POLITICS HOME #1: 11 January 2012

‘Invisible’ air pollution: the biggest public health failing or ‘cover-up’ for decades

Air pollution is much worse than most of us have realised. It regularly exceeds twice World Health Organisation (WHO) guidelines and legal limits near our busiest roads in London and elsewhere. Only smoking causes more early deaths than air pollution in the UK.

In December 2009, ‘Clean Air in London' (CAL) accused the previous Government of one of the biggest public health failings or ‘cover-ups’ by a Government in modern history. Perhaps amazingly given the seriousness of the accusation, the Environmental Audit Committee (EAC) has twice since confirmed CAL’s findings. In CAL’s view, the current Government is still failing to warn people and may be misleading them with statistics such as: “air pollution has declined significantly in recent decades”; “air quality is good across 99% of the UK”; and “air pollution still reduces life expectancy by an average of six months”.

Let’s rewind. Ambient or outdoor air pollution comprises particles and gases. The particles, which can comprise anything from tiny droplets to diesel soot and tyre and brakewear, are called ‘particulate matter’ and classified by their aerodynamic diameter in microns (one-millionth of a metre (um) which is about one-hundredth of the thickness of a human hair) e.g. PM2.5 and PM10. The gases, which can coalesce and become particles, are mainly nitrogen dioxide (NO2), ozone (O3) and sulphur dioxide (SO2).

The WHO says there is little evidence to suggest a threshold below which no adverse health effects would be anticipated for particulate matter or, put another way, there is no safe level of human exposure to it. An ‘Update of WHO air quality guidelines’ (AQG) published in February 2008 said ‘The AQG have always addressed exposures and health effects of individual pollutants or indicators (such as PM10 mass, an indicator of a complex pollution mixture with multiple sources). However, as understanding of the complexity of the air pollution mixture has improved, the limitations of controlling air pollution and its risk through guidelines for single pollutants have become increasingly apparent. NO2 for example is a product of combustion processes and is generally found in the atmosphere in close association with other primary pollutants, including ultrafine particles. It is itself toxic and is a precursor of ozone, with which it coexists along with a number of other photochemically generated oxidants. Concentrations of NO2 are often strongly correlated with those of other toxic pollutants. Its concentration is readily measured but needs interpretation as a potential surrogate for a set of sources and the resulting mixture. Achieving guideline concentrations for individual pollutants, such as NO2, may therefore bring health benefits that exceed those anticipated on the basis of estimates of a single pollutant’s toxicity.’ NO2 is not just a molecule therefore as the Government would have us believe.

In the Great Smog of December 1952 there were 4,075 deaths in London due to short-term exposure to air pollution with more over the following months. The number was easy to calculate through time-series analysis i.e. the number of deaths peaked about two days after air pollution levels peaked (and didn’t fall into a trough thereafter). Epidemiologists say these people were ‘harvested’ – a disgusting word in this context.

The Committee on the Medical Effects of Air Pollutants (COMEAP) published a report in 1998 on the health impact of short-term exposure to PM10. COMEAP estimated a total of 8,100 deaths ‘brought forward’ due to PM10 annually among total deaths in urban Great Britain (GB) (based on 1995 and 1996 air pollution levels). The same COMEAP report referred to 3,500 deaths brought forward per year due to SO2 in urban areas of GB and between 700 and 12,500 deaths brought forward by O3 in both urban and rural GB during the summer only.

It was not until 1995 and 2000 that huge cohort studies (which followed a group of people over a period of time to determine the absolute risk of one or more health impacts) in cities in the United States with different annual mean concentrations of PM2.5 showed the health impact of long-term exposure to air pollution. The results derived from the American Cancer Society (ACS) (Pope et al, 1995) and the Health Effects Institute (HEI) reanalysis of the ACS study and the US Six-Cities Study (HEI, 2000), which were subsequently confirmed on other continents and within cities, estimated a range of coefficients (i.e. hazard rates or relative risks) from 1% to 9% for a 10 microgram per cubic metre (ug/m3) reduction in PM2.5.

