Improving air quality, now and in the future

The Chartered Institute of Environmental Health (CIEH) serves as the professional voice of environmental health, protecting the public, supporting professionals and influencing policy for over 130 years. CIEH’s 7,600 members work locally, nationally and internationally across all areas of environmental health, including food, public health, housing, environmental protection, and health and safety.

As the trusted voice of our profession, CIEH harnesses member insight to ensure government policy creates environments that are cleaner, safer and healthier. Air pollution is at the forefront of this work, as the largest environmental risk to public health, contributing to around 40,000 additional deaths and costing the economy £22.6 billion each year.

Photograph: iStock/oversnap

As a result, CIEH has consistently campaigned for an ambitious and holistic approach to reducing air pollution that encompasses all sources of emissions from industrial, agricultural, transport and domestic.

The World Health Organization provides global air quality guidelines it feels to be appropriate to safeguard public health. Currently, UK legal limits for pollutants are set significantly above these guidelines.

UK should adopt more ambitious air quality targets

As air pollution is a transboundary issue, the UK’s legal framework for air quality is a combination of international commitments, retained EU law and domestic legislation. At a national level, the UK Government and the devolved executives are required to produce a national air quality strategy, and subsequent targets.

England’s current air pollution targets, to reach a maximum concentration of PM2.5 of 10µg/m3 by 2040 and a 35 per cent reduction in population exposure by 2040, are not considered by CIEH to take on board up-to-date evidence and modelling showing most of the country will achieve a more stringent standard by 2023.

As a member of the Healthy Air Coalition, CIEH has argued for the UK Government and devolved nations to adopt more ambitious air quality targets that meet WHO air quality guidelines and implement a holistic regulatory framework that supports local authorities with the capacity to enforce air quality targets.

While welcoming the passage of Wales’ Environment (Air Quality and Soundscapes) Act, CIEH is concerned with the current erosion of air quality legislation in many parts of the UK – from the decision to revoke regulations instrumental in setting legally binding emissions commitments, the limited consultation window for the Department for Environment, Food & Rural Affairs’ Air Quality Strategy and the currently slow progression of the Clean Air (Human Rights) Bill.

Matthew Clark is a member of the Chartered Institute of Environmental Health (CIEH) Environmental Protection Advisory Panel. Photograph: CIEH

While air quality is a national issue, it is local authorities that provide the frontline implementation and review of air quality targets and legislation locally. Environmental health practitioners within local authorities have various powers and responsibilities to control air quality in their areas, including regulating the environmental permitting regime which regulates industrial emissions, implementing local land use planning, environmental health, Smoke Control Areas (SCAs), roads, highways, environmental permitting and local air quality management.

Role of local authorities in reducing air pollution

As seen in the new Air Quality Strategy, local authorities are under increasing pressure to secure and maintain air quality standards, while lacking the strategic regulatory framework and necessary resourcing to do so.

In particular, local authorities can help reduce air pollution from transportation by promoting the infrastructure required to support lower emission transport modes to be seen as the best option for the majority – but crucially need the resources to do this.

Local authorities’ public health funding has suffered a 26 per cent cut since 2015/16, creating an increasing dependency on competitive grant schemes to enable local authorities to tackle air quality. However, this lifeline has recently been scrapped, with the decision to withdraw the Air Quality Grant Scheme. This has left local authorities with very limited means to promote the interventions required to reduce emissions and raise awareness of the agenda more widely – something commonly recognised as a barrier to creating change in this area.

Monitoring data is crucial

Comprehensive and accessible monitoring data is crucial for local authorities to adequately understand local exposure to air pollution, and identify hotspots to target and understand broader pollution levels across their area. However, there is a disjointed monitoring system that is inconsistent locally and nationally, and data across the country differs in quality and quantity. This ensures local authorities can’t fully facilitate an evidence-based approach to reducing air pollution.

CIEH welcomes additions to the national monitoring network but advocates for further thought on how to give everyone access to data that means something to them locally, which would necessitate further expansion.

There are also flaws within national ambition and the existing regulatory framework which hamper effective local authority enforcement, such as SCAs. CIEH has called for greater focus on regulating the sale and use of domestic solid fuel burners in urban areas where there are on-grid heating alternatives, which remain the biggest source of small particle air pollution in the UK.

We would encourage any future government to clearly identify where the cleaner air agenda overlaps with other critical policy priorities and enhance opportunities to ensure the greatest benefits across the board can be realised through integrated action.

The CIEH has fed into discussion at APP CO and PH group meetings the need to raise awareness and provide integrated solutions, which use current evidence to ensure that positive action for one cause pulls forward linked agendas. For example, ensuring a focus on providing good ventilation when carrying out work to retrofit homes to promote better energy efficiency creates a direct benefit to internal air quality and, at the same time, can reduce damp and mould growth concerns.

Insufficient clarity

Enforcement action against agricultural emissions falls outside the remit of local authorities and, crucially, many of the transitions to low carbon alternatives can create unintended consequences for air pollution. CIEH has also previously outlined in its response to consultation on proposed reforms to the national planning policy framework to DLUHC that air pollution and wider public health aren’t adequately considered in wider planning policies, creating insufficient clarity for local authorities with respect to how these plans should be implemented.

Practical actions for the UK Government:

1. The UK Government must urgently introduce ambitious air quality targets by committing to reducing the concentration of PM2.5 of 10µg/m3 by 2030 and look to review and reduce the NO2 annual average limit building on the work that has gone into the Clean Air (Human Rights) Bill.
2. Create a clear mechanism in legislation for reviewing and updating air quality targets, alongside an expanded and consistent monitoring and regulatory infrastructure to clearly outline local authorities’ legal duties and powers.
3. The UK Government must adopt a whole system approach to tackling air pollution, linking key partners across transport, planning, health and education to tackle nitrogen oxides, particulate matter, ozone, carbon monoxide and ammonia.
4. The UK Government must build a long-term sufficient funding model for local authorities to provide comprehensive resourcing and capacity to build public awareness, enforce restrictions and reduce pollution.
5. The UK Government must promote awareness of both the short- and long-term health impacts of exposure to pollution. National campaigns would be welcomed and promoting greater focus from health practitioners when engaging with more at-risk individuals is needed to reduce the health impacts suffered by who feel the impact most.

Matthew Clark is programme manager for air quality at Hertfordshire County Council and a member of the Chartered Institute of Environmental Health (CIEH) Environmental Protection Advisory Panel.

For more information on the work of the CIEH see:

cieh.org

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