The purpose of the cross-party Campaign for Clean Air in London (CCAL) is to achieve urgently and sustainably at least World Health Organisation (WHO) recommended standards of air quality throughout London.

Air pollution near many of London's busiest roads averages well over twice the WHO's maximum recommended levels. When the political will existed in the past, air pollution issues were tackled quickly, for example the ozone layer, leaded petrol, acid rain and pea-souper smogs. All that is needed now is for the Prime Minister to make a commitment that the government will comply fully with [health based] air quality laws and for that commitment to be followed by determined action to meet deadlines. If you are worried about air pollution, please email the Ministers responsible for air quality at hilary.benn@defra.gsi.gov.uk and Lord Adonis at andrew.adonis@dft.gsi.gov.uk telling them about your concerns and ask them to press the Prime Minister for such a commitment and such action. It really is that simple.

With the spotlight on the London 2012 Olympic and Paralympic Games (London 2012) after the successes of Beijing, the United Kingdom has a choice: 'Ridicule for breaching air quality laws every year'; or a 'Standing ovation for showing the world how to address sustainability issues'.

CCAL's immediate priority is to see that air quality laws are rigorously enforced in each year leading up to London 2012.


For a comprehensive update on London air quality, please see the webcast of the London Assembly Environment Committee's investigation into air quality (4 February 2009, 110 minutes)

   more »

CAMPAIGN UPDATE: 4 February 2010

Government says ‘there has not been a cover-up’ on air quality premature deaths

Government fails to: acknowledge importance of premature deaths as a key metric in communicating health impact of dangerous airborne particles to the public; or justify its slowness in updating crucial air quality statistics

‘Clean Air in London’ urges again Environmental Audit Committee to support call for government apology after failing to update, or covering-up of, over 250,000 premature deaths due to dangerous airborne articles over 10 years

‘Clean Air in London’ urges Mayor of London not to make the same mistakes

The government has written to the Campaign for Clean Air in London (CCAL), just days before the Environmental Audit Committee (EAC) meets next Tuesday to take evidence as part of its inquiry into air quality, to say ‘there has not been a cover-up’ over air quality premature deaths. CCAL has published the government’s letter on its website with this Campaign Update.

The EAC has announced today it will take evidence from King’s College London and others.

Government makes its case for not updating premature death estimates since 1998

Simon Birkett, Founder of CCAL, said:

“We must welcome the government setting out, at last, its reasons for not updating estimates of premature deaths due to dangerous airborne particles since 1998. Justification is needed since the government has known since 2001 the health effects of long-term exposure are ‘considerably greater’ than the effects of short-term exposure that were quantified in 1998.

“In CCAL’s view, two points are particularly indefensible. First, the government’s persistent refusal to acknowledge the importance of premature deaths (aka ‘attributable’ or ‘brought forward’ deaths) as a key metric in communicating the health impact of dangerous airborne particles to the public. Its stance contrasts sharply, for example, with that of the European Environment Agency, the European Commission, the United States’ Environment Protection Agency and the World Health Organisation (WHO). Second, the government’s slowness in updating crucial air quality statistics.

“The government’s complacency is indefensible when 3,460 and up to 7,900 people are estimated by CCAL to have died prematurely due to dangerous airborne particles in London in 2005 alone. They may have died 9.8 years early on average.

“CCAL therefore calls again on the government to apologise for not warning the public, as it should have done, about the full extent of the health risks of poor air quality after its failure to update, or its ‘covering-up’ of, over 250,000 premature deaths due to dangerous airborne particles over 10 years. CCAL urges the EAC and others to support such a call.”

Further details of CCAL’s investigation are shown in the Appendix that follows.    more »

CAMPAIGN RESPONSE: 28 January 2010

The Rt. Hon. Hilary Benn MP
Secretary of State
Department for Environment Food and Rural Affairs
Nobel House
17 Smith Square
London SW1P 3JR

By email: hilary.benn@defra.gsi.gov.uk and euairquality@defra.gsi.gov.uk


28 January 2010


Dear Secretary of State

Secretary of State warned of need to take action after hourly limit value for NO2 breached today

Response to consultation on draft Air Quality Standards Regulations 2010 and Impact Assessment

Secretary of State reminded he would be in breach of statutory duties if Mayor of London removes WEZ without full and simultaneous offset of air quality impacts

I am writing on behalf of the cross-party Campaign for Clean Air in London (CCAL) to respond to the consultation on the transposition of Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and cleaner air for Europe (the Directive) which closes on 29 January 2010. Thank you for the opportunity to do so.

CCAL understands the Department for Environment Food and Rural Affairs (Defra) intends to transpose the new Directive into English law under the draft Air Quality Standards Regulations 2010 (draft AQSR 2010). The consultation documents can be seen at:

http://www.defra.gov.uk/corporate/consult/airquality-transposition/index.htm

Details of CCAL’s Mission and a list of its supporters can be found at www.cleanairinlondon.org.

CCAL supports strongly all the comments made by the ClientEarth and Environmental Protection UK in their responses to this consultation (except if in conflict with this letter in which case this letter prevails).

Summary

The current consultation takes place against a background of legal action and public concern over the UK’s failure to comply with air pollution deadlines it has known about since 1999. Awareness of the scale of the public health crisis is also spreading rapidly.

As you know, the European Commission launched legal action against the UK in January last year for breaching limit values for dangerous airborne particles (PM10) that entered into force in January 2005. On 11 December 2009, the European Commission rejected the UK’s application for a time extension until 11 June 2011 to comply with these obligations in London. London is the only place in the UK still in breach of the daily limit value for PM10. The government has said it wishes to reapply for a time extension. However, when doing so, the government will need to address a consequence of it changing the monitoring of PM10 (which reduced the number of reported daily exceedances in Marylebone Road last year from 110 to 39 days i.e. just over the legal limit of 35) i.e. that widespread areas of the south east UK are likely to breach the daily limit value during warm years (such as 2003 or 2006). Please see the excellent presentation given by David Green of King’s College London in December 2009 which explains this important change:

http://www.cleanairinlondon.org/_attachments/4426048/CCAL%20080%20D%20Green%20at%20RSC%20December%202009.pdf

Limit values for annual mean and hourly concentrations of nitrogen dioxide (NO2) entered into force on 1 January 2010 to protect public health further. With London having the highest mean concentrations of NO2 of any capital city in western, or eastern, Europe, it is shocking but not surprising that London breached - in less than two weeks - the hourly limit value of 18 exceedances in a whole year (in Kensington and Chelsea, Lambeth and Wandsworth). The government’s main monitoring site for London, in Marylebone Road, breached that limit value today for the first time by reporting 25 exceedances in the year to date (after 18 yesterday for the year to date). See:

http://www.londonair.org.uk/london/asp/publicstats.asp?statyear=2010&mapview=NO2b®ion=0&site=MY1&postcode=&la_id=&objective=All

CCAL hereby formally brings the breach of the hourly limit value for NO2 in London to your attention, as the responsible Secretary of State, and requests and requires that you take urgent action as you are required to do to ensure full compliance with this standard. These standards have the same legal force as those for PM10 that you are also required to meet this year.

The primary purpose of this letter is to respond formally to Defra’s consultation on the draft AQSR 2010 and associated Impact Assessment. CCAL has a number of detailed comments on these documents which are set out in later in this letter. However, CCAL’s general impression is that the draft AQSR 2010 have been faithfully transposed except in the most important areas where the government has failed to transpose the most essential elements and/or weakened the wording to make it ambiguous e.g. which pollutants are covered, what standards must be met, where they apply, when they must be met and what happens if a time extension is obtained. Furthermore, the draft AQSR 2010 omit completely the need for penalties that are ‘effective, proportionate and dissuasive’ if the Secretary of State fails to comply fully with his obligations. The Impact Assessment quantifies the risks of long term exposure to particulate air pollution represented by PM2.5 but then fails to accept advice from its own scientific advisory body to include in any such report a wider interval up to 15% (i.e. relative risk 1.15).

In CCAL’s view, these are serious and unacceptable failings which must be addressed before the AQSR 2010 are finalised. The proposed transposition of the Directive into the draft AQSR 2010 does not yet meet the minimum requirements of the Directive.

In CCAL’s considered view, Defra’s assessment of the impacts of transposing the Directive, as set out in the consultation Impact Assessment, is not thoroughly considered. CCAL has therefore provided you with additional information that it thinks must be considered i.e. herein and CCAL’s letter to the Environmental Audit Committee dated 13 December 2009 (attached) (which forms part of this submission).

CCAL wishes separately to bring to your attention that the Mayor of London would put the Secretary of State in breach of his statutory duty (to ensure that the daily limit value for PM10 is not exceeded having been attained in west London) if the Mayor removes the Western Extension of the Congestion Charging Zone (WEZ) without offsetting fully adverse air quality impacts. CCAL’s analysis shows the position very clearly and confirms the situation beyond reasonable doubt.

