Clean Air Strategy consultation response

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Name ​(Required)​ Keith Taylor MEP

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Health and the economy
The environment and the economy
Health, the environment and the economy
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If you answered Yes, please give your reason

1. Understanding the problem

Air pollution comes from many sources. Pollutants can travel long distances and combine
with each other to create different pollutants. Emissions from distant and local sources can
build up into high local concentrations of pollution. The UK has set stringent targets to cut
emissions by 2020 and 2030. The goal is to reduce the harm to human health from air
pollution by half. A robust evidence base, backed by the most up to date science is essential
to help us achieve this.

Proposed actions
● We are investing £10m in improving our modelling, data and analytical tools to give a
more precise picture of current air quality and the impact of policies on it in future.
● We will increase transparency by bringing local and national monitoring data together
into a single accessible portal for information on air quality monitoring and modelling,
catalysing public engagement through citizen science.

Q1. What do you think about the actions put forward in this chapter (see
drop-down menu above)? Please provide evidence in support of your
answer if possible.
Whilst this chapter provides broad information on the pollutants under consideration, there
are just two lines about the government’s broad intentions to tackle these massive problems.
Much more information on how the £10 million is to be invested is required before
substantive comments can be given.

Modelling is helpful, but what is truly required is much more sophisticated and detailed
monitoring of on the ground emissions, real-time and across the spectrum of pollutants. It is
important not only to collect the data, but to take action based on what this real information
reveals, as well as scenarios and models. What will be modelled? Which data will be
derived? Who will be analysing it? What will the policy and real world implications of this
information gathering be? How does this action contribute to solving the problem? Whilst a
more precise picture of the problem is the objective, how this translates to ‘the impact of
policies to improve it in the future’ is incredibly vague and in reality, in and of itself does
nothing to guarantee improved air quality.

Increasing transparency is important - this can be done by making information about legal
and safe levels of pollutants and their sources readily available. The collated graph in this
chapter which demonstrates downward trends of all pollutants is misleading. Using the
information about where the pollutants are in relation to their recommended safe levels
would be a very different graph, and perhaps one that would be more useful and more in
keeping with the ‘transparency’ that the objectives of the consultation are striving for.

The action set out in section 1.5 of the consultation document suggests that there will be a
single accessible portal for information on air quality monitoring and modelling and
catalysing engagement through citizen science. There needs to be more information about
the onus that will be placed on local authorities in terms of monitoring. At the current time,
monitoring of many of these pollutants is scant, upkeep of monitoring equipment can be poor
and gaps in the data are often unexplained and can skew the severity of the problem in
given areas. There needs to be more support for local authorities to improve their
monitoring, as well as the provision to share the data that is generated at the national level.
Are there formalised requirements in place for reporting, or will these be covered as part of
the proposed measures? Will any existing reporting mechanisms be updated to take account
of the new proposed strategy? There are no details here to answer any of these questions.

This consultation discusses the emissions from multiple sectors, it would be useful to
understand more about how industrial emission reporting will be linked into this ‘single
accessible hub’ to ensure that the whole picture is clearer - or perhaps it would be that
industry will report at the local level to local authorities - either way this should be explicated.
Moreover, action to improve transparency should not stop with monitoring. More detail about
the processes through which this centralised data will be used to formulate and implement
policy to improve air quality is fundamentally important.

Citizen science is an important consideration in understanding the severity of the problem,

but the relationship to the proposed centralised portal is unclear - will citizens be providing
their data, how will this information be verified and analysed at scale? Is the onus on the
people to provide information? ‘Catalysing public engagement through citizen science’ is a
very vague assertion, especially when the context of the action is itself very ambiguous.
Much more information about the details of this action and its implications for policy are
needed.

Q2. How can we improve the accessibility of evidence on air quality, so

that it meets the wide-ranging needs of the public, the science
community, and other interested parties?
Reporting at the local level needs to be standardised and the monitoring equipment needs to
be accurate and reliable so that the data is robust. With better data, the evidence on air
quality is improved. Local authorities should be provided with the resources they need to
install, manage and maintain real time monitoring stations. There should be clear guidance
on how to report the information and how it will be analysed. There needs to be adequate
detail to ensure that policy decisions can be based on actual information about the severity
of the problem and modelling should be reserved for understanding future trends based on
actual information.

There needs to be cross-sector working between science and policy communities to ensure
that information is understood and can be easily translated into policy actions, but also so
that scientific developments can be appreciated and facilitated through public sector support.
The public needs access to scientific information, but it also needs easy to digest, readily
understandable resources, not just about pollutants, their causes, impacts and how to
address them, but also about what government and local authorities are doing to tackle the
problem.

2. Protecting the nation's health

Air quality is the largest environmental health risk in the UK. It shortens lives and contributes
to chronic illness. Health can be affected both by short-term, high-pollution episodes and by
long-term exposure to lower levels of pollution. There are small things we can all do that will
make a big difference to emissions locally and nationally. Effective communication of health
messages about air pollution can save lives and improve quality of life for many.

