DEFRA Clean Air Strategy consultation – Manchester Friends of the Earth’s response

13th August 2018

The Department for Environment, Food and Rural Affairs (DEFRA) recently consulted on the Government’s draft Clean Air Strategy. Manchester Friends of the Earth detailed response is available (pdf).  See below for the introduction to our response and why we need both national and local government to take urgent action to clean up our toxic and illegal air.

It is vital that Greater Manchester and other cities take action on air quality, and are supported and encouraged by national Government. We consider air quality a public health emergency. June 2018, IPPR North published research from King’s College London that estimated “that 1.6 million life years will be lost in Greater Manchester in the coming century due to its poisonous air. This is equivalent to each of us having our life expectancy reduced by six months.

Using the 2011 baseline, NO2 pollution alone was estimated to have caused up to 1,781 premature deaths in Greater Manchester and particulate matter pollution up to 1,906 premature deaths” and air pollution has a “£1 billion annual cost to the Greater Manchester economy.” Central Manchester has the highest rate of hospital admissions for asthma in the country, finds the report, followed by North Manchester.

To be successful, air quality policy must target transport. According to Transport for Greater Manchester, road transport contributes 75% of emissions of nitrogen oxides and 81% of particulate emissions in the Greater Manchester conurbation. Road transport also accounts for 32% of carbon dioxide emissions.

Within our cities there is strong potential for modal shift away from private car use towards not only electric cars but also modes that result in significantly less pollution, including walking, cycling and public transport. Half of all trips made in Greater Manchester are less than 2km (1.25 miles) and 30% of these trips are by cars. 88% of trips within Greater Manchester are of 5 miles or less, and more than half of these are made by car.

We note that the Clean Air Strategy covers a wider range of air pollution issues than simply the road transport sector. However, given the impact of the road transport sector on air pollution in UK cities our consultation response has focussed on the transport sector. Whilst our work is primarily in Greater Manchester and the North West, we would like to see strong action on air quality across the UK. When we draw on examples in Greater Manchester this is because we believe they are relevant to other UK cities.

Our response is arranged in 8 sections, namely:

1. Greater Manchester’s illegal air pollution – a public health emergency
2. Clean Air Zones
3. Target dates for removing diesel and petrol vehicles.
4. Air pollution monitoring
5. Diesel scrappage scheme
6. Building more roads is not a sustainable solution.
7. We need integrated policies at local and national level.
8. Rail electrification

Manchester Friends of the Earth’s vision for Greater Manchester’s transport system is one in which there has been substantial modal shift away from the private car and towards public transport, walking and cycling. All vehicles have zero tailpipe emissions. Transport provision is affordable and well integrated with easy-to-use journey planning tools and everyone has the services they need within easy access in their district centre so that there is less need to travel.

In this vision, these changes have greatly increased the level of active travel and improved air quality across Greater Manchester. This has seen improvements in the health and wellbeing of the people living and working in the region helping to reduce pressure on the health service. Better spatial planning, focused on improving access and opportunities in district centres across the region, has reduced the need to travel and has resulted in a low carbon footprint for the conurbation’s transport system and a thriving economy.

In our response we make the following key points:

* Air pollution has major health impacts and costs and in Greater Manchester and other cities and has been described as a public health emergency. The government’s response does not match the urgent need to reduce air pollution.\

* Air pollution is an issue on which the Government has received and will continue to receive legal challenges.

* The Clean Air Strategy appears to pass the responsibility for tackling this emergency to local authorities without clarity or commitment on where the resources to meet this responsibility will come from.

* We question why the government has failed to provide funding to enable all conurbations with illegal air pollution to implement the measures that reduce people’s exposure “as quickly as possible” and “ensure that compliance is not just possible, but likely.”

* Requiring local authorities to bid for cash-limited funds will result in a “postcode lottery” – where people living in local authority areas which are unsuccessful with funding bids will have to continue suffering the ill effects of air pollution.

* Electric trains are better for the climate, better for our health and better for passengers. Cleaner, greener, faster travel offered by electric trains should be accessible to people across the country, not just those in London and southeast England.

* In order to be an effective Clean Air Strategy, this strategy needs to mandate and fund charging Clean Air Zones in cities with illegal air.

* In cities, walking and cycling offer pollution free and low carbon ways of getting around, particularly for journeys under 5 miles.

* Building new roads, or widening existing roads may be attractive as a way of demonstrating action, is neither a sustainable nor an effective solution to air pollution. Building new roads increases traffic levels and will increase air pollution

* Effective monitoring is vital for action to reduce air pollution. Local authorities should be mandated to do this and supported financially. Monitoring information should be available to policy makers, planners and the public alike.

Manchester Friends of the Earth
13th August 2018

Full response available as PDF.