With the government and the Mayor failing in so many ways to comply with their duties to improve air quality, CCAL hereby requests and requires the government comply immediately and in full with its obligations to protect public health.   more »

CAMPAIGN RESPONSE: 11 January 2010

Boris Johnson
Mayor of London
Greater London Authority
City Hall
The Queen’s Walk
More London
London SE1 2AA

11 January 2010


Dear Mayor Johnson

The draft Transport Strategy is not yet ‘fit for purpose’. The same is true of the Mayor’s draft: Air Quality Strategy; Economic Development Strategy; Health Inequalities Strategy; and London Plan

Mayor’s strategies fail to grasp the magnitude or urgency of the public health crisis caused by poor air quality in London. Mayor is taking ‘one or two steps backwards’ on air quality when ‘one or two bold steps forward’ are required. Mayor would need to be ‘several steps ahead’ before considering, in any way, weakening the WEZ or delaying Phase 3 of the LEZ

Mayor should announce immediately WEZ will remain and Phase 3 of LEZ will go ahead as planned in October 2010 unless a fully offsetting and substantial further package of air quality measures are implemented simultaneously with removal of WEZ and/or delay of Phase 3 of LEZ


I am writing on behalf of the cross-party Campaign for Clean Air in London (CCAL) to respond to the consultation on the Mayor’s draft Transport Strategy (TS) which closes on 12 January 2010. Thank you for the opportunity for do so. The full consultation document can be seen at:

http://mts.tfl.gov.uk/Read-the-strategy/Download-the-full-strategy-(1).aspx

Details of CCAL’s Mission and a list of its supporters can be found at www.cleanairinlondon.org.

CCAL supports strongly (except if in conflict with this letter in which case this letter prevails): all the comments made by the Campaign for Better Transport, ClientEarth, Environmental Protection UK and Friends of the Earth in their responses to this consultation; the 65 Recommendations submitted previously by CCAL to your environment team (attached); and the cross-party report published by the Environment Committee of the London Assembly on 1 May 2009 titled ‘Every Breath You Take’ which can be seen at:

http://www.london.gov.uk/assembly/reports/environment/air-quality-report-200904.pdf

CCAL has responded separately to the Mayor’s draft: Air Quality Strategy (AQS); Economic Development Strategy (EDS); Health Inequalities Strategy (HIS); and London Plan. Those responses are referred to in more detail later in this letter. The various attachments to this letter form an integral part of CCAL’s response to this consultation on the draft TS.

CCAL hopes that the Mayor will give proper consideration to the responses to the consultation on the draft TS, and take into account intervening events (e.g. the recent decision by the European Commission to reject the UK’s application to delay compliance with the limit values for dangerous airborne particles (PM10)), in order to produce a robust and realistic plan for tackling the Capital’s pollution. In the absence of clear action to provide a proper response to the consultation exercise, CCAL reserves the right to launch a challenge in the Administrative court.

Please consider carefully all the above submissions and include all their recommendations in the Mayor’s TS. You will be aware that the Mayor’s strategies must be consistent between one another as well as each being adequate and properly prepared in its own right.

Summary

CCAL has reviewed in detail and responded formally to each of the Mayor’s draft: Air Quality Strategy; Economic Development Strategy; Health Inequalities Strategy; and London Plan. This letter together with its attachments comprises CCAL’s main response to the Mayor’s draft Transport Strategy.

In CCAL’s view, the strategies individually and collectively fail to grasp in their analysis, policies or proposals the magnitude or urgency of the public health crisis caused by poor air quality in London. Furthermore, but particularly the draft AQS and the draft TS, these strategies fail to include an adequate environmental assessment of the likely impact of key measures such as the removal of the Western Extension of the congestion Charging Zone (WEZ) and/or the delay of Phase 3 of the London low emission zone (LEZ). In CCAL’s carefully considered view, therefore, none of the above mentioned strategies are yet ‘fit for purpose’.

CCAL opposes the removal of the WEZ and/or the delay of Phase 3 of the LEZ. CCAL has reached this view inter alia because:

1. the WEZ is a good measure in its own right. While not primarily intended to be a mechanism to reduce harmful emissions, even the Mayor’s own, limited analysis, indicates that air quality would be adversely affected by its removal per se. CCAL considers that the WEZ could be improved by the adoption of dynamic road pricing, although this seems to have been ruled out by the Mayor;

2. Phase 3 of the LEZ is a good measure in its own right. As a mechanism intended to tackle directly harmful emissions, even the Mayor’s own, limited analysis, indicates that air quality would be adversely affected by its removal per se. In fact, earlier analysis by TfL suggested that Phase 3 of the LEZ would protect over 15% of those worst affected by poor air quality. CCAL considers it could be improved by the introduction and faster tightening of one or more additional inner LEZs combined perhaps with the slower (all other things being equal) tightening of the current outer LEZ;

3. CCAL has seen no credible package of mitigation measures to ameliorate the impact on air quality of the removal of the WEZ and/or Phase 3 of the LEZ. Those that are included are largely unspecified, unquantified, untested and likely to be small or even de minimus in effect;

4. the draft TS fails to address the scale or urgency of the air quality challenges in London and includes no adequate assessment of the environmental impact of removing the WEZ or delaying Phase 3 of the LEZ. CCAL finds it extraordinary that no modeling of air pollutant concentrations is included at this stage of the consultation process;

5. after failing to find details of local air pollution concentrations, CCAL has undertaken its own analysis and produced persuasive evidence that the daily limit value for PM10 would be breached in west London (even in a wet, mild year) if the WEZ is removed in the manner proposed. Such an event would put the Secretary of State (SOS) for Environment Food and Rural Affairs (Defra) in breach of his statutory duty to ensure limit values are not exceeded once attained. CCAL has copied this letter therefore to the SOS effectively putting him on notice, again, of this issue; and

6. in CCAL’s view, the Mayor is taking ‘one or two steps backwards’ on air quality when ‘one or two bold steps forward’ are required. Mayor would need to be ‘several steps ahead’ before considering, in any way, weakening the WEZ or delaying Phase 3 of the LEZ.

With the Mayor’s strategies and thinking seemingly still so far adrift from public health and legal realities, they clearly require substantial reworking and fresh public consultation(s). It seems most unlikely therefore that the Mayor and/or Transport for London (TfL) will be able to complete the necessary steps to delay Phase 3 of the LEZ by October 2010 and/or the remove the WEZ by the end of 2010.

CCAL therefore urges the Mayor to announce immediately that the WEZ will remain and Phase 3 of the LEZ will go ahead as planned in October 2010 unless a fully offsetting and substantial further package of air quality improvements are implemented simultaneously with the removal of the WEZ and/or the delay of Phase 3 of the LEZ. An expeditiously executed ‘handbrake turn’ now by the Mayor is better than last minute chaos and confusion.

In CCAL’s view, the Mayor cannot keep taking adverse decisions and expect them not to have consequences when long standing deadlines requiring action from him start to ‘bite’. London needs urgently a major package of systematic measures to improve air quality in a sustainable manner.   more »

CAMPAIGN UPDATE: 7 January 2010

‘Clean Air in London’ congratulates National Audit Office on its air quality report highlighting: government’s failure to comply with air pollution laws; health impact of poor air quality; Mayor’s delay of Phase 3 of LEZ; and confused delivery framework

Environmental Audit Committee takes oral evidence from Mayor of London’s Environment Adviser, Isabel Dedring, who “would tend to agree” “some of the government estimates are on the low side for the consequences of poor air quality”

Lord Berkeley articulates clearly air quality failings in London in House of Lords debate on Olympic and Paralympic Games 2012. Lord Berkeley refers to ‘Clean Air in London’ estimate of up to 7,900 premature deaths in London in 2005

The Campaign for Clean Air in London (CCAL) welcomes the high-profile highlighting this week, in separate developments, of the government’s failure to tackle air pollution over the last 10 years and the serious health consequences arising.

CCAL calls on the government to apologise for not warning the public, as it should have done, about the full extent of the health risks of poor air quality after its failure to update, or its ‘covering-up’ of, over 250,000 premature deaths due to dangerous airborne particles over 10 years.

NAO publishes its briefing on air quality for Environmental Audit Committee

The House of Commons Environmental Audit Committee (EAC) announced on 21 October 2009 its new inquiry into Air Quality. The purpose of the inquiry is to assess whether the Government is developing an effective strategy for meeting its obligations under the EU Air Quality Directives.

As a prelude to that inquiry, the EAC asked the National Audit Office (NAO) to prepare an overview of the UK’s performance to date in meeting various targets and limits for each air pollutant. The NAO has published today its report on air quality. See:

http://www.nao.org.uk/publications/0910/eac_briefing_-_air_quality.aspx

Further details of the EAC’s inquiry into air quality, including its Terms of Reference, Next Evidence Session and Written Evidence received can be found on its homepage. See:

http://www.parliament.uk/parliamentary_committees/environmental_audit_committee/inqairquality.cfm

Mayor of London’s Environment Adviser gives oral evidence to EAC

The Mayor of London’s top Environment Adviser, Isabel Dedring, and Simon Cousins, a GLA Environment Programme Officer, gave evidence at the EAC’s first oral evidence session on air quality on Tuesday 5 January 2010.

The Mayor of London had previously submitted written evidence to the EAC. See:

http://www.cleanairinlondon.org/_attachments/4404538/CCAL%20075%20Mayor%20of%20London%20submission%20to%20EAC%20111209.pdf

Other Memoranda submitted to the EAC’s air quality inquiry will be available at:

http://www.publications.parliament.uk/pa/cm200910/cmselect/cmenvaud/memo/airquality/contents.htm

For the webcast of the meeting, please see (from 56 minutes to 1 hour 33 minutes):

http://www.parliamentlive.tv/Main/Player.aspx?meetingId=5439

A transcript of the oral evidence session will be available (in due course) on the EAC’s Reports and Publications webpage.

Lord Berkeley articulates clearly London air quality failings in 2012 Olympics debate

In a separate development on Tuesday 5 January, Lord Berkeley (Labour) spoke in a landmark debate in the House of Lords on the preparations for the Olympic and Paralympic Games 2012.