Proposed actions
● We will progressively cut public exposure to particulate matter pollution as suggested
by the World Health Organisation. We will halve the population living in areas with
concentrations of fine particulate matter above WHO guideline levels (10 μg/m3) by
2025.
● We will provide a personal air quality messaging system to inform the public,
particularly those who are vulnerable to air pollution, about the air quality forecast,
providing clearer information on air pollution episodes and accessible health advice.
● We will work with media outlets to improve public access to the air quality forecast.
● We will work to improve air quality by helping individuals and organisations
understand how they could reduce their contribution to air pollution, showing how this
can help them protect their families, colleagues and neighbours.
● We will publish updated appraisal tools and accompanying guidance this summer to
enable the health impacts of air pollution to be considered in every relevant policy
decision that is made.
Q3. What do you think of the package of actions put forward in this
chapter (see drop down menu of proposed actions above for a
summary)? Please provide evidence in support of your answer if
possible.
Improving information about risks and episodes is helpful - but the objective of this chapter is
protecting the nation’s health - information provision is just one, preliminary step in achieving
this objective. Information measures put the onus more on individuals and communities to
take action, and whilst this can contribute to a reduction in air pollutants, it would be more
effective if these proposed actions were more substantive, tracing the sources of the
emissions and proposing policy measures that could reduce pollution from these directly.

The proposed actions only seek to halve the population living in areas which exceed PM
WHO levels, but doesn't mention other air pollutants as a target. Attention should also be
paid specifically to ultrafine particulates. Focusing attention on PM alone, does not take into
account the importance of the size of particulates, which is a significant consideration.
Moreover, limiting targets to PM and seeking to halve the number of people affected simply
isn’t an ambitious enough target to tackle the problem effectively.

The lack of substantive mention of PM in the Government strategy produced after the legal
action on NOx is at odds with this document, where it is treated more seriously. There is a
need for better coordination between strategies.

Q4. How can we improve the way we communicate with the public about
poor air quality and what people can do?
The data provided in documents (such as this consultation) needs to clearly articulate what
the safe limits are and show where current UK and local levels are in relation to these limits.
Using different scales or measurements does not provide a clear indication of the severity of
the problem or the threats to health.

Information should clearly discuss sources and causes and information about what the
government is doing, as well as how impacts can be avoided and sources reduced or
removed.

Real time and easy to understand data should be provided.

3. Protecting the environment

This strategy is a key part of delivering our 25 Year Environment Plan. Air pollution has
direct impacts on the natural environment, contributing to climate change, altering
biodiversity, reducing crop yields and polluting oceans. Cleaner air will directly benefit plants,
animals and habitats as well as creating a better environment for everyone to live, work and
thrive in.
Proposed actions
● We will monitor the impacts of air pollution on natural habitats and report annually so
that we can chart progress as we reduce the harm air pollution does to the
environment.
● Later this year we will provide guidance for local authorities explaining how
cumulative impacts of nitrogen deposition on natural habitats should be mitigated and
assessed through the planning system.

Q5. What do you think of the actions put forward in this chapter (see
drop-down menu above)? Please provide evidence in support of your
answer if possible.
As with some other actions in different chapters of this consultation document, details on the
proposed action are minimal. How will the impacts of air pollution on natural habitats be
monitored and reported - who will be responsible for this task. Charting progress in reducing
the harm caused by air pollution is a challenge when the measures laid out in the strategy
are passive and not actively engaged in reducing the harm. Measuring and understanding
impacts is important and this is welcome, but there needs to be much more information
about how the emission reductions will be delivered.

Similarly, the guidance for local authorities on nitrogen deposition will be a useful document,
but is again lacking in any details about how the problem at hand can be reduced and
avoided. And at the time when a major overhaul of the planning system is underway through
the NPPF, the lack of integration between these strategies means there is a possibility that
this guidance will be overlooked by local authorities. Therefore adequate steps need to be
taken to ensure that this information is prominent.

Q6. What further action do you think can be taken to reduce the impact
of air pollution on the natural environment? Where possible, please
include evidence of the potential effectiveness of suggestions.
Many impacts are discussed in the chapter text - for example, the crop damage caused by
ground level ozone and microplastics from roads and vehicles, but there are no associated
actions in place to reduce the damage caused. The contextual information in this document
could serve as a basis for a comprehensive plan which lays out action on each of the
impacts with a real, tangible plan for tackling each issue. Instead information is provided on
the causes of the pollution, but details on how the government will address them is missing.

The issue of air pollution needs to be placed in the context of the bigger, long-term picture.
As well as researching to understand how tyres and brakes pollute the air and the marine
environment, the government should be looking practically at how to reduce the amount of
traffic on the roads generating the PM pollution discussed. Are new roads going to help
address these issues or make them worse? Larger scale thinking is required - the
Environment Plan and the Clean Growth Strategy have not been thought of in tandem and it
is clear from the information here that the Clean Air Strategy will be similarly disconnected. If
the government really intends to leave a better environment than it inherited, it needs to start
thinking across policy boundaries.

4. Securing clean growth and driving innovation

This strategy contributes to the government’s action on clean growth. Action to clean up the
air will boost productivity and economic growth. We will make the UK a world leader in the
development, use and export of goods and services focused on tackling air pollution.

