Nice intentions, let’s see the detail. A take on the Government’s Clean Air Strategy

Government published its clean air strategy today (109 pages) You can read an executive summary here and the full version here

Although there has been some cynicism, and it raises more questions than answers, this fundamentally mixed plan has some potentially really good things we should welcome.

Intention and Provenance

The clean air strategy sets out how the government will work to implement its 25-year environment plan, alongside its clean growth proposals.

The cross government plan is published by the Department for Business, Energy and Industrial Strategy, the Department for Environment, Food and Rural Affairs, the Department for Transport, the Department of Health and Social Care, the Treasury, and the Ministry of Housing, Communities and Local Government.

Among the documents highlighted is the shared briefing The Association of Directors of Public Health produced with Defra and LGA and PHE in 2017 highlighting the local leadership already being provided by DsPH and what more there is to be done

Who should be interested?

Local Authority Chief Executives and growth partnerships, but also Directors of Public Health, because repeated mention is made of what DsPH could do with the right powers. Directors of Place/Environment seem to be omitted, which is unfortunate.  A major concern is whether the Buck is being passed to Councils, as has been suggested by various commentators today.

Key Issues for Directors of Public Health

I have used the analysis by Ben Wealthy, Policy Manager at  the Association of Directors of Public Health, here.

  • The main mention of DsPH is a commitment to work with local authorities and DsPH (strange way of phrasing this which gives the impression DsPH are not working within local government already) to equip and enable them to lead and inform local decision-making to improve air quality more effectively. This fits with the whole system leadership role and makes sense. But little detail
  • It slightly addresses ADPH concerns that Defra don’t really understand what responsibilities sit at what tiers of local authorities but there remains a lack of detail about who they think should do what.
  • It talks about a raft of new powers for local authorities and sets out a number of options which could be included in the Environment Bill, although it is unclear who these duties would fall on within councils – DsPH or others.
    • Given many relate to transport, the economy and planning it seems Directors of Place would have to take more of a role but they aren’t actually mentioned. Which feels like a major omission
    • Proposals like requiring local authorities to create an action plan to reduce population exposure during Air Pollution Episodes to protect public health could potentially be aimed at DsPH.
  • There is a lack of bold action from the government, particularly on transport, and no word on funding

Ben points out, rightly I think, that this is generally welcome but must be matched by clearer national policy action and more funding, including for public health . The Clean Air Strategy focusses on the importance of facilitating the sharing of best practice and knowledge between local authorities and there are already some good ways of working between place shaping and public health directorates.

ADPH will be doing more work on this with colleagues in the sector. But the crucial thing, as Ben points out, is we need clarity and detail.

Biggest Challenge

My biggest sense from reading this document is that the plan is vague on powers and funding, and doesn’t quite get the balance right of how to enable local action without those. While the chapter on leadership at all levels is well intentioned, it needs more sophistication and sometimes feels like a wish list rather than a coherent strategy

The document feels heavy on rhetoric, low on detail. That may be fine for a high level strategy but let’s bearing in mind that government in the years 2000-2003 committed £326million on vehicle crime reduction, in 2019-2021 this plan specifies only around £34m in actual commitments. But does say £3.5bn is already committed to tackle air quality through cleaner road transport.

Headline Commitments

  • a new pledge to bring the UK’s air quality into line with WHO guidelines
  • new policies to tackle emissions from biomass and agriculture, and proposes restrictions on domestic burning on stoves and open fires
  • action to reduce emissions across the government estate.(In addition to a pledge to make all of the central government car fleet ultra-low emission by 2030, the plan proposes to extend existing requirements that departments report on their plans to reduce carbon emissions to cover air pollutants such as nitrogen dioxide.)
  • recommitts the Government to ending the sale of conventional new diesel and petrol cars and vans from 2040.
  • New powers
  • A range of actions for a range of actors
  • No real money

A synopsis: Chapter 1: Understanding the problem

Sets the scene and targets. Glosses over recent court cases however. But aims to cut impact on human health from air pollution by half, by 2030. Discusses the need for a greater evidence base and identifies investment of £10m in modelling, data and analysis of air quality. National and local monitoring data will be brought together into a single portal. (Doesn’t mention that air quality monitoring remains patchy and reduced by local government cuts.)

Chapter 2: Protecting the nation’s health

Recognises Air quality as the largest environmental health risk in the UK.

Commits to

  • progressively cut public exposure to particulate matter pollution as suggested by the World Health Organization.
  • set a new long-term target to reduce people’s exposure to PM2.5 by 50%
  • publish evidence in 2019 to examine action needed to meet the WHO annual mean guideline limit of 10 μg/m3.
  • provide air quality messaging system to inform the public about the air quality forecast,
  • provide powers designed to enable targeted local action in areas with an air pollution problem (no real mention of funding)
  • work with media outlets to improve public access to the air quality forecast
  • work to improve air quality by helping individuals and organisations understand how they could reduce their contribution to air pollution (the rather over-worked personal responsibility doctrine again despite the fact existing evidence shows regulatory action will achieve far more.)
  • equip health professionals to play a stronger role by working with the Medical Royal Colleges and the General Medical Council to embed air quality into the health professions’ education and training. (This is vague)
  •  work with local authorities and directors of public health to equip and enable them to lead and inform local decision-making to improve air quality more effectively. (Again, exceptionally vague. Without powers and money and the ability to bring the Highways Agency and others to the table on enforcement there is little they can do.)