For the full text of Lord Berkeley’s speech, see:

http://www.theyworkforyou.com/lords/?gid=2010-01-05a.118.0

For Lord Berkeley’s speech in the context of the full, two hour, debate, please see:

http://www.theyworkforyou.com/lords/?id=2010-01-05a.103.2#g118.0

Quotes

Simon Birkett, Founder of the cross-party Campaign for Clean Air in London (CCAL), said:

“The Campaign for Clean Air in London welcomes the high-profile highlighting this week, in separate developments, of the government’s failure to tackle air pollution over the last 10 years and the serious health consequences arising.”

National Audit Office report on air quality

“CCAL congratulates the National Audit Office (NAO) on its hard-hitting report on UK air quality which highlights the:

i. government’s failure to comply with air pollution laws and targets for dangerous airborne particles (PM10), nitrogen dioxide (NO2), oxides of nitrogen (NOx), ozone (O3), polycyclic aromatic hydrocarbons (PAH) and sulphur dioxide (SO2) under the air quality laws, the National Emissions Ceilings Directive and otherwise;

ii. source of the government’s ‘up to 24,000 [premature] deaths per year’ due to air pollution as being a report on the impact of short term exposure to air pollution (sulphur dioxide, PM10 or ozone) published by the Committee on the Medical Effects of Air Pollution (COMEAP) in 1998 (see paragraph 1.11 on page 11) (Note 1);

iii. Mayor of London’s draft strategy setting back Phase 3 of the London low emission zone to 2012, a year after the extended deadline for compliance with the limit value [for PM10] (see paragraph 2.29 on page 23); and

iv. confused and ineffective delivery framework that exists currently to tackle air pollution (see Figure 8 on page 28 and Figure 11 on page 38).

“This is an excellent report which should be compulsory reading for anyone interested in judging the UK government’s track record of complying with its obligations to reduce air pollution. CCAL urges the EAC to make good use of the NAO’s hard-hitting evidence.”

Environmental Audit Committee takes oral evidence from Mayor’s Environment Adviser

“CCAL was impressed by the EAC’s first oral evidence session on air quality on 5 January including the frankness of answers given by the Mayor’s Environment Adviser. It was refreshing to hear:

i. an acknowledgement from the EAC of evidence it has received alleging that “some of the government estimates are on the low side for the consequences of poor air quality”. When asked for a view on such evidence, the Mayor’s Environment Adviser responded “we would tend to agree [with it]” (1 hour 28 minutes);

ii. a recognition that “a couple of hundred million pounds is needed ideally to tackle this problem [of poor air quality]” (1 hour 16 minutes); and

iii. EU legal action and the threat of unlimited fines are having the positive effect of energising people to take action, belatedly, to protect public health and comply with air quality laws (1 hour 17 minutes).

“CCAL has offered to give oral evidence to the EAC.”

Lord Berkeley’s speech in parliamentary debate on Olympic and Paralympic Games 2012

“Lord Berkeley is to be congratulated for articulating so clearly the urgent need to improve air quality in London in a high-profile debate in the House of Lords on the first day back after the Christmas recess. In particular, Lord Berkeley highlighted the:

i. breaching by “a very wide margin” of air quality standards in London” (Note 2) and “We have to remember [also] that the UK is the largest emitter of NOx in the whole of Europe and is set to breach the emissions ceiling by 2010”;

ii. massive health impact of poor air quality. “This may all seem a little scientific and detailed but it is worth reminding ourselves that the Campaign for Clean Air in London estimates that in 2005 up to 7,900 premature deaths were due to dangerous airborne particles [PM10] in London. On average, those people, who account for about one in eight of the total deaths in London, may have died 10 years early”;

iii. breaching of air quality laws for PM10 every year since 2005 and the prospect of further breaches for PM10 and NO2. “I have to ask my noble friend why the Government are being so patient with the mayor”;

iv. opportunity for the Olympic Delivery Authority to “save about 800,000 lorry journeys around Stratford between last year and the time of the Olympics”;

v. need for urgent action by the Mayor and the government. “Do we want them to be called the high-pollution Olympics? I hope not”; and

vi. question: “how [can] the government say that the preparations for the Olympics are going well and breaking new grounds of sustainability in a healthy and enjoyable environment?”

“CCAL supports strongly Lord Berkeley’s recommendation that the government should waste no further time and give the Mayor of London full legal responsibility for complying with air quality laws, at least for PM10, in London. Lord Berkeley is also right to highlight the: merits of the Government’s boiler scrappage scheme; need to ban [or clean up] pre-Euro 4 diesel vehicles by 2012; and other practical steps to improve air quality.”

CCAL calls for government apology over air quality failings or ‘cover-ups’

“With Parliament’s most heavyweight groups – the House of Commons Environmental Audit Committee, the National Audit Office and the House of Lords – all now engaged fully in the real issues around poor air quality in the UK, we must expect to see urgent and meaningful action at last.”

“Importantly, evidence from the NAO has confirmed, yet again, the government’s failure since 1998 to update, or its ‘covering-up’ of, the real number of premature deaths due to dangerous airborne particles – despite scientific research pointing to much higher numbers.

“CCAL calls on the government to apologise for not warning the public, as it should have done, about the full extent of the health risks of poor air quality. CCAL urges the EAC and others to support such a call.”

Notes:

1. Health impact of exposure to dangerous airborne particles

The number of 24,000 premature deaths, referred to by the government, includes 8,100 due to short term exposure to PM10 air pollution compared with CCAL’s estimate of some 35,000 due to long term exposure to PM2.5 (i.e. fine particulate matter which comprises around 70% of PM10). The government has published no new estimate of premature deaths (whether short-term, long term or total for either PM2.5 or PM10) since 1998. The government says the coarse fraction of dangerous airborne particles (i.e. PM2.5-10) contains no significant health risk.

For further details, please see the COMEAP report published in 1998 titled ‘Quantification of the Effects of Air Pollution on Health in the United Kingdom’:

http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@ab/documents/digitalasset/dh_108458.pdf

2. Quantification of the number of premature deaths due to poor air quality

The European Topic Centre on Air and Climate Change published a report in June 2009 titled ‘Assessment of the health impacts of exposure to PM2.5 at a European level’. See:

http://air-climate.eionet.europa.eu/docs/ETCACC_TP_2009_1_European_PM2.5_HIA.pdf

3. London Air Quality Network results for 2009

Marylebone Road

http://www.londonair.org.uk/london/asp/publicstats.asp?region=0&bulletin=&site=MY1&postcode=&statyear=2009&mapview=all&objective=All

Brompton Road

http://www.londonair.org.uk/london/asp/publicstats.asp?region=0&bulletin=&site=KC3&postcode=&statyear=2009&mapview=all&objective=All   more »

CAMPAIGN UPDATE: 1 January 2010

The most-read stories of 2009

A look back at the campaign letters and updates that proved the most popular of the year.

January

Secretary of State for Environment, Food and Rural Affairs has a legal duty to ensure air quality limit values are attained and not exceeded once attained

February

Leading NGOs call for Government commitment to comply fully with Air Quality laws

March

Government maps show action is needed urgently if UK is to avoid breaching health based air quality laws for nitrogen dioxide (NO2), a toxic gas, in London from 2010 to 2015 and beyond

April

Latest research suggests 2,900 premature deaths each year in London due to dangerous airborne particles (PM10): nearly three times earlier estimates

May

Air quality: Fairer and more ambitious CO2 charge needed

June

A warning to London 2012 Olympics as Defra issues ‘First “summer smog” of 2009 alert’ with research highlighting premature deaths during August 2003 smog ‘event’

July

Air quality: Fairer and more ambitious CO2 charge needed

August

‘Every Breath You Take’: an investigation into air quality by the London Assembly’s Environment Committee

September

Mayor Johnson urged to apply Precautionary Principle for Air Quality Strategy assuming 6,300 to 7,900 premature deaths in London in 2005 due to dangerous airborne particles (PM10)

October

Verdict on Mayor Johnson’s draft Air quality Strategy: It’s a start but not yet ‘fit for purpose’

November

Mayor Johnson has a statutory duty to ensure his Air Quality Strategy includes policies and proposals for the achievement of the air quality standards

December

‘Clean Air in London’ applauds European Commission’s decision to reject UK’s application to delay compliance with health based laws for dangerous airborne particles (PM10) in London   more »

CAMPAIGN LETTER: 14 December 2009

Submission to Environmental Audit Committee's (EAC) inquiry into air quality - Published with permission from the EAC

Clerk of the Committee
Environmental Audit Committee
House of Commons
7 Millbank
London
SW1P 3JA

Dear Member of the Environmental Audit Committee

The AIR QUALITY INQUIRY

MEMORANDUM by the CAMPAIGN FOR CLEAN AIR IN LONDON

One of the worst public health failings or ‘cover-ups’ in modern history with over 250,000 premature deaths due to poor air quality in the UK undisclosed over 10 years*

Introduction

1. I am writing on behalf of the cross-party Campaign for Clean Air in London (CCAL) to submit a memorandum to the Environment Audit Committee’s (EAC’s) inquiry into Air Quality which opened on 21 October and closes on 14 December 2009. Thank you for the opportunity for do so. The EAC’s announcement of the inquiry can be seen at:

http://www.parliament.uk/parliamentary_committees/environmental_audit_committee/eacpn211009.cfm

2. The purpose of CCAL is to achieve urgently and sustainably at least World Health Organisation (WHO) recommended standards of air quality throughout London. CCAL operates under the auspices of The Knightsbridge Association, an amenity society. Further details of CCAL’s mission and its supporters can be found at www.cleanairinlondon.org.

3. CCAL supports strongly all the comments made by ClientEarth and Environmental Protection UK in their responses to this inquiry (except if in conflict with this letter in which case this letter prevails).