Proposed actions
● In partnership with UK Research and Innovation, we will seek ways to support further
investment in Clean Air innovation to enable the development of novel technologies
and solutions that tackle emissions from industry, vehicles, products, combustion and
agriculture and support both improvements in air quality and decarbonisation.
● We will make the UK a world leader in goods and services focused on tackling air
pollution.
● Future energy, heat and industrial policies will together improve air quality and tackle
climate change. Phasing out coal-fired power stations, improving energy efficiency,
and shifting to cleaner power sources will reduce emissions of air pollution as well as
carbon. As we phase out oil and coal heating, we will ensure this transition improves
air quality wherever possible and cost effective to do so. In addition, the government
will conduct a cross-departmental review into the role of biomass in future policy for
low carbon electricity and heat, focusing on the air quality impacts. The proposed
way forward will be set out in the final Clean Air Strategy.
● We will minimise the air quality impacts of the Renewable Heat Incentive Scheme, for
example by tackling non-compliance and consulting on excluding biomass from the
RHI if installed in urban areas which are on the gas grid. We will work across central
and local government to put a plan in place. In addition, we will consult on making
coal to biomass conversions ineligible for future allocation rounds of the contracts for
difference scheme.
● We are seeking evidence on the uses of non-road diesel, mainly in urban areas,
considering the air quality impacts and the potential for market distortion. The
Treasury has also announced it will review how alternative fuel rates line up with
rates of petrol and diesel ahead of Budget 2018.
● We will cut emissions from non-road mobile machinery and give local authorities
tough new powers to control the use of such machinery where it is causing an air
pollution problem.
● Green Great Britain Week, starting in autumn 2018, will engage the public on air
quality, alongside climate change, and highlight the economic opportunities it offers
for the UK.
Q.7. What do you think of the package of actions put forward in this
chapter (see drop-down menu above for a summary)? Please provide
evidence in support of your answer if possible.
How will the leadership in the development, manufacture and use of technologies, services
and systems that tackle air pollution be achieved? - what advantages will be maximised,
what level of funding and support will be provided? More information on the specifics are
required here. And technology alone cannot solve the problems. As with the Industrial
strategy and Road to Zero, more needs to be done to improve existing technologies and the
fundamental causes of the problems - not simply by investing in novel technologies and
more pilots. These schemes are conducted in isolation and there is seldom follow up or
scaling up. They can also mean that there is less money for on the ground issues. For
example, industrial processes need reviewing, urban areas need fewer vehicles, farms need
better practices, energy needs to be harvested, not combusted. Research and development
into new technology is not the answer to all problems, real substantive societal change is
also needed.

Perhaps examples of the goods and services that will be developed to address air pollution
would be useful in this proposed action as with little insight into the kind of initiatives that
would receive investment, it is difficult to see the value of this measure.

Phasing out oil and coal heating is mentioned in section 4.3 - there is no mention of gas,
which makes clear that ‘integrating both air quality and climate change considerations into
government policies such as energy’ is simply not taking place. Gas is not a clean fuel, it will
not contribute to tackling climate change. This plan, as with the NPPF, 25 year environment
plan and Clean Growth Strategy, needs to acknowledge that fossil fuels can no longer be
exploited. No policy which allows hydraulic fracturing, acidisation and other means to
generate fossil fuel-derived energy can be considered to integrate climate change or air
quality considerations. When support for renewable energy is at a 10-year low, despite cost
parity being achieved much earlier than expected, and with the government circumventing
local democracy to permit drilling for gas, this package of actions designed to promote
‘clean’ growth cannot be taken seriously.

In the proposed actions of bullet 3, it talks of "future energy.... policy will ... improve air
quality". This is completely contradicted in Government approval of new fracking regulations
when Ministers would have been aware of a suppressed 2015 report from its own Air Quality
Expert Group 'Potential Air Quality Impacts of Shale Gas Extraction in the U.K.' Which
concludes that the UK evidence base is improved before significant shale gas extraction
begins. Additionally it stresses the necessity - at a local level - for a full well lifecycle analysis
(footnote 12 page 44) See:
https://uk-air.defra.gov.uk/assets/documents/reports/cat09/1807251315_AQEG_Shale_Gas
_Extraction_Advice_Note_vfinal_for_publishing.p
Whilst it is positive that there is a proposed action to look at the air quality implications of the
RHI, with the scheme coming to an end, this is perhaps a measure which is too little too late
and one that would have happened anyway. This should be fast tracked to ensure that as
few as possible new applications are accepted without considering air quality.

Financial support should be given to finding new energy sources for non-road diesel
applications and cost of fuel should better reflect the impact it has. The language used in the
proposed action on seeing how alternative fuel rates ‘line up’ is ambiguous. It needs to be
clear exactly what this means and what subsequent action will be taken following the
findings.

It is positive to commit to cutting emissions from non-road mobile machinery and to giving
local authorities ‘tough’ powers to tackle these sources. However, when it comes at the
same time as the Government removing planning powers from local authorities to further
their shale gas future, a measure which will dwarf the impact coming from such machinery, it
is disingenuous to expect that this measure will have any significant impact in addressing
future air and climate quality considerations.

Green Great Britain Week - announcing public engagement around air quality and climate
across the UK seems like a positive step, but details are required again about how this
information sharing event will take place, the information that will be shared etc. The
Government could be accused of greenwashing with such a scheme - given the airport
expansion, road building, diesel railway and shale gas exploitation policy decisions that have
all come in the past 12 months.

