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COMMENT ON UK’s APPLICATION TO DELAY COMPLIANCE WITH AIR QUALITY STANDARDS

By email to: airinfo@ec.europa.eu

Dear Sir/Madam

I am writing to urge the European Commission to reject the United Kingdom’s application for a delay to comply with legal standards for dangerous airborne particles (so called PM10) in London. As you know, the level of these particles in London has risen by around 0.4 % per year since the late 1990s.

Mayor Johnson’s recently published draft Air Quality Strategy (AQS) is a start but not yet ‘fit for purpose’. It confirms that neither he nor the UK government has a credible plan to comply with air quality laws in London.

After identifying road transport as being responsible for 83% of PM10 emissions in central London, the Mayor’s draft AQS goes on to say he will tackle this huge problem by delaying or cancelling key transport measures (notably Phase 3 of the low emission zone and the western extension of the congestion charging zone) and omitting others (such as one or more additional inner low emission zones). Many proposals to improve air quality are unfunded and therefore little more than aspirational.

We need the European Commission please to trigger the decisive action needed in the UK to improve air quality in London. No reply to this email is needed or expected.

Yours faithfully

[YOUR NAME]

ENDS



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

‘Many proposals’ in Mayor’s draft Air Quality Strategy are unfunded as he calls on government to fully back his plan with adequate policy and financial support

Mayor Johnson ‘torpedoes’ government’s time extension plans for dangerous airborne particles (PM10) by delaying Phase 3 of the London Low Emission Zone


Mayor Johnson announces his draft Air Quality Strategy

Mayor Johnson announced his draft Air Quality Strategy, ‘Clearing the Air’, on 5 October for consultation with the London Assembly and Greater London Authority (GLA) functional bodies. See media release (with a link to the 86 page document):

http://www.london.gov.uk/view_press_release.jsp?releaseid=23879

The consultation period will run until 30 November. In early 2010 a second version of the strategy will be published for formal public consultation.

Quotes

Simon Birkett, Founder and Principal Contact of the Campaign for Clean Air in London (CCAL), said:

The challenge

“The Mayor’s acknowledgment of the seriousness of London's air quality problem and that it has not improved in recent years is welcome. In fact, the level of dangerous airborne particles (so called PM10) in London has increased at a mean rate of around 0.4% per year since the late 1990s (Note 1).

“The scale of the nitrogen dioxide (NO2) challenge dwarfs that for PM10. Even the government’s own forecasts indicate 1,117 kilometres of roads in London will breach legal standards in 2010 with 520 kilometres still in breach in 2015 (the final date for compliance if a time extension is obtained for NO2) (Note 2). The Mayor estimates some 700,000 Londoners live in areas expected to breach legal standards for NO2 in 2010.

“To put London's air quality challenge in perspective, let's remember: legal action is already underway against the UK for breaching legal standards for PM10 (Note 3); London has the highest annual average concentrations of NO2, a toxic gas, of any capital city in western (or eastern) Europe (Note 4); and some 6,300 to 7,900 people may have died prematurely in London in 2005 due to exposure to PM10 alone (Note 5).”

“The human cost of failing to improve air quality is frightening.”

The proposals

“Some encouraging new measures are included in the Mayor's draft Air Quality Strategy (AQS). For example, plans to start cleaning up the bus and taxi fleets and launch a public information campaign.

“However, some thinking does not seem to stack up. For example, the draft AQS says road transport produced 83% of PM10 emissions in central London in 2006 (page 26). The draft AQS suggests that this huge problem can be dismissed as just ‘a few hotspots’ (page 40) and tackled (page 39) by:

• planting street vegetation;

• introducing unspecified, untested and unfunded ad hoc local traffic management measures;

• focusing an unspecified number of cleaner buses down the most polluted roads at some time in the future, where possible; and, meanwhile,

• delaying or cancelling the two biggest measures already in train i.e. Phase 3 of the London low emission zone (LEZ) and the western extension (Note 6) of the congestion charging zone (WEZ).

“CCAL is concerned also that the draft AQS seems to have focused mainly on emissions of oxides of nitrogen (NOx) and assumed (apparently) that concentrations of nitrogen dioxide (NO2) will fall at the same rate as NOx. History suggests otherwise.”

Three key issues

“There are three key issues, at least, around the AQS:

• first, the Mayor's decision to delay Phase 3 of the London low emission zone from October 2010 to 2012. This decision will impact over 15% of those worst affected by poor air quality (Note 7);

• second, ‘many of the proposals’ included in the AQS are unfunded (see page 80 of the draft AQS) i.e. they are aspirational; and

• there is still no credible plan for London to comply with legal standards for PM10 by the June 2011 deadline since most measures (even if funded) would not be implemented until 2012. Ad hoc and minor measures and ‘pre-compliance’ (i.e. the early purchase of LEZ compliant vehicles for Phase 3, in contrast to the experience of earlier Phases) would be relied upon as London ‘seeks to meet’ these legal standards in 2011.

“The first of these is sure also to torpedo the government's application to the European Commission for a time extension until June 2011 to comply with legal standards for PM10 (since you cannot substitute uncertain measures for certain ones) (Note 8).

“It is also very disappointing that air quality laws, in place to protect public health, seem unlikely to be complied with in London in any year up to or including 2012 (or thereafter) Note 9. The AQS says emissions of oxides of nitrogen (NOx) need to be over 80% lower in 2015 than current projections in order for the EU limit value to be met everywhere in London (page 25). It then goes on to show that the current (mainly unfunded) proposals would achieve reductions of only 34 to 40% by 2015 (page 78).”

“CCAL has therefore written to Commissioner Dimas urging him to reject the UK’s application for a time extension to comply with EU limit values for dangerous airborne particles. If the UK continues to fail to take effective action during the enforcement process, it would eventually face unlimited lump sum and daily fines Note 10.”

Next steps

“Boris has lobbed – though, for now - the ‘air quality’ ball into the government’s court. Not least, he says “The GLA’s modeling shows that even with strong action by the Mayor, London cannot clean up its air on its own” (page 16). Therefore:

• will the government finally disclose the contents of its discussions with the Mayor on air quality?;

• how will the government close the gaping hole between the (latest) plans for London and the legal standards to be met by specific deadlines?;

• will it offer the Mayor all the financial support he has called for and/or issue him with legal directions?;

• can it somehow salvage, within weeks, its time extension application for PM10?; and

• what will the government do to fix the shambles it has created nationally on NO2?

“The bottom line for the Mayor and the government is that this strategy needs to tackle a problem estimated to have resulted in 6,300 to 7,900 premature deaths in London in 2005 due to dangerous airborne particles alone – and it does not.”

“Air quality looks set, at last, to become a major election issue. It’s about time.”
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