COMEAP reported on these results in 2001 that ‘using the 1% coefficient, the effects of long-term exposure were about ten-fold greater, on a years-of-life-lost basis (i.e. in terms of average life-shortening), than the effects of short-term exposure’. Based on further scientific evidence, COMEAP in June 2009 recommended, as a best estimate for mortality in the UK, the higher risk coefficient of 6% change in risk of death from all causes with a 10 ug/m3 change in PM2.5 derived from the extension of the ACS study (Pope et al, 2002). Oversimplifying, for population weighted exposure of 10 ug/m3 anthropogenic (man-made) and non-anthropogenic PM2.5 in a city with 50,000 deaths in a given year, this equates to 3,000 attributable deaths in a year.

Mayor Johnson was the first politician to use COMEAP’s 2009 advice to publish in June 2010 estimates by ward of 4,267 deaths in London in 2008 attributable to long-term exposure to PM2.5. COMEAP lead the way nationally in December 2010 by estimating, using the language used for alcoholism, obesity and smoking, 29,000 deaths in the UK in 2008 attributable to long-term exposure to PM2.5 at an average loss of life for these people of about 11.5 years. COMEAP and the Mayor’s estimates were calculated after eliminating the effect of dozens of other possible risk factors (e.g. educational status as a surrogate for income and smoking) to produce a pure number assuming air pollution is the sole cause of those deaths. In CAL’s view, these estimates are much more meaningful to members of the public than ‘years of life lost’ or an ‘average loss of life of six months for everyone in the UK’.

The estimates of 4,267 and 29,000 extra or excess deaths are good ones for comparing the effects of air pollution with the effects of other causes such as alcohol, active or passive smoking, obesity, diet etc which are calculated in the same way. However, COMEAP has shown us that because, in practice, individuals experience multiple risks, including air pollution, almost certainly air pollution played some part in shortening the life of a much larger number of individuals. It is not possible to estimate that number reliably but, given that much of the impact of air pollution on mortality is linked to cardiovascular deaths, it is more reasonable to consider that air pollution may have contributed to all 200,000 deaths due to cardiovascular causes in the UK in 2008 (i.e. one in three of all deaths) at an average additional loss of life for these people of about two years (at typical ages for cardiovascular deaths e.g. 15% of which are before age 65).

Combining therefore the short and long-term impacts of different pollutants suggests a range of between 29,000 and 53,100 nationally if there is no overlap or 100% overlap between the health effects. For the first time, we can compare easily the health impact of long-term exposure to PM2.5 with the Government’s estimates for the number of premature deaths attributable to alcoholism (15,000 to 20,000 in England; average men 20 years, women 15 years), obesity (9,000 in England; average nine years) and smoking (87,000 in England; average 10 years) and understand the complexities of these metrics. There were 2,222 deaths from road traffic accidents in GB in 2009.

The health impact of air pollution is not just about mortality; it is also about morbidity i.e. illness. Separate scientific research published by the Aphekom group of scientists in 2011 has shown that those living near roads travelled by 10,000 or more vehicles per day on average could be responsible for some 15-30 per cent of all new cases of asthma in children; and of COPD (chronic obstructive pulmonary disease) and CHD (coronary heart disease) in adults 65 years of age and older. The same study further estimated that, on average for all 10 cities studied, 15-30 per cent of exacerbations of asthma in children, acute worsening of COPD and acute CHD problems are attributable to air pollution. This burden is substantially larger than previous estimates of exacerbations of chronic diseases, since it has been ignored so far that air pollution may cause the underlying disease as well. Related research indicates that associations of asthma with traffic-related pollution from nearby sources at schools were independent of estimated effects of exposures at homes. A Freedom of Information request to Transport for London by CAL has found 1,148 schools in London within 150 metres of roads carrying over 10,000 vehicles per day and a total of 2,270 within 400 metres of such roads.