Q8. In what areas of the air quality industry is there potential for UK
leadership?
Science, research and understanding of air pollution and its impacts
Monitoring and modelling of air pollution
Mitigation technology
Low or zero emissions technology
Other
- Renewable energy generation
There is a role to play in all these areas, and given that the UK has thus far set the bar very
low in terms of action to address the issue, leadership might be a way off. But with
development of clean, renewable energy, fewer vehicles on the road and the reversal of
numerous policy decisions that have been made, the UK would demonstrate commitment
and leadership.

Q9. In your view, what are the barriers to the take-up of existing
technologies which can help tackle air pollution?
Upfront costs
Operational costs
Lack of knowledge of the technologies available
Lack of information on the technologies available
Lack of reliable advice on the technologies available
Lack of track record for the technologies available
Familiarity with existing technology
Fit of older technology with other infrastructure and organisational processes
Lack of a strong reason to use a new technology

Other
If other, please specify
Lack of political will to implement or facilitate policies that would derive real air quality
improvements. The Government continues to hide behind a solely technocentric approach to
tackling the problems, failing to acknowledge the role of policy and political change in these
processes (even these questions/this section of the strategy allows no room for other
considerations that technology). And by continually committing to more technology projects
and public awareness, this gap never gets filled. Change of mindset and attitudes in decision
makers and industry are required too.

How can these barriers be overcome?

Not all problems can be solved through technology, some require substantive and
transformative policy change in other areas - planning, transport etc. Pilot projects and
research schemes can only deliver results if they are scaled up, rolled out or supported with
long term policy certainty.

Local authorities have been operating under austerity for almost a decade, budgets have
been cut and monitoring equipment used to measure emissions has perhaps not kept pace
with the developments in available technology, nor is the technology in place kept in optimal
conditions. Funding is required, not so the UK can reinvent the wheel in terms of making
new technologies, but so that local authorities have access to them and can understand
better the issues at hand in communities across the country. And once the data capture has
improved, resources need to be made available so that action plans can be delivered to
bring pollution levels back into safe parameters.

Q10. In your view, are the priorities identified for innovation funding the
right ones (see drop down box below for the priorities)?

Innovation funding priorities

Particulate matter emissions from industrial combustion; tyre, brake and road wear; industrial
processes; and domestic burning
Zero or ultra-low emission heavy goods vehicles
Volatile organic compounds from industrial processes and product formulation
Low and zero-emission options for non-road mobile machinery
Ammonia emissions from agriculture

Yes
No
Partly
Don’t know

Please briefly explain your answer

These are all relevant innovations to invest in, but funding should also be allocated for the
investment in altering or improving industrial practices at scale and more generally, over and
above those mentioned, so as to ensure the specificity of these measures does not result in
unintended consequences which worsen or create problems elsewhere. Other innovations,
for example, rail electrification should be prioritised, especially when evidence comes to light
about the air quality impact of the existing systems.

Moreover, research into ultrafine PM, in terms of impacts, ways to monitor and better
understand it and potential ways to reduce it is also worthy of innovation funding.

5. Action to reduce emissions from transport

Transport is a significant source of emissions of air pollution. The immediate air quality
challenge is to reduce emissions of nitrogen oxides in the areas where concentrations of
these harmful gases currently exceed legal limits. The government has already committed
£3.5bn to tackle poor air quality through cleaner road transport and is working closely with
local authorities and Local Economic Partnerships to make progress. Alongside this, the
government is committed to cutting air pollution from all forms of transport.

We will shortly publish Road to Zero, our strategy for reducing exhaust emissions form road
vehicles. This, together with the UK Plan for Tackling Roadside Nitrogen Dioxide
Concentrations, sets out our approach to addressing exhaust emissions from road transport.
These are not part of this consultation.

Proposed actions
● In 2018 we will set out our ambitious plans to drive down emissions from shipping
and aviation.
● We will end the sale of new conventional petrol and diesel cars and vans by 2040.
We will position the UK as the best place in the world to develop, manufacture and
use zero exhaust emissions vehicles and, during the transition, we will ensure that
the cleanest conventional vehicles are driven on our roads.
● We will work with international partners to research and develop new standards for
tyres and brakes to enable us to address toxic non-exhaust emissions of
microplastics from vehicles which can pollute air and water.
● New legislation will enable the Transport Secretary to compel manufacturers to recall
vehicles and machinery for any failures in their emissions control system, and
environmental nonconformity or failure, and make tampering with an emissions
control system a legal offence.
 ● We will reduce emissions from rail and reduce passenger and worker exposure to air
pollution. By the autumn, the rail industry will produce plans to phase out diesel-only
trains by 2040.
● All major English ports should produce air quality strategies setting out their plans to
reduce emissions. These plans will be reviewed periodically to establish if the
measures are effective or whether government action is required.
● We will review policy on aviation-related air quality to improve air quality.

Q11. What do you think of the package of actions put forward in the this
chapter (see summary above)? Please provide evidence in support of
your answer if possible.
It is confusing that the proposed actions outlined in this consultation response document are
not the same as the measures that get discussed at length in the Clean Air Strategy
document which makes an informed response difficult.

