMT’s vehicle taxes, • as well as normal mechanisms eg building regulations,

development control and local transport plans.

Role of LAQM • There are no measures to ensure local authorities have all the

powers they need to be effective.

• Will the new LAQM guidance give strong support to LAs, and will development and transport planners be required to prioritise air quality?

• Many AQAPs are old and have projects with no impacts in the future which will not help achieve compliance by 2020.

• The National Plan needs to include further information on more forward facing schemes, and on how national government will support their development and implementation.

• Many local authority air quality teams under increasing pressure and threat, with reduced resources and support.

CAZ• Is a CAZ workable and is it the best form for local

authorities to address air pollution and health?

• Will government support and encouragement for CAZ be sufficient to overcome the substantial barriers around political will, government funding and technical feasibility?

• What happens if LAs don’t want to?

• We doubt that a CAZ could be operational by 2020.

• No information on financial support for LAs.

• No mention of national databases and systems.

CAZ Standards• A CAZ must address NOx, PM and primary NO2. Some

thought for CO2 also useful. • National framework makes sense, provided it has some

flexibility to tailor to local conditions. • LAs should be able to go further, eg taxis in ULEZ.• Restrictive packages may not be suitable, eg bus and

taxi LEZ can be implemented without cameras.• If based on Euro standards (or test cycle), these must

be proven. • Other issues with implementation include misuse of

emissions abatement equipment, poor maintenance of equipment or vehicle, and checks.

Other CAZ elements?• Mobile machinery• Planning measures, eg EPUK/IAQM best practice• Small scale energy generation, biomass and STOR• London’s Low Emission Neighbourhood concept• Local incentives, eg parking charges

Clean Air Alliance UK• The Clean Air Alliance wants the government to act on the

latest recommendations of the Environmental Audit Committee. Priorities are: • Developing and promoting a national framework for low

emission zones;• Promoting low emission and electric vehicles;• Implementation of emission controls for non-road mobile

machinery;• Promoting public awareness (for example, CAAUK is planning to

launch an annual air quality action week);• Promoting guidance for reducing air pollution through the

planning system and development control (in May this year, EPUK and IAQM published joint guidance);

• Ensuring the continued availability of high resolution clean air data.

Summary• Lack of evidence made it very difficult to properly assess

the plans• Optimistic emissions factors hiding the problem• Plans are unlikely to meet the EU limit values and to

adequately reduce air pollution impacts on public health• Where is national action in the national action plan? • Missed opportunity for air quality benefits from non-

Defra programmes• If requiring LAs to fix the problem, do LAs have the

necessary legal powers?• CAZ – lack of funding and political support, need for

government action. Are Euro standards best?

Thank you.

Sarah LeggeSarah@slhenvironmental.co.uk

And don’t forget -EPUK Annual Conference

18 November 2015, Birminghamwww.environmental-protection.org.uk