Nor is the health impact of air pollution spread evenly across the population. The EAC said “Preliminary results for England indicate that poor air quality is associated with areas of low income, low employment and lower education attainment, with differences in exposure to air pollution between different ethnic groups”. CAL which saw these results, from work done by Imperial College’s highly respected Small Area Health Statistics Unit (SASHU), presented at the International Society for Environmental Epidemiology (ISEE) conference in Barcelona on 16 September 2011 recollects that the worst effected groups were exposed to up to 50% more NO2 than those least effected i.e. the health inequalities linked to combustion related air pollutants are up to twice those for PM10. The research presented in Barcelona was titled “Associations between small area levels of air pollution and socio-economic characteristics in the Netherlands and England”. A detailed report for Defra in 2006 showed that inequalities are greater in areas with poorest air quality. CAL has analysed marginal Parliamentary constituencies and zones breaching NO2 limit values.

In conclusion, it is fair to point out there were as many early deaths in London in 2008 due to long-term exposure to PM2.5 as we thought occurred during the Great Smog of 1952 (due to short-term exposure to air pollution when we knew nothing of the long-term effects). Put another way: knowing that there were 4,000 early deaths in the Great Smog of 1952 was enough to ‘change the world’; but knowing there were 4,000 early deaths in London in 2008 is now considered by some ‘room for improvement’.

We must not let this ‘invisible’ public health crisis be ignored any longer. Just because air pollution was visible in 1952 and the effects short-term, does not excuse ignoring the invisible, long-term effects now. Who knows what further health risks the scientists will identify 10 years from now? Officials should stop saying they’re worried about alarming people about the dangers of air pollution and start warning them. It is a disgrace, for example, that it is much harder to find a list of cities and towns in the UK where NO2 diffusion tube data shows legal limits are breached than it was three or four years ago. The Government should also be warning people that indoor air quality can be worse than outdoor and revising advice from 1998 on ‘tunnel dust’ in the London Underground.

The solutions are simple . The Government should accept immediately and in full the recommendations of the two EAC reports. In particular, it should implement a massive campaign on the scale of those for alcoholism and smoking to building public understanding of the dangers of air pollution with advice for people on protecting themselves and reducing pollution for themselves and others. Some 90% of people at a conference on air quality in 2010 said they wanted to see an estimate for their local authority of the number of deaths attributable to long-term exposure to PM2.5 with advice on the careful interpretation of the information.

It’s time for change. London and the UK should be leading the world in the Olympic year in tackling air pollution as we did after the Great Smog of 1952.

This is the first in a series of six articles being written for Politics Home by Simon Birkett, Founder and Director of Clean Air in London, about air quality in the lead up to the London 2012 Olympics. Other topics are expected to include: legal issues; sources and solutions; Mayoral manifestos; indoor air quality; and the Olympics.


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Autumn 2011 update by Clean Air in London

THIS ARTICLE MAY BE REPRODUCED IN FULL WITH THE PRIOR WRITTEN PERMISSION OF CLEAN AIR IN LONDON

WORKING DRAFT 180911

The worst public health crisis since the Great Smog of 1952

Air pollution is rocketing up the public, media and political agenda in London and more widely. By Easter this year, London had already breached the number of ‘Bad Air Days’ for dangerous airborne particles allowed for a whole year. The standard has been in legislation since 1999 and required to be met since January 2005.

The Mayor is correct to say – when comparing the public health risk with alcoholism, obesity and smoking – there were 4,267 deaths in London in 2008 attributable to long term exposure to fine particles at an average additional loss of life of 11.5 years. However, Clean Air in London (CAL) has found that this is a pure number, calculated after eliminating up to 40 other possible causes of death. It is more likely, in practice, air pollution may have contributed to all 15,800 deaths due to cardiovascular causes (i.e. one in three of all deaths) in London [in 2009] at an average additional loss of life of around three years for these people. Either way, this is as many early deaths as we thought occurred due to short-term exposure during the Great Smog of 1952 (when the impacts of long-term exposure were unknown).

It is not just older people though who are at risk. Earlier this year, CAL published a list – obtained under the Freedom of Information Act – of 1,148 schools and other educational places within 150 metres of roads carrying over 10,000 vehicles a day after discovering new scientific research that traffic-related air pollution from such roads could be responsible for up to 30% of all new cases of asthma in children. This is a public health crisis and far too little is being done to tackle it.