4. Please acknowledge receipt of this letter to the email address provided separately.

* CCAL calculation for the UK using COMEAP 2009’s 6% coefficient and methodology described in Appendix 3. In other words, the government seems to have decided not to disclose since 1998 an updated estimate of the number of premature deaths due to exposure to dangerous airborne particles (PM2.5 or PM10). There is a separate question as to whether the 250,000 figure is a substantial underestimate.

Summary

5. No effective strategy: In CCAL’s carefully considered view, the UK does not have an effective strategy to comply fully with air quality laws and shows no sign of developing one. The EAC’s inquiry is therefore timely.

6. At separate public meetings in November and December 2009, highly respected members of COMEAP (the Committee on the Medical Effects of Air Pollution) were referring still to 8,100 premature deaths per year due to PM10 in urban areas of Great Britain (Table 1.1 on page 3 of the COMEAP 1998 report). CCAL can find no other official number disclosed by the government for total premature deaths due to PM2.5 or PM10 in the UK since 1998. The COMEAP 1998 report was titled ‘Quantification of the Effects of Air Pollution on Health in the United Kingdom’ and recommended a coefficient of 0.75% per 10 micrograms per cubic metre (ug/m3) PM10 (e.g. 1.07% PM2.5) See also:

http://www.advisorybodies.doh.gov.uk/comeap/statementsreports/airpol7.htm

7. CCAL estimates, using COMEAP’s 2009 recommendation of a 6% coefficient per 10 ug/m3 PM2.5, there were around 35,000 premature deaths due to dangerous airborne particles (PM2.5) (which would be the same for PM10 based on current government advice) in the UK in 2005 (and perhaps 51,537). See Appendix 2 and paragraph 25 below.

8. Failings or ‘cover-up’ of the real health impact: Assuming CCAL is correct, pending a better estimate from the government, it is not unreasonable to assume there have been some 350,000 premature deaths due to PM2.5 and/or PM10 over the last 10 years compared to the 81,000 premature deaths one might have assumed from COMEAP or government published figures. In CCAL’s view, this ‘gap’ of over 250,000 may represent one of the biggest public health failings or ‘cover-ups’ in modern history. Action: We need clarity now on the actual and Precautionary Principle figures.

9. CCAL is concerned separately, based on a close reading of the Peer Review of the COMEAP 2009 report, that COMEAP may be substantially underestimating the health impact at 6% per 10 ug/m3 PM2.5. Higher coefficients of 12%, 15%, 16% and/or 17% are possible.

10. Modeling is not ‘fit for purpose’: The government’s modeling of air quality concentrations over the last decade has not been ‘fit for purpose’. It has pointed and continues to point to expected sharp reductions in concentrations of dangerous air pollutants. Each year, the government registers apparent ‘surprise’ when actual results show the opposite picture. What is more alarming is that the UK has justified less monitoring of air pollution than other countries on the back of its commitment to modeling. This is not acceptable and again endangers public health and the successful planning and delivery of an effective strategy to improve air quality. Action: Future strategy should assume no change in concentrations under business as usual until modeling is proven to be reliable.

11. No coherent delivery chain: The almost total disjunction between the government’s responsibility, on behalf of the Member State, and the ‘work towards compliance’ duty on local authorities has been a recipe for failure. In general, local authorities (and the Mayor of London) seem to have little appetite to take action they are not required to take. Action: The Environment Agency should be given national responsibility, authority, accountability and adequate resources to ensure full compliance everywhere with air quality laws (perhaps as in the USA; proposed at Heathrow; and/or in relation now to flooding). Alternatively or additionally, a very clear chain of delivery needs to be defined for each layer of government and others. See also Appendix 5.

12. Next steps: Many steps need to be taken to improve air quality in the UK and comply fully with air quality laws. These include: scrapping COMEAP and replacing it with a body more like the Health Effects Institute in the USA; giving the Mayor of London sole responsibility for complying immediately with EU limit values for PM10; using everything including the ‘kitchen sink’ to ensure full compliance with EU limit values for nitrogen dioxide (NO2); and launching a major campaign to build public understanding of the health risks of poor air quality and the actions needed to minimise them.

13. The opportunity: Protecting public health and complying with air quality laws also offers many co-benefits. The UK could show at the 2012 Olympics how air pollution and wider sustainability issues can be tackled successfully in major cities. Ridicule is in prospect if air quality is not tackled.

Health and environmental risks caused by poor air quality

Warning: CCAL has a lay understanding of epidemiology but has made every reasonable effort to ensure the accuracy of its statements on health risks.

Health risks - Dangerous airborne particles (see also Appendix 1)

14. Dangerous airborne particles are usually categorised by size: fine particles called PM2.5 (less than 2.5 microns in diameter (um)); coarse particles called PM2.5-10; and PM10 (less than 10 um in diameter). PM2.5 arises largely from combustion and PM2.5-10 arises largely from mechanical processes e.g. tyre and brake wear. A recent EEA/ETC report estimated that within Europe about 70% of PM10 concentrations comprise PM2.5. i.e. 0.75% per 10 ug/m3 PM10 = 1.07% per 10 ug/m3 of PM2.5.

15. Note: COMEAP’s advice is that there is little risk in the coarse fraction so its health impacts are often not quantified i.e. all the risk for PM10 is contained in PM2.5. Some scientists disagree and consider that toxicity appears across the PM fraction. CCAL has adopted COMEAP’s stance for simplicity i.e. the number of premature deaths due to PM2.5 and PM10 is the same.

16. CCAL’s understanding of the timeline of knowledge about the health risks of PM2.5 and PM10 is set out in Appendix 1 and more briefly below.

17. In 1998, in its report titled “Quantification of the Effects of Air Pollution on Health in the United Kingdom”, COMEAP proposed in paragraph 9.18 on page 57 a hazard rate (or risk coefficient) for short term exposures of 0.75% per 10 ug/m3 PM10 as a 24 hour mean for all ages. It felt there was insufficient data to allow acceptably accurate quantification of [long term] health effects.

18. In March 2001, in its report titled “Statement and Report on Long-Term Effects of Particles on Mortality”, COMEAP proposed a hazard rate (or risk coefficient) for long term exposures of 0.1% per 1 ug/m3 drop in annual mean PM2.5 for those aged 30 years and over (i.e. 1.0% per 10 ug/m3).

19. In June 2009, in its report titled “Long-Term Exposure to Air Pollution: Effect on Mortality”, COMEAP proposed in paragraph xiii on page 3 a hazard rate (or risk coefficient) for long term exposures of 6.0% per 10 ug/m3 increase in annual mean PM2.5 for those aged 30 years and over.

20. CCAL urges the EAC to consider the Peer Review comments submitted on COMEAP’s draft report (see Appendix 1 of COMEAP 2009) which include serious criticisms of COMEAP’s choice of coefficients and of the elicitation process used by COMEAP to choose the recommended coefficient.

See: http://www.dh.gov.uk/ab/COMEAP/DH_108151

21. CCAL urges the EAC to consider Defra’s report on the impact of delay in complying with air quality laws on race. It is titled ‘UK notification to the European Commission to extend the compliance deadline for meeting PM10 limit values in ambient air to 2011, Race Equality Impact Assessment (England)’. See Appendix 6.

22. CCAL is not aware of any update on the total societal costs of poor air quality since Table 2.14 on page 90 of the Defra 2007 Air Quality Strategy (AQS):

http://www.defra.gov.uk/environment/quality/air/airquality/publications/stratreview-analysis/chap-2-icgb.pdf

While 6% remains the COMEAP 2009 recommendation, the range for 2005 societal costs is £8.582 bn to £20.165 bn. The 7 to 8 months average national impact in life expectancy appeared in the Foreword of the same 2007 AQS.

23. Applying COMEAP 2009 recommendations using the Precautionary Principle suggests a coefficient of 15%. Even however at a lower 12%, the societal costs were £16.238 bn to £38.115 bn in 2005 (per Table 2.14 in the 2007 AQS).

Government or COMEAP statements re premature deaths due to PM2.5 in the UK in 2005

24. At separate public meetings in November and December 2009, highly respected members of COMEAP were referring still to a 1998 COMEAP figure of 8,100 premature deaths per year due to PM10 in urban areas of Great Britain (Table 1.1 on page 3 of the COMEAP 1998 report). CCAL can find no other official number disclosed by the government for total premature deaths due to PM2.5 or PM10 in the UK since 1998. The COMEAP 1998 report was titled ‘Quantification of the Effects of Air Pollution on Health in the United Kingdom’. See also:

http://www.advisorybodies.doh.gov.uk/comeap/statementsreports/airpol7.htm

The public events were the Environmental Protection UK autumn conference on 12 November 2009 and the Royal Society of Chemistry’s annual conference on 9 December 2009.

CCAL’s lay calculation of premature deaths due to PM2.5 in the UK in 2005

25. The European Topic Centre on Air and Climate Change estimated in its paper titled ‘Health Impacts and Air Pollution – An exploration of factors influencing estimates of air pollution impact upon the health of European citizens’ in December 2008 estimated that there were 51,537 premature deaths attributable to exposure to ambient PM10 concentrations in the UK in 2005 (Table 1.1 on page 8).

See: http://air-climate.eionet.europa.eu/reports/ETCACC_TP_2008_13_HealthImpact_AirPoll

26. CCAL has calculated the number of premature deaths due to PM2.5 in the UK in 2005 using three separate methods (see Appendix 2).

27. CCAL estimates that between 33,000 to 40,000 people died prematurely due to PM2.5 (or PM10) in the UK in 2005 assuming the COMEAP 2009 6% coefficient. The number may be as high as 51,537 (see paragraph 25 above). Note that levels of PM2.5 have been broadly static over the last 10 years.

