Our response to DEFRA consultation on Improving Air Quality
On 15th June 2017, we submitted this response to the Government’s plans for tackling nitrogen oxide pollution in our towns and cities. With thanks to Client Earth for their guidance on these issues and this particular consultation.
7 How satisfied are you that the proposed measures set out in this consultation will address the problem of nitrogen dioxide as quickly as possible?
We are very dissatisfied with the draft plan that has been put forward for consultation. If it goes ahead as planned the government will not be able to meet its legal duty of ensuring that legal limits of nitrogen dioxide are met in the shortest time possible.
The draft plan put forward for consultation is a plan for a plan with no new concrete measures proposed. All it does is lead to further consideration by central government, the devolved administrations and local authorities. The government have been breaking the law on air pollution for seven years and we need policies implemented quickly, without more delay.
The draft plan doesn’t make sense, because it doesn’t say what a non-charging Clean Air Zones will actually be, it just says they mustn’t charge cars to enter. It’s hard to see how a clean air zone will effectively reduce air pollution if the most polluting vehicles aren’t discouraged from driving into the most polluted parts of town and the draft plan doesn’t provide any evidence to show how it could work.
The technical report published with the draft plan identifies charging Clean Air Zones as by far the most effective measure to reduce emissions, but the draft plan says they are effectively only to be considered as a last resort despite the evidence showing they are the most effective measure to clean up our air quickly and protect people’s health.
It’s counterproductive to ask people to respond to this consultation, without telling them clearly that the technical report says charging Clean Air Zones are the most effective option and that there isn’t any evidence for non-charging Clean Air Zones. The government must make it clear to people that charging Clean Air Zones will fix the problem quickest.
The draft plan also fails to address national policies that are identified as contributing to the problem. In particular, despite identifying the role of the vehicle tax regime in worsening air quality by encouraging the increase of diesel vehicles, no measure has been proposed and the matter has been left to the Treasury to explore at a later date.
8 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?
Legal limits of nitrogen dioxide should be met in the shortest time as possible. The technical report accompanying this consultation identifies charging Clean Air Zones, as the most effective way to reduce levels of nitrogen dioxide in the shortest time possible. In addition, the 2015 air quality plans identified mandated charging Clean Air Zones as more effective than voluntary Clean Air Zones.
This suggests that local authorities should not be left to determine the arrangements for a Clean Air Zone. Therefore, where legal limits of air pollution are being broken and road transport is identified as a significant source, the UK government and devolved administrations should mandate charging Clean Air Zones. To support this, they should provide a clear and comprehensive national framework to ensure consistency in the approach throughout the UK.
The UK government and devolved administrations should then work with the relevant local authorities to determine the appropriate local arrangements. The UK government or devolved administrations, however, should mandate the category of charging Clean Air Zones, based on the evidence, to include all the type of vehicles that make a significant contribution to the problem.
Charging Clean Air Zones should be complemented by supporting measures to help individuals and businesses make cleaner transport choices. A range of policies such as a targeted scrappage scheme and changes to Vehicle Excise Duty need to be introduced.
9 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?
The best way for the government to target funding to cut air pollution would be by having a comprehensive and strategic national plan based on a robust analysis of the problem. This should first address national policies that contribute to air pollution, such as the vehicle tax regime, or that could help reduce it across the UK and not just in some hotspots. It should then look to optimise opportunities at a regional and local level. The UK government should fund an effective national network of charging Clean Air Zones based on a robust national framework to ensure a consistent approach across the country. These should be complemented by measures to help individuals and businesses move to cleaner forms of transport, such as:
• Greater investment in public transport, walking and cycling infrastructure.
• A targeted diesel scrappage scheme particularly to lower income drivers and small businesses. This scheme should offer a vehicle exchange in return for help with the cost of a less ultra-low or zero-emission vehicle, subsidised car club membership, free public transport season tickets or e- bike purchase loan.
• Changes to the vehicle tax regime to stop incentivising diesel vehicles and instead encourage a shift to cleaner forms of transport. For example, an additional charge could be applied to new diesel cars on their Vehicle Excise Duty first year rate to address the greater impact of diesel cars compared to their petrol equivalents.
• Retrofitting initiatives for private, passenger and commercial vehicles
10 How best can governments work with local communities to monitor local interventions and evaluate their impact?
The best approach would be for government to proactively engage with the relevant authorities and the general public to ensure local interventions are being delivered and are having an impact. This should be part of a comprehensive national public engagement strategy that proactively raises awareness of the problem and the actions being carried out to tackle it.
Current information sharing via government and local authority websites are not user-friendly for the general public, lack information and are often out of date. The government should facilitate a national system that ensures transparency and allows local communities to directly access relevant and up to date information at a national and local level.
The UK government should also ensure that the general public are proactively alerted about high pollution events when they are forecasted and as they happen. This will help people protect their health and consider how they can reduce their contribution to the problem. The current system is based on thresholds that are too high and don’t cover all pollutants. It is also a passive system that relies on individuals looking for the information online. An air pollution alert system could use the similar systems in place for heat waves and cold weather warnings.
11 Which vehicles should be prioritised for government-funded retrofit schemes?
The government should prioritise retrofit schemes according to the available technology that will have the greatest impact towards meeting legal limits of air pollution in the shortest time possible.
12 What type of environmental and other information should be made available to help consumers choose which cars to buy?
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.
13 How could the Government further support innovative technological solutions and localised measures to improve air quality?
The UK government could help support innovative technological solutions and localised measures by providing a comprehensive, long-term, strategic and funded plan to improve air quality beyond the current legal limits. Nationally coordinated measures, such as a national network of charging Clean Air Zones and changes to the vehicle tax regime, will help send a clear signal to businesses, local authorities and the general public of what investments they should be making. The government should accelerate implementation of an industrial strategy that will make the UK a world leader in clean technology, creating the jobs and industries that will help us, and others, clean up our air.
14 Do you have any other comments on the draft UK Air Quality Plan for tackling nitrogen dioxide?
The draft UK Air Quality Plan is weak and illogical. Firstly the government’s plans and consultation do not match what its own evidence says needs to happen. If the evidence shows that taking certain measures will be necessary to tackle the public health crisis of polluted air, then the plan needs to make that clear. Secondly, this is a plan to make more plans later when we need action now. I want to see a national network of clean air zones to protect people’s health alongside measures to help people switch to cleaner forms of transport such as a scrappage scheme and changes to vehicle taxation.