A recent survey by a group of green non-governmental organisations on actions to improve air quality in 17 European cities ranked London ‘Below Average’ and gave it an ‘F’ largely because of the Mayor’s backward steps on key air quality measures over more than three years. These have included: the scrapping of six monthly checks on taxi emissions (which are being reinstated next year); the removal of the western extension of the congestion charging zone; and the delay from October 2010 to January 2012 of Phase 3 of the low emission zone which was due to protect some 15% of those worst affected by air pollution. Amongst other things, the Mayor has been severely criticised for his use of ‘dust suppressants’ which mask air pollution in front of monitoring stations to avoid legal fines.

The planned Olympic and Paralympic Route Networks (ORN and PRN) pose serious congestion and air quality problems of their own. They seem designed to trap people in local streets or force everyone down one lane, or two if you are lucky, alongside the ORN or PRN with all the buses and taxis. The organisers need to reduce background or ‘non-Games’ traffic by some 30% to make this system work. The traditional solution involves the ‘Big Scare’ tactic which would play mind-games with Londoners to discourage them from driving or working in London even if there is no traffic problem. Beijing chose instead a last minute ‘odd and even’ number plate ban. Seeking something better, CAL has proposed a Berlin-style zone which would ban the oldest diesel vehicles from the most polluted parts of London for the required 100 days in 2012 with a smaller zone to remain as a legacy. CAL has told Transport for London it considers the current plans to be unlawful.

Not surprisingly, the legal pressures are building on the Government and the Mayor. After two failed attempts, the Government obtained finally from the European Commission in June a time extension until 2011 to comply with legal standards for dangerous airborne particles. No further time extension is allowed so the UK faces fines of up to £300 million per annum if the problems of this year are repeated in 2012 or thereafter.

The Government can apply similarly for a time extension from January 2010 to January 2015 to comply with legal standards for nitrogen dioxide (so called NO2). London has the highest annual mean concentrations of NO2 of all 27 European capital cities with pollution over twice the legal limit and World Health Organisation guideline near our busiest streets. Incredibly, the so-called ‘greenest Government ever’ is saying it can’t (or more likely won’t) comply with this legal standard in London until 2025. This raises the prospect of infraction action from the European Commission in the months leading up to the London 2012 Olympics and unlimited lump sum and daily fines in due course.

This Autumn will also see two ground-breaking legal cases on air quality reach the Courts. ClientEarth has won the right to seek a judicial review of the Government’s failure to produce proper action plans to comply with legal standards. In late November, CAL and Defra are due in the Court of Appeal in a Freedom of Information case. Separately, in a campaigning win for CAL, the new London Plan which sets the legal framework for development in London says “Development should…be at least ‘air quality neutral’ and not lead to further deterioration of existing poor air quality”. Together with other strict requirements, the new London Plan should restrict major developments unless harmful traffic emissions are reduced.

Parliament’s Environmental Audit Committee is also concerned about the lack of action to tackle air pollution in the UK. It launched a second inquiry this year into air quality after finding that the new Government had made no significant progress in response to its hard-hitting report published in March 2010. With political pressure building in City Hall, Westminster and Brussels, poor air quality looks set to be a Top 5 issue for the Mayoral elections in 2012. Among other things, CAL’s manifesto for Mayoral candidates will include a call for a major campaign to build public understanding of the dangers of air pollution with advice for people on protecting themselves and reducing pollution for themselves and others.

Finally, in an exciting new development, Camfil Farr – a world leader in air filters for buildings – has become CAL’s first Gold Sponsor and backed a campaign, initially in London, to build public understanding of the dangers of poor indoor air quality which can be worse than outdoor or so-called ambient air pollution.

Let’s encourage the Mayor and the Government to act urgently and boldly. If they do, the Olympic city could show the world next year how air pollution and wider sustainability issues can be tackled successfully through a mixture of political will, technology and behavioural change.

For more information please follow www.twitter.com/CleanAirLondon or see ‘Take 10 steps for Clean Air in London’ on www.cleanairinlondon.org.