28. Assuming CCAL is correct, pending a better estimate from the government, it is not unreasonable to assume there have been some 350,000 premature deaths due to PM2.5 and/or PM10 over the last 10 years compared to the 81,000 premature deaths one might have assumed from COMEAP or government published figures. In CCAL’s view, this ‘gap’ of over 250,000 may represent one of the biggest public health failings or ‘cover-ups’ in modern history.

29. CCAL is concerned separately, based on a close reading of the Peer Review of the COMEAP 2009 report, that COMEAP may be substantially underestimating the health impact at 6% per 10 ug/m3 PM2.5. Higher coefficients of 12%, 15%, 16% and/or 17% are possible.

CCAL’s lay calculation of premature deaths due to PM2.5 in London boroughs in 2005

30. CCAL has similarly calculated the number of premature deaths due to PM2.5 in London in 2005 for each London borough (Appendices 3 and 3A). CCAL estimates that there were between 3,500 (assuming a 6% coefficient) and 6,500 (assuming a plausible 12% coefficient) and 7,900 (using a wider 15% coefficient) premature deaths due to PM2.5 in London in 2005. The actual numbers may be around 10% higher depending on average population-weighted exposures in outer London. These numbers dwarf the 1,031 premature deaths due to PM10 in 2005 that the government told Mayor Livingstone which were based on a coefficient of 0.75% per 10 ug/m3 increase in PM10 (per COMEAP’s 1998 recommendation) (refer to CCAL letter to Mayor Johnson dated 20 September 2009).

Health risks - Nitrogen dioxide (NO2) (see also Appendix 4)

31. At Environmental Protection UK’s autumn conference on 12 November 2009, CCAL recollects Professor Jonathan Ayres, Chairman of COMEAP, making a personal comment (i.e. not official COMEAP policy) to the whole meeting that public exposure to ambient concentrations of nitrogen dioxide in the urban environment is ‘irrelevant’ for public health. CCAL recollects Professor Ayres went on to emphasise though that NO2 has the advantage of being very easy to monitor and it is a reliable indicator of hazardous vehicle emissions. Despite these important clarifications, CCAL considers that Professor Ayres’ personal comments could be a source of public confusion and therefore merit clarification from the government.

Environmental risks

32. CCAL draws the EAC’s attention to the European Commission’s press release dated 12 December 2007 which included estimates of the cost impact of air pollution on biodiversity. See:

http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/07/571&format=HTML&aged=1&language=EN&guiLanguage=en

Summary health issues and the effective communication of them

33. A cynic might say that COMEAP in 2009 chose not to increase its coefficient of total mortality for PM2.5, despite significant new research published in 2005 and 2006, because: it did not wish to ‘run’ ahead’ of WHO advice (2006); the European Commission’s CAFÉ programme; and/or Defra’s Air Quality Strategy (2007). A cynic might also suggest that COMEAP may have been concerned about presenting health impact coefficients much higher than those it had identified in 1998 and 2001.

34. CCAL’s carefully considered view, influenced by comments in the Peer Review of COMEAP 2009, is that COMEAP is likely to have understated (perhaps very substantially) in 2009 the health impact of poor air quality.

35. Further, CCAL considers that the Precautionary Principle should be followed when public health is at risk. On this basis, COMEAP’s 2009 recommendations point to coefficients of 12% or 15% per 10 ug/m3 PM2.5.

36. Irrespective of the correct coefficient for total mortality, CCAL considers it important to communicate the health impact of poor air quality appropriately (i.e. in a manner which is meaningful and most useful) to different audiences. There are four common metrics: premature or attributable deaths; total (e.g. national) years of life lost (YLL); average reduction in life expectancy across the whole UK population; and years lost per statistical victim. In CCAL’s experience, premature death and years of life lost per statistical victim are the most effective measures to use for communication with the general public. Clearly, as with all risks, it is important to explain the meaning of the metric carefully. YLL may be appropriate for economists et al.

37. Please note that CCAL has not mentioned the health impact of other forms of air pollution in this memorandum e.g. ozone (O3) and sulphur dioxide (SO2).

38. In CCAL’s view, Londoners should be warned that up to one person in eight who died in Greater London in 2005 may have done so due to exposure to dangerous airborne particles (assuming only average UK population-weighted exposures in London). Research published in 2001 by Professor Nino Kunzli suggests that those who die prematurely due to dangerous airborne particles may do so, on average, 9.8 years early. On this basis, the health impact of poor air quality in London is similar or greater to that for alcoholism, obesity and/or smoking.

Steps that need to be taken to ensure that air quality targets will be met in future

39. Many steps need to be taken to improve air quality in the UK and comply fully with air quality laws including those set out below.

40. The government must ‘grip’ the UK’s serious air quality problem and deliver on its responsibilities.

41. The government must disclose as a matter of urgency its assessment of the number of premature deaths due to dangerous airborne particles (PM2.5) in each region of the UK in 2005 (or preferably a more recent year) (using at a minimum COMEAP 2009’s 6% coefficient) together with a Precautionary Principle number (e.g. the 15% coefficient). Also an estimate of the years of life lost per statistical victim. These metrics are provided for other health risks e.g. obesity and smoking.

42. The government should scrap COMEAP or revamp it to ensure its independence, effective governance and focus on highlighting multiple metrics and adopting explicitly a faster review of evidence and the use of the Precautionary Principle approach to protect public health. CCAL would favour replacing COMEAP with a body more like the Health Effects Institute in the USA with its Independent Board of Directors (with legal duties). See: http://www.healtheffects.org/index.html

43. The government must weigh benefits and costs against the need to meet air pollution deadlines whether for air quality or climate change.

44. The government should give the Mayor of London legal responsibility for ensuring full compliance with air quality laws for PM10 immediately.

45. The government needs to take a strong lead on ensuring compliance with air quality laws for NO2. In CCAL’s view this may require ‘every measure available including the kitchen sink’. See Defra’s write up of its NO2 measures workshop dated 4 August 2009.

46. It is imperative that planning takes place now to ensure full compliance with air quality laws for PM2.5 since these are likely to drive public health benefits once EU limit values for PM10 and NO2 are met.

47. CCAL has proposed 65 recommendations to improve air quality in London (Appendix 7). Many are relevant nationally. These include ‘The London Matrix’, ‘The London Principle’ and ‘The London Circles’.

48. The government must maximise economy of scale benefits by taking an active lead and giving directions on measures such as inner city low emission zones (to avoid national waste and chaos).

49. The government must drop its myopic focus on CO2 to the exclusion of other air pollutants. In particular, its approach to diesel has been a significant cause of poor quality in our biggest cities.

50. A major public understanding campaign should be launched to warn people about the dangers of poor air quality and the measures individuals can take to reduce its impact.

51. Government should press the European Commission and the WHO to update urgently (and well before 2013) their recommendations for the health impact of poor air quality based on the most up to date scientific research referred to in this memorandum or otherwise.

52. Protecting public health and complying with air quality laws will show how air pollution and sustainability can be tackled successfully. The 2012 Olympics offers an opportunity to do so.

Close

53. CCAL would be pleased to clarify or provide further evidence and/or give verbal evidence to the EAC.

54. Please confirm that CCAL may publish this letter on its website and otherwise circulate it.

55. CCAL has copied this letter to the National Audit Office team investigating air quality for the EAC.

With best wishes.

Yours sincerely

Simon Birkett
Founder and Principal Contact
Campaign for Clean Air in London

Enclosures

Cc: National Audit Office

Note: the full letter appears as an attachment with three further appendices   more »

CAMPAIGN LETTER: 17 November 2009

Boris Johnson
Mayor of London
Greater London Authority
City Hall
The Queen’s Walk
More London
London SE1 2AA

By email: MAQS@london.gov.uk

17 November 2009


Dear Mayor Johnson

Mayor of London has a statutory duty to ensure his Air Quality Strategy (AQS) includes policies and proposals for the achievement of the air quality standards

‘Clean Air in London’ and Health Protection Agency have agreed estimates of premature deaths in London due to fine particulate matter (PM2.5) in 2005 (assuming average-only UK exposure): 3,000 (COMEAP central estimate); 5,600 (plausible estimate); and 6,900 (Precautionary Principle)

The draft AQS is a start but not yet ‘fit for purpose’. Five NGOs (and others) have written therefore to the European Commission urging it to reject the UK’s application to delay compliance with the EU limit values for PM10

I am writing on behalf of the cross-party Campaign for Clean Air in London (CCAL) to respond to the consultation on the Mayor’s draft Air Quality Strategy (AQS) which opened on 5 October and closes on 30 November 2009. Thank you for the opportunity for do so. The full consultation document can be seen at:

http://www.london.gov.uk/mayor/environment/air_quality/index.jsp

Details of CCAL’s Mission and a list of its supporters can be found at www.cleanairinlondon.org.

CCAL supports strongly (except if in conflict with this letter in which case this letter prevails): all the comments made by Environmental Protection UK and ClientEarth in their responses to the consultation; the 65 Recommendations submitted previously by CCAL to your environment team (attached); and the cross-party report published by the Environment Committee of the London Assembly on 1 May 2009 titled ‘Every Breath You Take’ which can be seen at:

http://www.london.gov.uk/assembly/reports/environment/air-quality-report-200904.pdf

Please consider these submissions and include all their recommendations in the Mayor’s AQS.

Summary

The Mayor’s draft AQS is a start but it is not yet ‘fit for purpose’. To become ‘fit for purpose’ it should apply the Precautionary Principle to tackle a serious public health problem and must show how air quality laws will be complied with in full.