The level of detail regarding the ‘ambitious plans to drive down emissions from shipping and
aviation’ is sparse, therefore it is difficult to respond comprehensively to these elements of
the package. Applying international emission standards would appear to be something that
should already be implemented in the UK for domestic ships - so consulting on these
measures next year before taking steps to implement them seems to be a dilatory approach.
It is made clear in the consultation document that the strategy document that the approach
for addressing exhaust emissions from road transport is not part of this consultation, but in
the proposed measures listed, both the sale of conventionally-fuelled vehicles and the place
of the UK as a leader in zero exhaust emission vehicles appear, which is confusing. As
proposed actions, the timeline set for the elimination of internal combustion engines is too
long. How it can be assured that the cleanest conventional vehicles are driven on the road is
unclear. This is a very compelling statement, but the realities are that people in the UK drive
8 year old cars on average, the second hand market is significant and not all UK drivers
want to buy new vehicles, so without substance to back this notion up, it is very difficult to
see how such a measure can be achieved.

As well as stating that investment in zero emission freight is a priority in the longer term, the
UK Government could start by creating a level playing field between existent freight modes,
removing subsidies from road freight and making it more viable for rail and waterways to
compete in the logistics industry.

Moreover what is lacking in this strategy is more consideration of the role of on non-exhaust
transport pollutants. Brake and tyre emissions are mentioned, but only in the context of
standard setting, no measures are suggested which would bring about a reduction in the
emissions from these sources. Given that the vision of future mobility in the UK set out by
the current Government seems to rely heavily on zero emission vehicles, establishing how
these will be able to brake and have more resilient tyres would be a useful element to
establish in this transport strategy concerned with clean air.
The information in the strategy about promoting alternative modes - walking, cycling and
public transport - does not make it into the proposed actions, suggesting that these areas will
not be prioritised or featured in the final plan. These measures are low cost and have the
potential to achieve significant emission reduction. The funding that has been allocated to
large towns needs to be filtered down to smaller urban areas too.

The measures relating to emissions controls and manufacturers are positive, but details are
required about how non-domestic manufacturers or vehicles will be included, given that the
UK car market is made up of vehicles from across Europe and the rest of the world. How the
legalities of these plans will affect these companies needs to be better explained.

It is positive that the Government will announce plans in the autumn relating to the phasing
out of diesel trains by 2040, but again progress in this area is too slow - electrification was
on the table and plans were subsequently cancelled. Electric trains should already be
running on UK railways and it is a travesty that the Government thinks it would take more
than 2 decades to make the switch.

UK port air quality strategies will also be useful, but it is unclear how the ships and the
companies that run them will also be held accountable to make their vehicles and the fuels
powering them cleaner too - where/whether this fits in as a proposed measure needs to be
clearer.

A lot of the proposed measures in this strategy are vague, perhaps none more so than ‘​we
​ ithout the aviation
will review policy on aviation-related air quality to improve air quality.’ W
strategy available to comment on, the main critique of this strategy is that it fails to take into
account the growth in aviation the Government is actively promoting and by not mentioning
the expansion of Heathrow and the impact that this will have, it is clear that the
Government’s commitment to actually reducing the impact of the sector on air quality is
virtually non-existent.

Q12. Do you feel that the approaches proposed for reducing emissions
from non-road mobile machinery are appropriate or not?
Yes
No
Neither yes/no
Don’t know

Please briefly explain why.

The measures proposed to improve checks, controls and introducing a register of machinery
and an emissions labelling scheme all seem like logical measures which would help bring
the sector under control, however the management of such a scheme, especially at a local
level would be costly. Ensuring that all machines, especially those owned or managed by
SMEs fell under the new measures would be a huge undertaking, so more clarity is needed
about how this will be achieved and subsequently managed. Moreover, it is important to
establish where responsibility for keeping abreast of new technologies and new
developments would lie and how information about these developments would be shared
with NRMM operators and owners. Finally, there are no proposed measures here which
commit to finding alternative sources of energy for NRMM - there are examples which could
be drawn from where cleaner fuels are replacing diesel in such equipment and more
attention needs to be paid to these ideas in this strategy.

6. Action to reduce emissions at home

Many people are unaware that emissions in the home increase personal exposure to
pollutants and contribute significantly to our overall national emissions. Burning solid fuel in
open fires and stoves makes up 38% of the UK’s primary emissions of fine particulate matter
(PM2.5). Harmful sulphur dioxide (SO2) is emitted by coal burned in open fires.
Non-methane volatile organic compounds (NMVOCs) from a wide variety of chemicals that
are found in carpets, upholstery, paint, cleaning, fragrance, and personal care products are
another significant source of pollution.

Proposed actions
● We will legislate to prohibit the sale of the most polluting fuels.
● We will ensure only the cleanest stoves are available for sale by 2022.
● We will update outmoded legislation on ‘dark smoke’ from chimneys and underused
provisions on Smoke Control Areas to bring these into the 21st century with more
flexible, proportionate enforcement powers for local government.
● The government will work with industry, retailers, health experts and consumer
groups to reduce NMVOCs from consumer products, develop options to promote
product innovation and encourage the use of low emissions alternatives.

Q13. What do you think of the package of actions put forward to reduce
the impact of domestic combustion (see summary in drop-down list
above)? Please provide evidence in support of your answer if possible.
More information would be useful on how only the cleanest stoves will be available for sale
by 2022. Likewise, what will the new powers that are given to local authorities be? The
proposed actions in the consultation response document are not the same as those listed in
the strategy document - the action which relates to ensuring that consumers understand
what they can do to reduce their impact from burning is missing. This however is one of the
most important. As well as ensuring that consumers understand how they can reduce their
impact, providing more information about the cleanest fuels available and the costs and
availability of these would also be useful in order to address the concerns about fuel poverty
that were raised in previous consultations. Similarly providing guidance about best use of
fuels and burning equipment would be a wise addition.

