Air quality affects everyone’s health and the environment. The Royal College of Physician’s (RCP) 2016 report led to horrifying media headlines of 40,000 deaths a year in the UK being attributable to outdoor air pollution. The Government was ordered by the High Court to issue its draft Air Quality Plan, and has until the end of July to announce how it will reduce illegal levels of air pollution in the “shortest possible time”. However, there are grave concerns about the effectiveness of the Government’s draft plans to tackle this public health crisis. Drawing on our local context as a London-based consultancy, this is where we think the Government’s draft plan falls short and what we think needs to be done.
Air quality standards are concentrations recorded over a given time period, which are considered to be acceptable in terms of the effects of each pollutant on health and on the environment. These pollutants, measured in µg/m3, include particulate matter PM10 and PM2.5, nitrogen dioxide (NO2), ozone, sulphur dioxide, polycyclic aromatic hydrocarbons, benzene, carbon monoxide and lead.
The UK has national Air Quality Objectives and an EU limit with which to comply – but these are being frequently exceeded. London is breaking legal and World Health Organisation limits for nitrogen dioxide (NO2)and particulate matter (PM). Under the existing policy regime the capital is not expected to reach compliance with the legal limits on NO2 until 2025 or beyond. This has a detrimental effect on people’s health and the environment. The pollutants in the air affect everyone to some extent, and vulnerable groups, like the young, elderly and those with cardiac or respiratory conditions, much more.
In 2015, Defra issued guidance that attributed 23,500 deaths in the UK to NO2 pollution. According to the RCP report “Every breath we take: the lifelong impact of air pollution”, which estimated the overlap between PM and NO2 pollutants, “the annual mortality burden in the UK from exposure to outdoor air pollution is equivalent to around 40,000 deaths”, and the lead author of the report has said that “the best single number” in the report is actually 340,000 years, as years lost across the whole of the population – or shockingly, about three days for each person.
A main factor causing this air pollution is diesel combustion – from cars and also diesel generators and diesel-powered machines, such as diggers used on construction sites, combined with dust thrown into the air by spoil lorries. Research conducted by Edinburgh University and the British Heart Foundation found that exposure to diesel pollution is one of the main triggers of heart attacks and long-term exposure has been linked to health problems including asthma and lung cancer. Then consider the scale of the problem: Diesel vehicles emit about 40% of the capital’s total NOX emissions and a similar proportion for PM10. The ineffectiveness of the ‘Euro’ testing regime and increased use of diesel has worsened the situation in recent years.
In 2015, it was estimated that up to 12% of NO2 and 15% of PM pollution in London comes from construction and demolition activity. Eight Associates is based in Southwark, where The Evening Standard has reported on the effect on air pollution of South Bank construction, and monitors in Vauxhall close to the Nine Elms scheme have reported PM10 spikes on 43 days this year already. It is only likely to get worse; currently there are 20 major developments underway with at least another 12 to follow shortly.
What is the Government’s response? The High Court ordered the Government to publish a draft Air Quality Plan to tackle the country’s NO2 pollution by 9th May (the consultation ends on 15th June), and it has to the end of July to finalise its plan. The consultation includes the following proposed solutions:
The Government wanted to wait until after the General Election to announce its draft plan, which has been described as “weaker than hoped for” and “woefully inadequate”. Our primary observation of the plan is that it lacks detail: Responsibility to deliver clean air is pushed to local councils, without any accompanying resources to deliver this. Clean Air Zones are briefly mentioned but there is no guidance on how local authorities should implement them. There is a lack of technical supporting data. The plan makes no mention at all of a significant source of diesel combustion pollution, non-road mobile machinery (NRMM), or exemption levels to the enforcement measures in place. We could still be faced with illegal air quality for years to come.
We hoped to see a more detailed and robust policy – for transport and beyond. Perhaps the boldest step would have been a new Clean Air Act for the whole country to curb all types of air pollution. London has its own pollution level requirements, and these should be rolled out across all major UK cities. We need a wider national framework of low emission zones and well-funded Clean Air Zones where there are illegal levels of pollution.
For transport, it is disappointing that no robust diesel scrappage scheme was announced, or measures to promote an increased network of plug-in points for electric vehicles. The Government has missed the opportunity for increased investment in public transport, walking and cycling routes.
It is worth highlighting the simple fact that trees are low cost pollution detectors and deterrents. Increased green infrastructure – to act as an urban pollutant filter – could have a dramatic impact: A recent study by Lancaster University demonstrated that PM levels in residential properties along a busy road reduced by as much as 50% after installation of silver birch trees.
We must tackle construction sector pollution, the majority of which comes from diesel diggers, generators and other machines operating on sites, known as NRMM (non-road mobile machinery). A senior air quality analyst at King’s College stated that a single excavator could produce as much pollution as “14 or 15 double-deckers meeting the Euro 4 standard”.
In August 2014 the Mayor of London adopted the Control of Dust and Emissions from Construction and Demolition Supplementary Planning Guidance (SPG) following extensive consultation. The SPG includes a Non-Road Mobile Machinery Low Emission Zone (NRMM LEZ), which comprises standards to address both nitrogen oxide and particulate matter emissions.
From 1st September 2015 construction equipment used on the site of any major development within Greater London has been required to meet the EU Stage IIIA as a minimum; and construction equipment used on any site within the Central Activity Zone or Canary Wharf will be required to meet the EU Stage IIIB standard as a minimum. From 1st September 2020 any NRMM used in Greater London should be IIIB rated, with Central Activity Zone or Canary Wharf needing to meet Stage IV. Under the latest EU proposals all new engines entering the EU market must be Stage 5 certified by 2021.
What impact will this have? The reduction in air pollution for a diesel nonroad engine (NRE) rated between 130-560 kW under the EU stages are significant (see figure below).
However, whilst all machinery operating on London major developments should be IIIA rated, there are exceptions for where procuring plant with these standards is not feasible or is prohibitively expensive. For example, currently there are block exemptions for truck mounted cranes and constant speed engines (e.g. generators), which do not need to achieve the IIIB standard.
Enforcement is made through Air Quality Management Plans and Section 106 commitments. Currently the enforcement system requires contractors to log their plant details on the NRMM register, which is then checked by the Local Authority’s Pollution Officer. Whilst enforcement could be used, in theory, to delay discharge of planning conditions as punishment for non-compliance, any examples or data relating to participation (or violations) has been uneasy to find. Also, it is unclear how many site checks have been undertaken. Making performance data reporting available would demonstrate that local authorities are serious about tackling this issue through rigorous enforcement – and most importantly, that progress is actually being achieved. The NRMM policy is still in the relatively early stages, however, given the life-limiting state of air quality in London, it would seem appropriate to expect some hard data on enforcement and demonstrable commitment to the policy intent.
Air pollution is an inescapable, unignorable public health issue that affects everyone. Eight Associates will be using our expertise to contribute to the Government’s consultation and calling for greater transparency in the performance data – and we encourage you to do the same.