CCAL has agreed with government officials that some 3,000 premature deaths occurred due to exposure to dangerous airborne particles (PM2.5) in London in 2005 (even assuming average UK population-weighted exposure) and that the number may have been 6,900 (again assuming average UK population-weighted exposure). At the higher level that would represent one in eight deaths in London in 2005. Professor Nino Kunzli estimated in 2001 that the amount of time lost per statistical victim is 9.8 years equating to some 0.6 years in the total population (i.e. seven to eight months). Please recognise the scale and urgency of this public health crisis in the Mayor’s AQS.

The Greater London Authority Act 1999 (GLA Act) requires that the Mayor of London’s AQS contains ‘… policies and proposals – for the achievement in Greater London of the air quality standards and objectives prescribed in regulations made under the Environment Act.’ In ‘Mayor answers to London’, you have admitted to Mike Tuffrey that ‘expected’ compliance with PM10 limit values is ‘subject to: detailed concentration modeling; and – importantly – to full funding of the programme and support from boroughs and central government’. You have stated that concentrations of oxides of nitrogen (NOx) need to be reduced by some 80% to ensure compliance with the limit values for nitrogen dioxide (NO2) by January 2015 and yet your AQS plans shows only reductions in emissions of NOx of 35-40% by 2015. You have omitted to address other air quality laws also e.g. the need to ensure annual average concentrations of NO2 remain below 60 micrograms per cubic metre (ug/m3) from 1 January 2010. This is not good enough. Please recognise the scale and urgency of these legal duties in the Mayor’s AQS and comply fully with relevant health-based laws throughout London.

In CCAL’s view, the Mayor has the legal powers necessary to ensure full compliance with the European Union (EU) limit values for PM10 throughout London by June 2011 (or forthwith if the UK fails to obtain a time extension for PM10, as seems likely). Indeed, London is the only city in the UK expected still to breach those standards by that date. In contrast, over 100 cities and towns across the UK are expected to breach limit values for NO2 from January 2010, with London experiencing the highest concentrations of any capital city in western (or eastern) Europe. In CCAL’s view, the limit values for PM10 could be achieved quickly through the adoption of sensible transport policies (e.g. a Berlin style inner low emission zone) whereas the latter will require ‘everything including the kitchen sink’ (backed by numerous national initiatives and funding).

CCAL is particularly concerned that the Mayor is taking ‘one or two steps backwards’ on air quality when ‘one or two bold steps forward’ are required. The delay of Phase 3 of the LEZ and the removal of the WEZ seem certain, based on the draft AQS, to result in an unnecessary and unacceptable health burden on the public and exacerbate breaches of air quality laws. This is totally unacceptable. CCAL urges you to implement one or more inner LEZs by early 2011. CCAL is concerned that you may have wrongly dismissed such an approach by wrongly weighing the costs and benefits of a Euro 4 inner zone with a Euro 3 outer zone when you should have considered the same standards for both (since the standards must be met in inner London whether through a carefully chosen inner zone or a blunt outer zone). A transect of London for annual average concentrations of oxides of nitrogen demonstrates this situation clearly (attached).

CCAL urges you to go from ‘zero to hero’ simultaneously on environment, transport and public health matters. You could achieve a wonderful legacy for London by ensuring full compliance with air quality laws by the 2012 Olympics and put in place measures that will surely save thousands of lives. Please show the world how air pollution can be tackled successfully in all large cities including London.

Protecting public health

Poor air quality is a major public health issue in London. London is well known for having the worst air quality in the UK and amongst the worse in Europe. Without robust, early action, the UK is set to breach health-based air quality laws in London every year up to and including 2012 (and thereafter).

CCAL therefore wrote to you, in a letter dated 20 September 2009, urging you to tackle fully and urgently this public health problem and apply the Precautionary Principle when developing your AQS (including government recommendations for sensitivity analyses).

It is particularly disappointing therefore that you have failed to include any estimates for the health impact of poor air quality in your draft AQS. CCAL therefore urges you again to do so when determining the extent of policies and proposals needing to be included in the draft AQS for public consultation. CCAL’s letter of 20 September is attached and should be considered part of this submission.

CCAL was invited to meet government officials on 21 October including the Health Protection Agency (HPA) to discuss the letter of 20 September and agree the health impact of poor air quality in London. CCAL and the HPA have agreed that some 3,000 people died prematurely in London due to dangerous airborne particles (PM2.5) in 2005 (using the latest recommendation of the Committee on the Medical Effects of Air Pollutants (COMEAP) of a 6% coefficient and assuming only UK average populated-weighted exposures in London). CCAL and the HPA have also agreed, using a similar recommendation and assumption, that a plausible upper limit may be 5,600 (using a 12% coefficient) and the actual number of premature deaths may have been 6,900 (using a 15% coefficient) (out of some 52,995 total deaths in Greater London in 2005). The detailed method and calculations are shown in Appendix One. These are shocking numbers and exclude deaths from other forms of air pollution e.g. ozone (O3) and sulphur dioxide (SO2).

In a wide ranging and thorough discussion at the above meeting:

i. CCAL and the HPA agreed estimates for the number of premature deaths due to PM2.5 in London in 2005 assuming the three coefficients recommended by COMEAP (i.e. 6%, 12% and 15% as above);

ii. the HPA offered to send a weblink to the Executive Summary of the COMEAP 1998 Report titled ‘The Quantification of the Effects of Air Pollution on Health in the United Kingdom’. See below:

http://www.advisorybodies.doh.gov.uk/comeap/statementsreports/airpol7.htm

iii. we agreed for the relevant reference, in the third paragraph on page 5 of the letter, that the COMEAP Report 2009 might have used better wording such as ‘but linear scaling is a reasonable approximation in certain circumstances’;

iv. the HPA team pointed out that the COMEAP 1998 Report assessed the risk of premature death due to short term exposure to poor air quality whereas subsequent reports (2001 and thereafter) have assessed deaths due to long term exposure to poor air quality. COMEAP recommended a coefficient of 0.75% for the former and 1.0% for the latter in its 2001 Report (now 6%);

v. the HPA team pointed out that the health impact of short term exposure to poor air quality is assessed using time series analysis and deaths from all age groups. Long term, cohort studies usually apply to deaths amongst those aged 30 years and older; and

vi. the Defra team pointed out the health costs referred to on page 9 of the letter are ‘societal’ values not the cash cost to the Department of Health.

These were the only changes proposed to the letter other than identifying the need to agree subsequently an updated estimate, using COMEAP’s latest recommendations, of the 1,031 premature deaths referred to on page 3 of the letter. At the end of that meeting, CCAL asked the relevant officials to consider and revert with their estimate:

i. of the 1,031 premature deaths referred to on page 3 of the letter based on COMEAP’s current 6% coefficient for PM2.5 and assuming ratios of PM2.5 to PM10 of 65%, 70% and 75%; and

ii. for the most recent year possible, the number of premature deaths due to PM2.5 (and preferably all air pollution) in Greater London using 6%, 12% and 15% coefficients (and, if necessary, say 65%, 70% and 75% ratios for PM2.5 to PM10).

A reply is awaited but still expected.

The HPA team expressed concern that the number of premature deaths should be presented in a bar chart to show how the number of premature deaths would fall gradually over time as concentrations of dangerous airborne particles fall. CCAL agreed this approach would be useful but pointed out that it would need to show also the number of deaths due to PM10 and/or PM2.5 between the years, say, of 2000 and 2010 with a line showing actual population-weighted exposures to particulate matter over the same period i.e. not assuming sharply falling concentrations due to optimistic modeling.

The numbers estimated to die prematurely due to poor air quality have risen sharply in recent years as large scale, long term scientific studies have been completed. CCAL urges the Mayor therefore to be ‘upfront’ with people about the sheer scale of the risks in a way that means something to people i.e. not using abstract concepts for the entire 61 million UK population such as total (i.e. millions of) years of life lost and/or reduction in average life expectancy of up to seven to eight months nationally.

In CCAL’s view, people should be told that up to one person in eight who died in London in 2005 may have done so due to exposure to dangerous airborne particles (assuming only average UK population-weighted exposures in London). Research published in 2001 by Professor Nino Kunzli suggests that those who die prematurely due to dangerous airborne particles may do so, on average, 9.8 years early.

The health impact of poor air quality is similar or greater to that for alcoholism, obesity and/or smoking.   more »

CAMPAIGN LETTER: 20 September 2009

Mayor Johnson urged to apply Precautionary Principle for Air Quality Strategy assuming 6,300 to 7,900 premature deaths in London in 2005 due to dangerous airborne particles

Boris Johnson
Mayor of London
Greater London Authority
City Hall
The Queen’s Walk
More London
London SE1 2AA

By email: mayor@london.gov.uk

20 September 2009

Dear Mayor Johnson

Government releases previously unpublished spreadsheets for calculating premature deaths due to air pollution in London after formal information request from ‘Clean Air in London’ (CCAL)

Using government spreadsheets and its current risk figures indicates there were around 5,000 premature deaths in London in 2005 due to dangerous airborne particles (PM10) alone

CCAL urges Mayor Johnson to apply the Precautionary Principle when developing his Air Quality Strategy and accept government recommendations for sensitivity analyses which suggest there may have been some 6,300 to 7,900 premature deaths in London in 2005 due to PM10 alone

CCAL calls for a radical overhaul of guidance from the Health and Safety Executive after a long-serving London policeman describes air pollution on a ‘fixed post’ that made him ‘rasp’

I am writing on behalf of the Campaign for Clean Air in London (CCAL) to urge you to take full and appropriate account of the most up-to-date scientific evidence on the health impact of poor air quality and to apply the Precautionary Principle in developing your forthcoming Air Quality Strategy.