It is positive to work with multiple stakeholders to raise awareness of and limit the impact of
NMVOCs and VOCs in the home but again more information on what this ‘work’ will be
would be useful.
Q14. Which of the following measures to provide information on a
product’s non-methane volatile organic compound (NMVOC) content
would you find most helpful for informing your choice of household and
personal care products?

Information on "ABC" labelling

“A B C” labelling would provide a categorised product rating for relevant domestic products,
similar to other labels such as food traffic light labels

Not helpful Quite helpful Very helpful Not sure

x
“A B C” label on
product packaging

l x
Information on
manufacturer
website

x
Leaflet at the point
of sale

x
Inclusion in
advertising
campaigns
Please briefly explain your choices

Is there any other way of providing NMVOC information we should consider? Please briefly
explain what and why.

Perhaps in this area there is a role for regulation to limit the use of polluting chemicals in
household products. The Reach Directive may be useful in this regard.

Q15. What further actions do you think can be taken to reduce human
exposure from indoor air pollution?
Suggested further actions for indoor pollution

Promote better ventilation practices, encourage use of more natural cleaning and household
products and alternatives, continuing support for cleaner heating systems using renewable
energy.
7. Action to reduce emissions from farming
The agriculture sector accounts for 88% of UK emissions of ammonia, which is emitted
during storage and spreading of manures and slurries, and from application of inorganic
fertilisers. Ammonia damages sensitive natural habitats and contributes to smog in urban
areas. Action by farmers can make a big difference to ammonia emissions. The government
is already acting to help farmers by funding the necessary equipment.

Proposed actions
● We will provide a national code of good agricultural practice to control ammonia
emissions.
● We will require and support farmers to make investments in the farm infrastructure
and equipment that will reduce emissions.
● A future environmental land management system will fund targeted action to protect
habitats impacted by ammonia.
● We will continue to work with the agriculture sector to ensure the ammonia inventory
reflects existing farming practice and the latest evidence on emissions.
● We will regulate to reduce ammonia emissions from farming and are seeking views
on 3 possible approaches to regulation.

Q16. What do you think of the package of actions put forward in this
chapter (see the drop-down menu above for a summary)? Please
provide evidence in support of your answer if possible.
These measures all seem like sensible first steps to tackle the issue, but in considering the
experiences from the Netherlands and Denmark to address these problems, it seems that
the approach proposed is not particularly ambitious and could potentially be implemented
much faster than is outlined in the document.

Fundamentally however, there is a lack of acknowledgement that the environmental impact

of the animal agriculture industry is not sustainable long term. The Government’s measures
outlined here treat the multiple impacts of the industry as externalities that can be paid for at
cost, offering support to farmers to enable them to reduce their impact whilst continuing
business as usual. There is no recognition that animal agriculture’s impact on air quality and
GHGs is one of the most significant and that practices must significantly change if we are to
successfully address these problems.
Q17. What are your preferences in relation to the 3 regulatory
approaches outlined and the timeframe for their implementation: (1)
introduction of nitrogen (or fertiliser) limits; (2) extension of permitting to
large dairy farms; (3) rules on specific emissions-reducing practices?
Please provide evidence in support of your views if possible.
All of the measures need to be implemented in parallel and the timeframes should be moved
forward to be introduced in the next 2-3 years.

Q18. Should future anaerobic digestion (AD) supported by government

schemes be required to use best practice low emissions spreading
techniques through certification?
Yes
No
Neither yes/no
Don’t know
Please briefly explain

If not, what other short-term strategies to reduce ammonia emissions from AD should be
implemented? Please provide any evidence you have to support your suggestions.

8. Action to reduce emissions from industry

Industrial processes, including energy generation to power our businesses and homes, and
the manufacture of goods and food, can all create pollution. For many decades, the UK has
been at the forefront of reducing industrial pollution, and significant progress has already
been made. We will continue to build on that progress by increasing standards to reflect
international best practice.

Proposed actions
● We will maintain our longstanding policy of continuous improvement in relation to
industrial emissions, building on existing good practice to deliver a stable and
predictable regulatory environment for business as part of a world-leading clean
green economy.
● We will work with industrial sectors to review improvements to date, and to explore
opportunities to go further through a series of sector roadmaps that set ambitious
standards – moving beyond a focus on minimum standards to make UK industry
world leaders in clean technology and secure further emissions reductions between.
● We will close the regulatory gap between the current Ecodesign and medium
combustion plant regulations to tackle emissions from plants in the 500kW to 1MW
thermal input range. As legislation on medium combustion plants and generators
comes into force, we will consider the case for tighter emissions standards on this
 source of emissions. We will exempt generators used for research and development
purposes from emission controls.

Q19. What do you think of the package of actions put forward in this
chapter (see summary in drop-down list above)? Please provide
evidence in support of your answer if possible.
The regulation of smaller plants is positive, but the details about how this will be
implemented are scant. Understanding which plants will be covered and how the new
legislation will be managed to ensure compliance requires more information.

Q20. We have committed to applying Best Available Techniques to drive

continuous improvement in reducing emissions from industrial sites.
What other actions would be effective in promoting industrial emission
reductions?
Considering renewable energy uptake for more areas of industrial use. Facilitating
cross-working between sectors to find synergies and opportunities for collaboration in
reducing emissions would also have the potential to yield positive results.