By Simon Birkett, Founder and Director, Clean Air in London
© Clean Air in London and Simon Birkett 2011


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CAMPAIGN UPDATE: 12 December 2010

An introduction to poor air quality in London

By Simon Birkett, Founder and Director of Clean Air in London

Clean Air in London is a company limited by guarantee that is responsible for the Campaign for Clean Air in London. For contact details or more please visit www.cleanairinlondon.org

‘Unlimited and free access to clean air of an acceptable quality is a fundamental human necessity and right’ and ‘an unequal distribution of health risks over the population raises concerns of environmental justice and equity’

Source: “Health aspects of Air Pollution” published by WHO Europe, June 2004.

Introduction

Clean Air in London’s (CAL’s) mission is to achieve urgently and sustainably at least World Health Organisation (WHO) recommended standards of air quality throughout London. CAL's immediate priority is to see health-based air quality laws complied with in full each year up to the London 2012 Olympics (and thereafter).

Air pollution in London

Air pollution in London is much worse than most of us have realised. It averages well over twice legal limits and WHO guidelines near our busiest streets.

There are three main pollutants in ambient air: particulate matter (for example very fine particles from dust, tyre and brake wear and black smoke from vehicles), nitrogen dioxide (NO2) and street level or tropospheric ozone (O3). Sulphur dioxide (SO2) is no longer seen as a health risk in London. PM is classified by diameter as ultrafine (PM1.0), fine (PM2.5), coarse (PM2.5-10) and PM10 (with the last, for example, including particles up to 10 microns in diameter). The finest is thought to be the most deadly since it travels furthest into the bloodstream and the body.

WHO guidelines typically include short-term mean (hourly for NO2 and daily for PM10) and long-term (annual mean) exposure levels to protect human health. There is no safe level for PM. In the calendar year up to 10 December 2010, annual mean and hourly peak concentrations of NO2 in Brompton Road, Kings Road and Marylebone Road were: 83 (micrograms per cubic metre or ug/m3) and 202 exceedances; 87 ug/m3 and 44 exceedances; and 98 ug/m3 and 539 exceedances respectively compared to the annual and hourly legal limits of 40 ug/m3 and 18 exceedances respectively. European Union (EU) legal limits are based on WHO guidelines.

Evidence from the summer smogs of 2003 and 2006 suggests that air quality will deteriorate as climate change causes warming unless additional mitigation action is taken that anticipates this rising trend.

Does it matter that air pollution in London is this bad?

Definitely, yes. CAL showed the previous government was responsible for one of the biggest public health failings or ‘cover-ups’ by a government in modern history.

For years we had been told there were 1,031 premature deaths due to air pollution in London in 2005 and some 12,000 to 24,000 per annum nationally. Research showed these estimates related to short-term exposure with the former due to PM10 and the range comprising 8,100 from PM10, 3,500 from SO2 and 700 to 12,500 from O3.

It was very odd though that the United States’ Environmental Protection Agency and others had published estimates attributable to long-term exposure while the UK had not. With much help, CAL calculated there were 3,460 such deaths in London and 35,000 nationally in 2005.

Parliament’s Environmental Audit Committee accepted these estimates saying: ‘Air quality must be given a higher priority for government. Defra must raise the profile of the issue by publicising the latest data on premature deaths more widely and making clear the benefits of improving air quality’. The Mayor of London subsequently published an estimate of 4,267 premature deaths in London in 2008 attributable to long-term exposure to PM2.5 and the new government has confirmed that the national calculations are correct.

To put the above numbers in context, compare them with the number of people who died in London in the same period from road traffic accidents (i.e. 230) and the 617 people annually who are estimated to have died prematurely from workplace related passive smoking nationally before relevant legislation came into force. Each person dying prematurely due to poor air quality in London may do so up to nine years early (or worse).

During London’s summer smog episode in August 2003 there were a total of between 46 and 212 premature deaths from O3 and 85 from PM10. London’s summer smog episode in July 2006 was likely to have resulted in a similar or greater number of premature deaths from O3 and a slightly lower number for PM10. These numbers should be of great concern to those planning for the Olympic Games and Paralympic Games in 2012.

In summary, air pollution has been linked to cardiovascular and cardiopulmonary events as well as asthma, cancers and other health effects. Increasing obesity may make people more vulnerable to air pollution. The young and old are most vulnerable to poor air quality.

