By Anna Livesey
My last blog on this topic was in the midst of the pre-election interruption to policy announcements. The publication of the draft air quality plan was exempt from such interruption thanks to a high court ruling. But it was not exempt from criticism regarding its lack of robust measures to tackle the issue of poor air quality in the UK. The pressure was on for improvements in the new version.
Like the draft, the new 2017 version of the plan has been met with complaints; media reports included that it still ‘lack’s urgency’ and passes too much of the responsibility onto local authorities. Whilst much of this criticism does not go unfounded, it is worth focussing in on a few areas to understand what might be important in terms of next steps:
- Wider clean air strategy: This air quality plan was designed to tackle nitrogen dioxide (NO2) emissions; as such it has focussed in on transport, as one of the largest emitters of NO2, and measures to tackle this. However, other sources of air pollution are also in the process of being examined to meet emissions limit targets including; particulate matter, sulphur dioxide, non-methane volatile organic compounds and ammonia, as well as nitrogen oxides. As referenced in the consultation the government has committed to publish a wider Clean Air Strategy in 2018. It is recognised that the sources of these five pollutants are varied; ranging from transport, to farms, to heating systems in buildings and a range of emissions reductions measures are therefore needed. The development of measures will be relevant to anyone who has a solution to help reduce these pollutants or who has a source of them.
- Role for local authorities: The air quality plan provides recommendations about measures to be implemented to tackle sources of NO2. How these are delivered, is a matter for local authorities. In the 2015 air quality plan, five cities (outside London) where required to have Clean Air Zones (Birmingham, Derby, Leeds, Nottingham, Southampton) and implement measures for these zones. In the new 2017 air quality plan, 29 local authorities (including the previous five) have all been required to develop local plans detailing how they will tackle air pollution. In addition, other areas are also expected to take steps to reduce emissions, if there are measures they could bring forward. As such, there will be merit in supporting local authorities in the process of identifying and implementing measures in such a way that ensures they are effective.
- More consultation: Another consultation will take place this autumn on appropriate actions to tackle air pollution; to aid development and assessment of options. Measures to be considered will include options to support motorists, such as private car drivers on lower incomes. Options might include retrofitting, subsidised car club membership, exemptions and discounts from any restrictions. The much debated targeted scrappage scheme is also to be considered further in this consultation, focussing on certain groups of drivers who most need support (such as those on lower incomes or those living in the immediate vicinity of a Clean Air Zone). A further strategy on the pathway to zero emissions transport for all road vehicles will be published in March 2018.
- Industrial strategy: The new air quality plan outlines how innovative solutions and new technologies should be considered to support the industrial strategy. Providers of such innovative solutions would be advised to engage with the autumn consultation, with local authorities tasked with delivering local air quality plans and with the wider clean air strategy.
- Other policy measures: As noted above, transport is only one source of air pollution. Policy measures are already underway to tackle other sources. For example, the Medium Combustion Plant (MCP) Directive sets emissions limits values for combustion plants in the 1-50MWth range. The controls will apply to new plant from December 2018 and existing plant must comply by 2024 or 2029 (dependent on size). As a result of stakeholder feedback the regulations were also extended to cover generators with a rated thermal input <1MW if they provide balancing services to the grid. As these measures come into place users of MCP will need to take appropriate steps to meet the limits. In addition, feedback captured in the MCPD consultation outcome said that “Some felt that the emission limit proposed was too generous considering there are alternative non combustion technologies available to provide the same services.” Hence, this could be considered an area where regulation might eventually be able to go further, particularly as more evidence is gathered on the causes, impacts and solutions to air pollution.
- Clean Growth Plan: The new air quality plan also states that further measures will be set out in the Clean Growth Plan which the Department for Business, Energy and Industrial Strategy will bring forward in the autumn.
Despite a general view that the air quality plan has still failed to fully tackle the issue, what it has done is provided a benchmark of opinion and thrown the limelight onto an issue that has incredibly detrimental impacts on health and the environment.
If the consensus is that this plan isn’t good enough, then utilising engagement opportunities to provide further feedback on what a robust approach should look like will be crucial. Taking into consideration the criteria for the local plans which include reaching legal limits in the shortest time possible, no unintended consequences and must demonstrate value for money. Beyond this we need a wider approach which tackles not only transport but all sources of air pollution across all sectors. Those with technologies that are able to tackle this issue will be important stakeholders in making the case for improvements.
Contact the author: Anna Livesey