Q21. Is there scope to strengthen the current regulatory framework in a

proportionate manner for smaller industrial sites to further reduce
emissions? If so, how?
Smaller industrial sites should be integrated into the coverage of a comprehensive updated
Clean Air Act.

Q22. What further action, if any, should government take to tackle

emissions from medium combustion plants and generators? Please
provide evidence in support of your suggestions where possible.
Providing long term certainty for industry is an important factor to consider, but it isn’t the
most important and must not preclude action from being taken.

Q23. How should we tackle emissions from combustion plants in the

500kW-1MW thermal input range? Please provide evidence you might
have to support your proposals if possible.
It is unclear which industrial combustions are covered in the ‘other’ sections in the graphs in
section 8.2 of the strategy. Emissions (PM2.5 and NMVOCs) from these activities are on the
rise, so it would be useful to have information about where these emissions are being
generated as it may uncover additional measures that would help to tackle emissions.
Q24. Do you agree or disagree with the proposal to exempt generators
used for research and development from emission controls? Please
provide evidence where possible.
Yes
No
Neither yes/no
Don’t know

Please briefly explain your answer

The scope of exempting research and development generators seems very broad and
providing no better definition of what would be covered allows significant potential for
loopholes to exist. Therefore in the current form, exemption is not acceptable unless the
parameters for what would be considered for exemption are much clearer.

9. Leadership at all levels

Emissions from abroad, across the UK and local sources all contribute to the pollution that
people and the environment are exposed to. Effective action is needed at all levels to clean
up our air. This strategy sets out our commitment to cut our national emissions to reduce
population exposure. As part of this we will make it easier to take action at local level.
Alongside this, the UK will continue to play an active, leading role in international action to
improve air quality.

Our international air quality commitments have been agreed at a UK level. However, air
quality is a substantially devolved policy area. Scotland and Northern Ireland have both
already produced their own Air Quality Strategies and Wales is currently in the process of
producing one (further details of these are set out in Chapter 9).

Proposed actions
● We are consulting on a new, independent statutory body to hold government to
account on environmental commitments following EU exit. Ensuring that there is
transparency and accountability in how we achieve our clean air ambitions will be a
priority in this work.
● We will bring forward new clean air legislation at the earliest opportunity. This will
bring long-standing frameworks for local and national action on air pollution into the
21st century with stronger powers and clearer accountability.
● To ensure that local action to reduce air pollution remains robust and relevant, we will
transform existing structures to increase transparency and back this up with stronger
statutory powers to tackle local air pollution.
● The UK government will work in partnership with the governments of Scotland, Wales
and Northern Ireland to develop a detailed National Air Pollution Control Programme
as required under the National Emissions Ceilings Directive for publication in 2019.
Q25. What do you think of the package of actions put forward in this
chapter (see summary in the drop-down menu above)? Please provide
evidence in support of your answer if possible.
It must be ensured that Clean Air legislation is comprehensive, fit for purpose and doesn’t
remove any of the important safeguards currently in place in UK legislation, or that which
currently comes from Europe. Brexit should not be an excuse to stop taking action on air
quality once the external penalties of inaction are removed - the UK Government must be
accountable for cleaning up it’s air.

Ensuring complementarity between national and local levels is important to prevent gaps
and replication as roles and responsibilities change. As well as increasing transparency,
adequate provision for monitoring and reporting. The Government needs to be held
ultimately accountable for the air quality across the country, so steps need to be taken to
ensure that the local authorities have the tools and support they need to tackle the problems
locally.

Q26. What are your views on the England-wide legislative package set
out in section 9.2.2 of the draft strategy? Please explain, with evidence
where possible.

Legislative framework
New clean air legislation will enable the Transport Secretary to compel manufacturers to
recall vehicles and machinery for any failures in their emissions control system, and make
tampering with an emissions control system a legal offence.

It will also replace the existing patchwork with single coherent legislative framework for local
authorities to tackle air quality and bring the law up to date with the evolution of structures at
sub-national level so that accountability for air quality sits in the right place.

It will update outmoded legislation on ‘dark smoke’ from chimneys and underused provisions
on Smoke Control Areas to bring them into the 21st century with more flexible, proportionate
enforcement powers.

Finally, it will create a new statutory framework for Clean Air Zones (CAZ) to simplify current
overlapping frameworks of CAZ, AQMA and Smoke Control Areas to create a single
approach covering all sources of air pollution.

In addition we will legislate to ensure that major sources of air pollution are subject to
proportionate controls that reflect the risk they pose to public health and the environment.
This will strengthen powers at both national and local level.

We will take England-wide action to:

 ● prohibit the sale of polluting fuels and inefficient stoves for domestic use -limit
emissions of ammonia from farming
● consider the case for setting tighter emission controls for biomass installations to
reduce PM pollution from energy generation
● close regulatory gap to apply limits to medium combustion plants between 500kw -
1MW and consider the case for increasing stringency of limits for plants above 1MW
● drive up emissions standards for diesel-powered non-road mobile machinery before
and after sale

More information is required on the proposals to merge the current AQMA, CAZ and Smoke
Control Area frameworks into a single entity. It is imperative that in this process current
measures are not weakened and that no pollutant or source is missed, excluded or
exempted. What is required is a new Clean Air Bill which is fit for purpose given the severity
of and complex factors contributing to the current air quality crisis. In this strategy document,
it has been repeatedly mentioned that the Road Traffic Nitrogen and Road to Zero strategies
are not part of this consultation exercise. Yet there is a huge danger here that in not
considering these initiatives collectively and in keeping those documents out of the scope of
this one, calls for Clean Air Zones which consider all pollution sources, including road
vehicles, will go unheard. Announcing support for Clean Air Zones here, but not explicitly in
the other documents is troubling.