What causes bad air pollution?

The Mayor of London has said that road transport was responsible for 79% of PM10 emissions in central London and around 80% of PM2.5 emissions in London as a whole in 2008 and 41% of emissions of oxides of nitrogen (NOx) in London as a whole in 2008.

Emissions from diesel engines are a particular problem. Empirical evidence published by the government suggests that, like for like, diesel engines for passenger cars may produce 17 times as much particulate matter and 83% more NOx emissions than petrol cars for a carbon dioxide (CO2) reduction of 4% or less. Diesel vehicles with pre-Euro 1 engines may produce more than five times as much particulate matter as diesel vehicles with Euro 4 engines.

The other main sources of harmful emissions include power stations, domestic natural gas, quarrying, construction and (outside London) agriculture. The proliferation of festival bonfires has also recently been recognised as a cause of more frequent air quality problems.

What are the likely solutions?

We need mitigation and adaptation to tackle air pollution whether poor air quality or climate change related. Mitigation means walking or cycling or using public transport rather than driving (particularly diesel vehicles) where possible to reduce air pollution for yourself and others. Adaptation includes walking or cycling down side streets rather than busy arterial roads.

Solutions split into two main categories:

• Non-traffic measures – such as complying with the Best Practice Guidance on Demolition and Construction published jointly by the London Boroughs and the Mayor of London. Other measures needed include action to control the impact of biomass burning and micro-generation and the proliferation of festival bonfires; and

• Traffic related measures – which can be split further into: Fewer and Smaller vehicles; and Cleaner vehicles. It is simplest to consider two overlapping circles: one for measures to reduce congestion and one to reduce harmful emissions.

Measures to reduce congestion include congestion charging and those to reduce harmful emissions include low emission zones (LEZs). The former can reduce emissions since vehicles travelling at 20 mph are roughly half as polluting as those travelling at 5 mph. The latter can reduce congestion by excluding some vehicles. Germany, for example, had some 40 inner city LEZ’s in place by the end of 2009 with Berlin saying its LEZ has been the single most successful measure to improve air quality in the city. Measures to promote walking, cycling and the use of public transport clearly reduce both congestion and emissions.

CAL considers key solutions for London should include: the abatement of harmful emissions from buses and taxis; a Berlin style LEZ in inner London and around Heathrow; a boiler scrappage scheme; and a massive campaign to build public understanding of the dangers of poor air quality with advice on mitigation and adaptation. CAL is concerned that the Mayor’s focus on buying new buses now (even hybrid) may distract from the need to comply (cheaply) with air quality laws in the short-term (e.g. through the fitting of selective catalytic reduction devices to 80% of London's 8,500 buses) and put infrastructure in place for a sustainable long-term solution (e.g. electric vehicles).

It is clear that successive governments have continued to hope for some ‘silver bullet’ to solve air quality problems (e.g. technology solutions such as tighter emission standards for vehicles) while it is clear the cheapest and most successful solutions will require bold political action and behavioural change.

Does the law protect us against poor air quality?

Yes. Since 1999, EU legislation has required the UK, as a Member State, to achieve annual mean and daily limit values for PM10 (by 1 January 2005) and annual mean and hourly limit values for NO2 (by 1 January 2010). These standards are based on WHO guidelines for human exposure to air pollution. While objectives are set by the EU, there are no limit values for O3 since it is considered to be a transboundary problem (although there are other obligations for O3 e.g. on health warnings).

Limit values for PM10 have been breached in London every year since they entered into force. The government has reapplied to the European Commission for a time extension until 2011 to comply with these standards in London having had its previous application rejected in December 2009. [It is expecting to hear within weeks.]

The NO2 hourly limit value for a whole year was breached in January 2010 and the annual mean for 2010 is certain to be breached by a large margin. The government says it plans to apply for a time extension until January 2015 to comply with the NO2 limit values in September 2011. Even if it is successful, the government must ensure that annual mean concentrations of NO2 are not exceeded by more than a maximum margin of tolerance of 50% from 1 January 2010 (i.e. 60 ug/m3).