Chapter 3: Protecting the environment

  • develop a new target for the reduction of deposition of reactive forms of nitrogen
  • review what longer term targets should be to further tackle the environmental impacts of air pollution
  • monitor the impacts of air pollution on natural habitats
  • provide guidance for local authorities explaining how cumulative impacts of nitrogen deposition on natural habitats should be mitigated and assessed through the planning system (the massive question of money left undiscussed)

Chapter 4: Securing clean growth and innovation

A chapter with the most hyperbole from which we glean:

  • Ambition to give an advantage too UK industry through leading development, manufacture and use of technologies, systems and services that tackle air pollution.
  • seek ways to support further investment in Clean Air innovation. (not much detail. Existing examples of joint research and small business funding amounting to £19.6 million and £5 million respectively.)
  • Future electricity, heat and industrial policies will together improve air quality and tackle climate change. (No detail but commits to Phasing out coal-fired power stations, improving energy efficiency, and shifting to cleaner power sources.).
  • Tackle non compliance with the air quality objectives (when they are clear what they are) of the Renewable Heat Incentive Scheme and tackle
  • consult on making coal to biomass conversions ineligible for future allocation rounds of the contracts for difference scheme.

Chapter 5: Action to reduce emissions from transport

  • Multiple reminded of already published policy (Road to Zero setting out aims by 2040 to end sale of new conventional diesel and petrol cars and vans; Aviation strategy published and Maritime Strategy due in 2019.)
  • New powers for Transport Secretary to compel manufacturers to recall vehicles and non-road mobile machinery for any failures in their emissions control system, and to take action against tampering with vehicle emissions control systems.
  • research and develop new standards for tyres and brakes to address toxic non-exhaust particulate emissions from vehicles which include micro plastics
  • reduce emissions from rail and reduce passenger and worker exposure to air pollution.
  • By spring 2019, the rail industry will produce recommendations and a route map to phase out diesel-only trains by 2040.
  • By spring 2019, government will publish guidelines to advise ports (within the scope to be confirmed) on Air Quality Strategies.
  • review current uses of red diesel so its lower cost is not discouraging the transition to cleaner alternatives.
  • explore permitting approaches to reduce emissions from non-road mobile machinery, particularly in urban areas.

Chapter 6: Action to reduce emissions at home

  • legislation to prohibit the sale of the most polluting fuels
  • ensuring that only the cleanest stoves are available for sale by 2022
  • make changes to existing smoke control legislation to make it easier to enforce
  • give new powers to local authorities to take action in areas of high pollution
  • work across government to look at opportunities to align our work on air quality, clean growth and fuel poverty in future policy design
  • develop a communication campaign targeted at domestic burners, to improve awareness of the environmental and public health impacts of burning
  • work with industry to identify an appropriate test standard for new solid fuels entering the market
  • work with consumer groups, health organisations and industry to improve awareness of NMVOC build-up in the home, and the importance of effective ventilation to reduce exposure including voluntary labelling systems
  • Consult on changing Building Regulations for ventilation to reduce indoor air pollutants

Chapter 7: Action to reduce emissions from farming

The agriculture sector accounts for 88%2 of UK emissions of ammonia, which is emitted during storage and spreading of manures and slurries and from the application of inorganic fertilisers.

Commits to:

  • requiring and supporting 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.
  • working with the agriculture sector to ensure the ammonia inventory reflects existing farming practice and the latest evidence on emissions
  • regulating ammonia emissions from farming by requiring adoption of low emissions farming techniques
  • extend environmental permitting to the dairy and intensive beef sectors
  • regulate to minimise pollution from fertiliser use, seeking advice from an expert group on the optimal policy approach

Chapter 8: Action to reduce emissions from industry

Commits to

  • considering closing 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.
  • we will consider the case for tighter emissions standards on emissions from medium combustion plants and generators

Chapter 9: Leadership at all levels

A crucial chapter and the one which needs most elucidation. Lots of talk of Public Health role.

Commits to

  • making it easier to taking action at local level but needs work
  • establishing an Office for Environmental Protection,
  • bring forward provisions on air quality to include an up to date legislative framework for tackling air pollution at national and local level,
  • An Environment Bill containing these
  • “ensuring responsibility sits at the right tier of local government and back this up with new powers as well as making existing powers easier to use. Neighbouring local authorities and other public bodies will work collectively to tackle air pollution.” (Great in principle, needs more detail.)

Chapter 10: Progress towards our goals

Not a great deal of detail here. A work in progress


All in all, broadly welcome, but a real mixed bag which much detail as yet unclear and no funding. But if all this is pulled off,it will be important.

  • It’s encouraging to see Government recognising the importance of PM2.5 and aspiring to meet the WHO guidelines.  It’s not clear how it plans to achieve these.
  • It is worth noting specifically ammonia – in some ways this is the most significant document on controlling ammonia emissions that UK government has ever produced. Ammonia largely goes underrated while we focus on other pollutants. A real reduction in ammonia and volatile organic compounds will bring multiple benefits.
  • The wide range of simultaneous actions being proposed, is a reflection that further improving air quality in the U.K. is getting ever more challenging. NOx and PM emissions are already on a (gradual) downward trajectory from road transport, but it remains a critical source of pollution.
  • Having said that, domestic and agricultural releases of air pollution have been increasing in recent years.  Solvents at home, fertilisers, and wood burners, make up a substantial fraction of national emissions

The proof will be in the implementation.

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