Many people have aided CCAL in understanding the issues set out in the letter. CCAL thanks them all.

Summary

Ministers tend to say: air quality is good across 99% of the UK’s landmass; has improved a lot since 1990; that people lose on average a maximum of seven to eight months of their lives due to the problem; and the alert bands show air pollution as being mostly ‘low’ or ‘moderate’.

The real picture is quite different. No-one lives in our fields and mountains; they live alongside the 1,117 kilometres of roads in London (2,496 kilometres nationally) [Note 2] forecast by the government to breach legal standards for nitrogen dioxide (NO2) in 2010. Air quality has improved since 1990 but the level of dangerous airborne particles (PM10) in London has increased at a mean rate of around 0.4% per year since the late 1990’s despite public health laws requiring sharp reductions [Note 3]. London has the highest annual mean concentrations of NO2 of any capital city in western (or eastern) Europe. Rather than talk abstractly about an average reduction in life expectancy across 60,975,000 people, Ministers should warn people that the amount of time lost per statistical victim due to dangerous airborne particles may be 9.8 years [Note 4]. Air quality can be in the 'low' band all year round but still breach European Union (EU) limit values.

Embarrassment at the London 2012 Olympics over unlimited fines and legal action to enforce air quality laws will be outweighed by the government’s failure to protect lives.

CCAL therefore wrote to the Secretary of State for Health in a letter dated 19 April 2009 to ask the Department of Health (DoH): for its urgent assistance to clarify the full extent of the health impact of poor air quality in Greater London; and to commit to a major public information programme to communicate updated similar information at least annually in future.

In a reply from the DoH (attached as Appendix One) and in subsequent meetings with DoH executives and others, CCAL has obtained a more detailed understanding of the health impacts of poor air quality in London. CCAL has also obtained a response from the Department from Environment Food and Rural Affairs (Defra) under the Environmental Impact Regulations 2004 (EIR) that discloses two previously unpublished spreadsheets used by the government to calculate premature deaths in London due to poor air quality (the letter and spreadsheets are attached). In addition, the Committee on Medical Effects of Air Pollution (COMEAP) published, in June 2009, its final report titled ‘Long Term Exposure to Air Pollution: Effect on Mortality’.

As a result of this further work, CCAL has become more concerned even than previously about the health impact of air pollution on Londoners. Assuming that London suffers no worse than average UK population-weighted levels of fine particles (PM2.5) CCAL estimates, from information in the government’s Air Quality Strategy 2007, that some 3,100 people died prematurely (i.e. Attributable Deaths) in London in 2005. This number compares with that calculated by CCAL earlier this year of around 2,900 from the European Environment Agency’s report on PM10. Using COMEAP’s currently recommended coefficient in the government spreadsheet indicates some 5,000 premature deaths in London in 2005 due to long-term exposure to PM10 alone compared to the 1,031 premature deaths from short-term only air pollution which has been referred to in London for several years. CCAL is arranging to meet government officials to check this result.

Please note that the need for scientists to have exceptionally high standards of proof means that it has taken some 15 years to determine that long-term exposure to airborne particles has some 10 times greater impact on mortality (i.e. deaths) than short-term exposure.

Assuming again that London suffers no worse than average UK population-weighted levels of PM2.5, and applying the Precautionary Principle and COMEAP’s recommendation to use a wider interval of relative risk in any report on quantification of risks from long term exposure to particulate air pollution represented by PM2.5, suggests that between 6,300 and 7,900 people may have died prematurely in London in 2005 due to PM2.5 (and therefore PM10).

Action 1: CCAL urges you, as Mayor of London, to take full account of this latest information in your forthcoming Air Quality Strategy and to address the other actions listed in this letter. Radical and urgent action is needed now to reduce sharply levels of dangerous airborne particles (PM2.5 and PM10) and other pollutants (e.g. NO2) in London.

Notes for Summary:

1. PM10 is particulate matter (or dangerous airborne particles) with an aerodynamic diameter of up to 10 microns (one-millionth of a metre), i.e. fine (PM2.5) and coarse (PM10 minus PM2.5) PM fractions together.

2. Page 6 of Defra’s ‘UK Approach to its Application for Time Extension Notification to Nitrogen Dioxide Limit Value deadline’. See

http://www.defra.gov.uk/environment/airquality/panels/forum/documents/aq-forum-draft-no2-approach-paper0902.pdf

3. Page 5 of King’s College London, London Air Quality Network report ‘Air quality in London, Report 14, 2006-7’

http://www.londonair.org.uk/london/reports/AirqualityinLondon2006-2007.pdf

4. Paragraph 3 of discussion section of ‘Assessment of Deaths Attributable to Air Pollution’ by Künzli et al 2001. See:

http://aje.oxfordjournals.org/cgi/content/full/153/11/1050   more »

CAMPAIGN LETTER: 19 April 2009

The Rt. Hon. Alan Johnson MP
Secretary of State for Health
Department of Health
Richmond House
79 Whitehall
London SW1A 2NS

By registered post

19 April 2009


Dear Secretary of State

What is the real health impact of poor air quality in Greater London?

Latest research suggests some 2,900* people aged 30 or over may die prematurely per annum from dangerous airborne particles (PM10) in Greater London alone: nearly three times earlier estimates

Research suggests amount of time lost, per statistical victim, may be 9.8 years equating to an average change in life expectancy of approximately 0.6 years (7.2 months) in the total population

This letter is sent on behalf of the Campaign for Clean Air in London (CCAL). Details of our Mission and Supporters can be seen at www.cleanairinlondon.org.

Summary

The primary purpose of this letter is to ask the Department of Health (DoH): for its urgent assistance to clarify the full extent of the health impact of poor air quality in Greater London; and to commit to a major public information programme to communicate updated similar information at least annually in future.

On 24 March 2009, the European Environment Agency published a report titled ‘Spatial assessment of PM10 and ozone concentrations in Europe (2005)’ (the EEA Report) from which CCAL calculates there were some 2,905 premature deaths attributable to dangerous airborne particles (PM10) among adults of 30 years of age and older in Greater London in 2005. The EEA Report (5.2 MB) can be downloaded at:

http://www.eea.europa.eu/publications/spatial-assessment-of-pm10-and-ozone-concentrations-in-europe-2005-1

Furthermore, some of the medical research to which the EEA refers (Kunzli et al, 2000), suggests that the amount of time lost per statistical victim may be 9.8 years equating to a change in life expectancy of approximately 0.6 years (7.2 months) in the total population.

This new information is particularly worrying given that: the only previous premature death figure for London seen by CCAL was 1,031 premature deaths from PM10 in total in 2005; and the government’s Air Quality Strategy for England, Scotland, Wales and Northern Ireland in 2007 (AQS 2007) appears to have omitted references to premature deaths (when earlier government-sponsored publications had included them) and years of life lost. The AQS 2007 stated simply ‘estimated to reduce life expectancy of every person in the UK by an average of 7-8 months with an equivalent health cost of up to £20 billion each year’.

CCAL is deeply concerned that the public health impact of poor air quality in Greater London, which is recognised – including by the government – to be the worst in the United Kingdom (UK), may be much worse than earlier research showed.

In addition, why have major public information campaigns been launched on alcohol abuse, obesity, road traffic accidents and smoking – and not on poor air quality – when poor air quality is such a major killer? Similarly, why is there no-one seemingly from the DoH commenting regularly in the media on the importance of major research into the health impacts of poor air quality whenever it appears?

In CCAL’s view, it is essential that people are given an opportunity to understand the full extent and seriousness of the air quality problem and the part they can play in improving the situation.

* CCAL calculation based on latest European Environment Agency Report; Greater London assumed to have no worse than average UK exposure to PM10; and ONS population estimates for mid-2007.   more »

CAMPAIGN UPDATE: 1 March 2009

Government maps show action is needed urgently if the United Kingdom is to avoid breaching health based air quality laws for nitrogen dioxide (NO2), a toxic gas, in London from 2010 to 2015 and beyond

United Kingdom tops the league for toxic traffic fumes in Europe with: the highest proportion of zones breaching the annual average limit value plus margin of tolerance for NO2; and the most polluted capital city

Government maps obtained by the Campaign for Clean Air in London (CCAL), under the Freedom of Information Act, show that the government expects currently the United Kingdom (UK) to breach health based air quality laws for nitrogen dioxide (NO2), a toxic gas, in London in 2010. These breaches are expected to continue each year thereafter up to, including and beyond 2015. These maps are attached to this Campaign update.

Simon Birkett, Principal Contact of CCAL, said:

“The United Kingdom (UK) is already on the receiving end of legal action from the European Commission (the Commission) for breaching legal standards for dangerous airborne particles (PM10) and missing the deadline to apply for a time extension to comply with them. This legal action must be broadened and escalated rapidly unless the UK comes up with a convincing plan to justify a time extension. ‘No time extension’ will be better than ‘a time extension with a weak plan’ because the former would, at least, leave the UK wide open to legal action to force the government to produce finally a credible plan to protect public health.

“The UK’s failure to tackle nitrogen dioxide (NO2), a toxic gas and an indicator of even worse pollutants, dwarfs its failures with dangerous airborne particles. For example, London has the worst annual average level of NO2 of any capital city in western – or eastern – Europe. In Brompton Road and Marylebone Road, current levels of NO2 exceed 95 micrograms per cubic metre (ug/m3) (i.e. over twice the World Health Organisation backed legal standard of 40 ug/m3 from January 2010). Over 100 UK cities breached in 2008 the level that will become the legal standard in 10 months time.