Next steps

The scale and urgency of the challenge requires radical and urgent action to reduce air pollution. But if we succeed, we will show the world (and London) how to tackle air pollution and sustainability issues more widely. Let's do it!

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THE FOLLOWING ARTICLE MAY BE REPRODUCED IN ITS ENTIRETY, APPROPRIATELY CREDITED, IF PRIOR PERMISSION IS OBTAINED FROM THE CAMPAIGN FOR CLEAN AIR IN LONDON - PLEASE CONTACT US IF YOU WISH TO DO SO.

Simon Birkett: ‘We’re choking to death while the government dithers’

New air quality laws require one-third less air pollution in London within 18 months

Live in a big city and you risk suffering from fumes, breathing difficulties, even premature death. Yet the government has spent 10 years in denial about the United Kingdom’s (UK’s) air quality problems. The rest of us know differently and action is long overdue.

For change to happen, UK citizens look set to have to rely on the European Union’s (EU’s) legal framework that first put legal force behind World Health Organisation (WHO) guidelines for air quality in 1999. That framework was updated on 11 June 2008 when a new EU directive on ambient air quality and cleaner air for Europe entered into force (the new AQ Directive). Now we need that directive to be translated into action.

Environmental, social and economic cases for action

Poor air quality has serious implications for public health resulting in between 12,000 and 24,000 premature deaths each year in the UK – those with asthma, lung diseases and heart conditions, particularly the very young and the old, are most susceptible. These numbers compare with some 617 such deaths per annum from workplace-related passive smoking before recent legislation came into force and up to 22,000 premature deaths per year related to alcohol consumption. The Rogers Review in 2006 stated that, in 2005, the UK’s annual cost of health impacts from one form of air pollution alone, called particulate matter (or PM10), was between £9.1 billion and £21 billion per annum. Aside from the terrible human cost, the economic case for action was made in the government’s own Air Quality Strategy in 2007 when it stated that ‘policies in the road transport sector and electricity sector have been shown to be very cost beneficial with benefits estimated to have exceeded costs by up to a factor of 24’.

This public health crisis is not surprising when air pollution near our busiest streets is so bad. During 2007 in London, for example, the average annual concentrations of a toxic gas called nitrogen dioxide (NO2) in Marylebone Road, Kings Road and Brompton Road were 102, 91 and 94 micrograms per cubic metre (ug/m3) respectively (and they have started five to 10% higher in 2008). These measurements compare with the WHO’s guideline, set in 2000 and re-confirmed in 2005, and backed by EU law, of a maximum average annual concentration of 40 ug/m3. The air we are breathing in hardly bears thinking about.

Article 22

Nearly 10 years on, the government has failed to deliver WHO recommended standards of air quality throughout the UK. Fortunately, Article 22 in the new AQ Directive provides, amongst other things, that the UK cannot get a time extension from meeting its legal obligations for NO2 by January 2010 unless it ensures that average annual concentrations of NO2 remain below 60 ug/m3 across the UK thereafter. This means that air pollution near London’s busiest streets, for example, must be reduced by more than one-third in just over 18 months.

One result of Article 22 is that it could stop the Heathrow expansion in its tracks. This issue should also concern London Mayor Boris Johnson as he reconsiders the western extension to the Congestion Charging Zone. Then there are the London Olympics in 2012. The organisers would face a public relations disaster if the European Court of Justice took enforcement action against the UK for breaching Article 22 in the months leading up to the Games. The legal obligations rest on the UK as a Member State.

At the Campaign for Clean Air in London (CAiL), we are confident that the European Commission will take robust, early enforcement action against the UK for three reasons. First, without it, the EU’s broader air pollution strategy, including its post-Kyoto climate change negotiations, will be a ‘laughing stock’. Second, with the new AQ Directive being a hard-fought compromise between those who wanted to achieve all the WHO’s standards for air quality and those who wanted delay and greater flexibility, it would be unthinkable for the European Commission to fall at its first enforcement hurdle. Third, the UK (and London in particular) can be singled out for the scale of its NO2 breaches. Enforcement action could take place this year or early in 2009 in respect of PM10 breaches.

