Royal Commission on Environmental Pollution

The Royal Commission on Environmental Pollution welcomes the government's intention to achieve specified improvements in air quality by 2005. The Commission's 1994 report on Transport and the Environment recommended that policies to cut air pollution should be based on targets for 2005.

The Royal Commission is concerned however that the government's proposals may not be capable of achieving the objectives set for improvements, and will not prevent air quality deteriorating again after 2005. It also believes the objectives themselves need to be reassessed and extended when the strategy is reviewed in three years time.

Most of the measures required to improve air quality affect transport. In relying on European legislation and air quality management plans to be drawn up by local authorities, the government has said little about measures that need to be taken at national level. The Royal Commission is now reviewing its report on Transport and the Environment, and will pay special attention to policies for protecting human health and the natural environment from vehicle emissions.

The text of the Royal Commission's comments on the draft National Air Quality Strategy, submitted to the Department of the Environment, is below.

Comments by the Royal Commission on Environmental Pollution

The Royal Commission on Environmental Pollution welcomes the publication in draft of the UK National Air Quality Strategy as an initiative aimed at achieving health-based 'specific objectives' for air quality by 2005 and as an important part of the government's response to the Commission's 1994 report on Transport and the Environment, which recommended such a target-based approach to improving air quality.

Selection of objectives

The Royal Commission notes that the specific objectives proposed in the draft Strategy are based on a combination of World Health Organization (WHO) air quality guidelines and recommendations from the Department of the Environment's Expert Panel on Air Quality Standards (EPAQS), and that under the Framework Directive on Ambient Air Quality Assessment and Management the European Community is now in the process of setting limit values (which will be based on revised WHO guidelines) for all but one of the relevant pollutants.

The Royal Commission is at present carrying out a wider study of the basis for environmental standards. The conclusions from this may have relevance for the approach adopted to air quality in future but will not be available until the second half of next year.

In the light of these considerations, the Royal Commission regards the intention to review the Strategy after three years as significant. It attaches particular importance to the commitments the government has given that the first review will:

examine the possibilities of extending the Strategy to other pollutants, notably polycyclic aromatic hydrocarbons (PAHs); investigate how ecosystem protection might be incorporated into the Strategy.

One pollutant for which a specific objective is proposed is particles of less then 10µm diameter (PM¹⁰), which are of growing concern on health grounds. Scientific evidence is increasingly indicating that it is the smallest-sized fractions of particulate matter that are the most damaging to health. The Royal Commission believes the government should keep the situation under review and consider the possibility of adopting a separate or replacement standard and objective for PM^2.5 (particles with a diameter less than 2.5 µm). This should be a priority topic for the first review in 1999.

Adequacy of measures proposed to achieve objectives

The Royal Commission's major concern is that the measures specified in the draft strategy may not be capable of achieving the air quality objectives set. The draft Strategy itself identifies 'policy gaps' between the reductions in concentrations expected to result from the present package of measures and the reductions necessary to achieve certain of its specific objectives. It estimates the gaps are about 5-10% for nitrogen oxides and PM¹⁰. It acknowledges however that these may be underestimates because of uncertainties in the modelling methods used. There are also uncertainties about the effectiveness of some measures in the present package, for example about how long catalytic converters on cars will continue to perform at full efficiency.

Emissions from road vehicles

Transport is the main source of many of the pollutants covered by the Strategy, notably benzene, 1,3-butadiene, carbon monoxide, lead and nitrogen oxides. It is also a major source of volatile organic compounds (reactive precursors of ozone) and a significant source of particulates especially in urban areas. Most of the measures required to implement the Strategy therefore will affect transport.

The Royal Commission agrees that the measures taken must be a flexible and cost-effective combination of

legislation at European level to place more stringent limits on emissions from new vehicles and modify fuel specifications action at national level measures taken locally in particularly sensitive areas (Air Quality Management Areas), which may extend to reducing the amount of road traffic in that area or changing its nature.

There is little in the draft Strategy about measures that should be taken by national government, or how these should be integrated with other measures to achieve the maximum impact. The Royal Commission's Fifteenth and Eighteenth Reports recommended a number of national measures that would make a considerable contribution to achieving the objectives of the Strategy. It is a ground for concern that the only government Departments to put their names to the draft Strategy are the Environment Departments. There is no clear evidence of the degree of commitment by other government Departments that will be essential if appropriate national policies are to be developed and implemented.

At local level, local authorities are not well prepared for the new air quality management duties that will be placed on them in April 1997. They do not generally have in place either budgetary provision or appropriately qualified and trained staff. Local authorities need to be given the new regulatory powers they are likely to require, or at least a clear indication when these will be forthcoming, and they need guidance from central government on a wide range of issues.

A more fundamental point is that drawing up and putting into effect Air Quality Management Plans will require a great deal of close co-operation between neighbouring local authorities, between authorities at different tiers, and between local authorities and the relevant Environment Agency. Central government needs to ensure that the necessary basis and framework exists for these types of co-operation.

Looking further ahead

Even if the present package of measures achieves the proposed objectives for air quality in 2005, it is generally acknowledged that road traffic growth beyond that date will cause air quality to deteriorate again unless further measures are taken. Greater emphasis is needed on assessing the potential of the next round of European legislation controlling emissions from new vehicles which is due to come into effect in 2005, and on what is likely to happen after that legislation has had its full effect in reducing emissions from individual vehicles. The solution must lie in the development and implementation of an overall transport policy which will be environmentally sustainable in the longer term.

Whilst welcoming the general approach adopted in the draft National Air Quality Strategy, the Royal Commission believes that it does not go far enough towards creating the policies or policy climate that will be essential for the achievement of its objectives. In carrying out the recently announced review of its Eighteenth Report on Transport and the Environment, the Royal Commission will be giving further attention to the form and content of a sustainable transport policy that will minimise environmental damage of all kinds, and in particular ensure that air quality is protected from the adverse effects of vehicle emissions.

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