Q27. Are there gaps in the powers available to local government for
tackling local air problems?
Yes
No
Don't know

If yes, what are they?

If road traffic will be incorporated into this new legislation for Clean Air Zones, this is a
positive move. However, as well as giving local authorities new powers to manage these
policy areas, it is fundamentally important that the Government also provides the tools and
knowledge transfer to enable local officers responsible for the management of these new
considerations to monitor, report and effectively carry out the duties. Linking previously
disparate emission sources and management plans is an extensive undertaking and it must
be ensured that it addresses all of the areas more efficiently and effectively and not that all
three areas get less attention through the consolidation.

At a policy level, local authorities are responsible for monitoring air quality, but not
empowered or resourced in tackling exceedances. Additionally local authorities are only
responsible for minor roads, whereas the Highways Agency are responsible for the major
roads/motorways even when they run through local areas, thereby affecting local air quality.
This is a mismatch and a clear accountability and responsibility for every road should be
identified and resourced properly.
Q28. What are the benefits and risks of making changes to the balance
of responsibility for clean local air between lower and upper tier
authorities?
What are the benefits?
As local authorities are all different, it will be easier to understand the major contributors to
pollution in any given jurisdiction. However, it may also be the case in certain areas that
there are many more pollutant sources under given jurisdictions than others and these
context specific needs must be dealt with sensitively, ensuring that plans are adapted
accordingly.

What are the risks?

Lack of oversight of the issue of pollution at the broader scale. Making local authorities
accountable increases the risk of non-compliance in certain areas going unnoticed. The
procedures for monitoring, verification and management of emissions needs to be easy to
understand, implement and report back on in order to maximise the likelihood that local
authorities will address the issue effectively. The national government should still have an
overarching role even if local authorities assume responsibility for this policy area, especially
following the exit from the European Union and the removal of the oversight the Commission
and ECJ provide.

Q29. What improvements should be made to the Local Air Quality

Management [LAQM] system? How can we minimise the bureaucracy
and reporting burdens associated with LAQM?
Suggestions to minimise bureacracy and reporting
In its current guise, the LAQM is not overly bureaucratic nor is the reporting onerous. It
would be useful if reporting was required on more pollutants so that the annual reports could
provide a comprehensive repository of all data in one place. This would provide local
authorities and the Government with a better snapshot of the issues, pollution hotspots and
enable action to be prioritised.

Suggestions for other improvements

The fact that only areas in excess of the limits get managed and reported on is something
which could be improved upon. Even if levels improve, it would still be useful to be
monitoring more areas outside of the LAQMs in any given area, so that it can be ensured
that levels stay within safe parameters. Or an alternative approach would be to do away with
the concept of LAQMs altogether and just establish monitoring equipment of a host of
pollutants across all urban areas. A large undertaking at the outset, but it would stop a
piecemeal approach of installing selected equipment over the longer term and would provide
a much more accurate understanding of the severity of the problems and where action is
required most urgently.
10. Progress against our clean air goals
Analysis shows that the actions set out in this draft strategy can meet our ambitious
emissions reduction targets, if they are implemented with the necessary pace and
determination.

This draft strategy developed by the UK government, on which we are consulting, sets out
how we will work towards meeting these ambitious reductions in England. The consultation
period for this strategy runs until 14 August 2018. We look forward to input from a wide
range of partners on the measures set out here and what more is possible.

Q30. What do you think of the package of actions in the strategy as a

whole?
It is largely lacking on details of the proposed measures laid out across the board, which
makes the exercise of providing considered and useful feedback difficult. When this is likely
to be one of the, if not the only opportunity to comment on significant policy changes, it really
would be a more constructive and useful exercise if pertinent information which could have
significant implications on the actions stated could be provided.

Q31. Do you have any specific suggestions for additional or alternative

actions that you think should be considered to achieve our objectives?
Please outline briefly, providing evidence of potential effectiveness
where possible.
This strategy needs to make more obvious and closer links to the other Government
strategies currently being realised. Moreover, it needs to be better situated in the broader
policy landscape. When airports are being expanded, planning is being nationalised, shale
gas is being exploited and roads are being built, strategies which suggest consumer
awareness campaigns and Green Weeks are hard to take seriously. This strategy needs to
consider how the energy, agriculture and transport sectors can be fundamentally shifted
towards a lower carbon, cleaner and healthier trajectory.

There are so many specific suggestions that would help to achieve the objectives, but the
overall ethos of the Government runs counter to making the air cleaner. So whilst these
measures will help at the peripheries, the large scale policy and investment decisions make
it impossible to realise the environmental improvements across the board that are so
desperately needed.

Finally more consideration of the social implications is needed, they have not been taken
into account at all in this strategy.
Q32. If you have any further comments not covered elsewhere, please
provide them here.
Further comments

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