Problems and solutions

The government has admitted that road transport is the cause of all breaches of air quality laws in the UK with diesel emissions being by far the biggest single component. The solutions involve two overlapping ‘circles’ of measures – one for congestion and the other for emissions - that target the most polluted areas with technology-based solutions and create a ‘tipping point’ of behavioural change backed by awareness, persuasion, incentives and regulation (when necessary). In one ‘circle’, road pricing is essential, fair and much needed in areas like central and west London, to tackle congestion and ‘make the polluters pay’ since vehicles produce less than half as much air pollution once their speed reaches 30 kilometres per hour. It should operate seven days per week. In the other ‘circle’, we need an additional, inner, Low Emission Zone (LEZ) at least in central and west London to reduce harmful emissions. It will join dozens of others around Europe which target the most polluted areas of large cities. Unless the government sets, belatedly and soon, national standards for the abatement of emissions of oxides of nitrogen from older diesel vehicles of all the main types, these vehicles must be banned soon by LEZs from the UK’s most polluted streets.

After nearly 10 years, the government must take action

There are clear environmental, social and economic cases for improving the UK’s air quality quickly. Despite this, the government has shown itself incapable, over 10 years, of mustering even the political will needed to meet its environmental obligations. It has listened to the same siren voices that argued against the creation and enforcement of the Clean Air Act introduced in 1956. We need a new approach urgently from the government and Mayor Johnson that will give stakeholders of all types, whether from business, the non-governmental sector or citizens generally, the certainty and time necessary to play their full part in delivering the required changes in the most cost effective manner. Failing that, we shall have to urge the European Commission to take robust action to defend WHO-based air quality laws.

Simon Birkett is the Principal Contact for the Campaign for Clean Air in London

This article is based on an opinion piece by Simon Birkett that was published in The Independent newspaper on 4 July 2008

http://www.independent.co.uk/opinion/commentators/simon-birkett-were-choking-to-death-while-the-government-dithers-859954.html   more »

Working draft as at 20 April 2008

An introduction to Air Quality issues in London

‘Unlimited and free access to clean air of an acceptable quality is a fundamental human necessity and right’ and ‘an unequal distribution of health risks over the population raises concerns of environmental justice and equity’

“Health aspects of Air Pollution” Published by WHO Europe, June 2004. See http://www.euro.who.int/document/E83080.pdf

What is the Campaign for Clean Air in London?

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

CAiL is supported by leading politicians of all the four main political parties in London, including Sian Berry and Ken Livingstone, as well as all the amenity societies in Central London and leading business groups including the Central London Partnership, London First and The Knightsbridge Business Group. It has also received a pledge of support from Environmental Protection UK (formerly the National Society for Clean Air). CAiL operates under the auspices of The Knightsbridge Association (www.knightsbridgeassociation.org.uk).

With such broad support, we do not always all agree on everything but we do all agree that we must achieve urgently ‘Clean Air in London’.

Next steps

Radical environmental action is needed urgently since just one of the many obligations of the new Air Quality Directive will require the UK to achieve air quality standards for PM10 throughout London, by mid-2011 at the latest, that were breached, in London, in each of 2005, 2006 and 2007. In the very broadest terms, air pollution near London’s busiest roads must be halved before the 2012 Olympic and Paralympic Games.

We need measures that: are ambitious and anticipate the adverse impact of climate change on air pollution generally; make full use of available technologies; are cost conscious while still focussing on the need to meet legally binding deadlines; and will be implemented in a timely manner that will also give as much notice as possible of the changes coming to those affected.

The new AQ Directive establishes a clear framework for the meeting of air quality obligations. The time extension process for PM10, and for NO2 in due course, will provide almost annual tests in the next few years of the resolve of the European Commission and the UK Government in respect of air quality and air pollution.

London’s political leaders should engage fully and constructively in this process. Given the sheer scale of policy measures that will need be implemented in the next term of office, they should set out all the key policies they would pursue to ensure that air quality laws will be complied with throughout London by the deadlines known now. London’s political leaders should do this before the elections so the electorate can make informed decisions on 1 May 2008.   more »