“It is astonishing that the government intends to spend the next 18 months to two years debating plans and programmes to include in a time extension application for NO2 – when it admits it already expects the UK to fail to meet at least one of the three requirements for such a time extension in London from January 2010 (i.e. Article 22(3) of the Directive on ambient air quality and cleaner air for Europe).

“Why is the government not working out now how the UK will become compliant with air quality laws for NO2 as quickly as possible after 1 January 2010? Legal compliance will require three things: the UK proving it has genuinely tried to achieve compliance by January 2010; a convincing plan to comply fully with limit values for NO2 by January 2015; and determined action to ensure average annual levels of NO2 stay below 60 ug/m3 (i.e. the limit value plus margin of tolerance) from January 2010. None of these is currently likely. In stark contrast, Germany, for example, is working hard to have inner low emission zones in place in some 40 cities by the end of 2009 to help it comply with the same health standards.

London needs: the Prime Minister to back a ‘green deal’ of major new measures; and the Mayor of London to promise to deliver upon it in a timely manner. London needs urgently one or more additional inner low emission zones and other measures, including incentives, to tackle harmful emissions at their source. Premature death and irreversible climate change are even worse fates than economic depression. Why can’t our political leaders wake up and tackle two problems at the same time?”

   more »

Note: The following letter was sent by The Knightsbridge Association not the Campaign for Clean Air in London: 3 January 2009

The Rt. Hon. Hilary Benn MP
Secretary of State
Department for Environment, Food and Rural Affairs
Nobel House
17 Smith Square
London SW1P 3JR

3 January 2009

By registered post and email: hilary.benn@defra.gsi.gov.uk

Dear Secretary of State

Near record air pollution in central London in 2008

Secretary of State for Defra has a legal duty to ensure health based limit values are attained and not exceeded once attained

The Knightsbridge Association asserts its right to require the government to develop an action plan to improve NO2 and PM10 air quality in the short term

The Knightsbridge Association presses the Secretary of State to direct Mayor Johnson not to remove or weaken the western extension of the Congestion Charging Zone unless a stronger inner Low Emission Zone is put in place simultaneously upon its removal

Summary

I am writing on behalf of The Knightsbridge Association (the KA) to urge you, as the relevant Secretary of State, to ensure that the United Kingdom (UK) complies in full with air quality laws in the wider Knightsbridge area of London (and elsewhere throughout the UK).

The KA is an amenity society registered with the Civic Trust. It represents around 1,000 residents and businesses in the wider Knightsbridge area bounded broadly by Hyde Park Corner in the east and Queen’s Gate in the west. Brompton Road, Cromwell Road and Knightsbridge pass through this area. Our website address is:

www.knightsbridgeassociation.org.uk.

For a map of the local area, please see:

http://www.multimap.com/maps/?qs=brompton+road&countryCode=GB#map=51.49919,-0.16453|16|4&bd=useful_information&loc=GB:51.49919:-0.16453:17|brompton%20road|Brompton%20Road%20(A4),%20London,%20England,%20SW7

The KA is concerned about serious breaches of air quality laws in this part of London (and elsewhere). Local air pollution levels in 2008 were close to record levels. Annual mean levels of nitrogen dioxide (NO2) were well over twice the maximum level recommended by the World Health Organisation (WHO) and peak levels occurred some 427 times compared to the WHO’s maximum recommended frequency of 18 times. The KA estimates that annual average levels of particulate matter (PM10) in this area exceeded 40 micrograms per cubic metre (ug/m3) and may have approached 50 ug/m3. The WHO has stated that there is no safe level for exposure to particulate matter. This situation is clearly unsustainable and unacceptable.

European Union (EU) air quality laws required annual average levels of PM10 air quality to attain 40 ug/m3 from 1 January 2005 and for that level not to be exceeded once attained. These laws were transposed into UK law in the Air Quality Standards Regulations 2007 (AQSR 2007). These Regulations impose inter alia a statutory duty on you, as the relevant Secretary of State, to develop action plans to improve air quality in the short term. This duty was reaffirmed and clarified recently in a preliminary Judgement by the European Court of Justice (ECJ). The KA is hereby notifying you that it respectfully requests and requires in respect of the wider Knightsbridge area that you as Secretary of State: (i) prepare and implement urgently an action plan that is capable of reducing to a minimum the risk that the limit values for NO2 and PM10 will be exceeded and of ensuring a gradual return to a level below those limit values; and (ii) at least maintain air quality (where limit values have already been met), and otherwise comply in full with relevant air quality laws. Please note that the requirement that limit values must not be exceeded once attained is an absolute legal requirement.

The KA is concerned further that decisions may be taken by the Mayor of London and/or others during 2009 or subsequently which would adversely and illegally impact air quality in this area e.g. the possible removal or weakening of the western extension of the Congestion Charging Zone (the WEZ). In the KA’s carefully considered view, such a decision would inter alia worsen air quality where it has attained limit values for PM10 and thereby breach air quality laws unless at least directly offsetting measures were put in place simultaneously upon its removal. These measures might include dynamic road pricing (such as ‘tag and beacon’) and/or one or more inner Low Emission Zones (which will be needed anyway to ensure that air quality laws are complied with cost effectively). Please therefore issue ‘directions’ as necessary to the Mayor of London and/or others to ensure that relevant air quality laws are complied with fully.

The KA hopes, if you respond positively and energetically to this letter in respect of the wider Knightsbridge area and/or London as a whole, that its actions may set a valuable precedent and encourage other community groups in London (and elsewhere) to seek improvements in local air quality and reductions in air pollution generally.   more »

CAMPAIGN RESPONSE: 27 September 2008

Boris Johnson
Mayor of London and Chair of Transport for London
Transport for London
Western Extension Consultation
12th Floor Windsor House
42-50 Victoria Street
London SW1H 0TL

Congestion Charging
Western Extension Consultation
Chiswick Gate
598 – 608 Chiswick High Road
London W4 5RT

By email: westernextension@tfl.gov.uk and mayor@london.gov.uk

Dear Mayor Johnson,

Consultation on the future of the Congestion Charge Western Extension (CCWE)

Keep the Congestion Charge Western Extension or an even tougher, additional, inner Low Emission Zone will be needed by early 2010

This response to Transport for London’s (TfL’s) public consultation on the future of the Congestion Charge Western Extension (CCWE), which is due to close on 5 October 2008, is sent on behalf of the Campaign for Clean Air in London (CCAL). See:

http://www.tfl.gov.uk/tfl/roadusers/congestioncharging/westernextension/default.aspx

In your letter to CCAL, dated 31 July 2008, you requested that CCAL submit a formal response to this consultation in September.

Summary

Government maps, recently published by CCAL, highlight yet again, that road transport is the biggest single cause of all breaches of air quality laws across London. The solutions needed involve two overlapping ‘circles’ of measures – one for congestion (since vehicles are about half as polluting once they reach speeds of 30 kilometres per hour) and the other for emissions (such as low emission zones) – that target the most polluting vehicles in the most polluted areas.

CCAL urges the Mayor of London (the Mayor) to keep the CCWE primarily on the grounds that traffic levels would rise significantly without it, leading to increased pollutants from vehicles. In CCAL’s view, it would be foolish of the Mayor to remove the CCWE when he would then need to toughen further additional measures, such as one or more additional inner low emission zones, that are already long overdue to reduce sharply hazardous vehicle emissions to comply with air quality laws in the same area of London.

CCAL urges the Mayor to pursue vigorously stronger measures to reduce congestion across London. Instead of weakening (or removing the CCWE), the Mayor should build on the current ‘blunt instrument’ by offering dynamic (or ‘intelligent’) road pricing, such as ‘tag and beacon’ or better, in parallel with the current CCWE and Congestion Charge Central (CCC). This would give people the choice of paying a fixed congestion charge or opting to pay a flexible charge i.e. such that they might pay nothing to drive short distances outside the hours of congestion. In due course, once dynamic road pricing is shown to work well, it should take over fully from the current ‘blunt’ scheme and be extended to operate, where necessary, across London.

CCAL is concerned that a relatively small number of vehicle owners, who are primarily responsible for congestion, are - at little or no cost to themselves - having a disproportionate, negative impact on the health of hundreds of thousands of Londoners. Those causing congestion should pay the full environmental cost of their actions as part of a much wider ‘polluter pays’ strategy in London. CCAL supports measures to reduce congestion, in their own right, as a means of increasing road capacity and improving quality of life for the vast majority of Londoners.

Last but most importantly, CCAL emphasises the need for the Mayor to work closely with the government to implement measures urgently to ensure that air quality laws are fully complied with throughout London not just in the CCWE area.

   more »

Campaign letter: 17 January 2008

London 2012: “Greenest Games ever” or “Most sustainable ever” breaches of air quality laws with EU and IOC legal action?

Government has no actions planned yet to comply with Nitrogen Dioxide (NO2) air quality laws in London by 2010, 2015 or 2020

Commitments received from the four main candidates for Mayor of London

The Campaign for Clean Air in London (CAiL) is writing to obtain a commitment now from the Government, on behalf of itself and the whole Olympic Family in the United Kingdom (the UK Olympic Family), in relation to the London 2012 Olympic Games and the London 2012 Paralympic Games (London 2012). The commitment is that they will take all necessary actions to ensure that London 2012 will, at an absolute minimum, comply sustainably and fully with the letter and spirit of all applicable UK and European Union (EU) air quality laws and the Host City Contract for London 2012.

CAiL also urges the Government to go further and make a commitment with regard to nitrogen dioxide (NO2). The commitment is to ensure that London 2012 meets the existing EU Limit Values for NO2, which are due (under the existing EU air quality directives) to be met by January 2010, by London 2012.

   more »