Campaign letters: 11 June 2007

Government comments on Air Quality legal breaches

Commenting on a letter sent on behalf of David Miliband, the Secretary of State for Environment, Food and Rural Affairs, replying to a recent submission on the Draft Climate Change Bill and other matters, Simon Birkett, Principal Contact for the cross-party Campaign for Clean Air in London, said:

“While we welcome tough action by the Government in the forthcoming Climate Change Bill, it is becoming increasingly untenable for the Government to treat this aspect of Air Pollution in isolation from Air Quality against a tidal wave of contrary advice from some of the world’s leading organisations and individuals.

“As the consultation period on the Draft Climate Change Bill closes, the Government is saying it recognises the need to treat Air Pollution holistically. Its actions now need to support its words.

Key questions include:

“First, will the Climate Change Bill now include a simple mechanism, as we have proposed, to protect Air Quality? Otherwise, policy may, for example, favour diesel engines because they produce up to 17% less carbon dioxide but over 65% more each of the hazardous nitrogen oxides and particulate matter than petrol engines.

Sir Nicholas Stern, the Intergovernmental Panel on Climate Change and the Air Quality Expert Group, sponsored by the Department for Environment, Food and Rural Affairs (Defra), have all highlighted the substantial benefits to be achieved by treating these two policy areas together. Even Defra’s own, soon to be published, revised UK Air Quality Strategy is expected to do the same.

“Second, will the Government please now commit to annual budgets in the same way that it wants annual carbon reporting from others?

“Third, what practical help is the Government giving to London to ensure that it meets urgently European Union legal limits for air quality (particulate matter or PM10) that were breached in 2005 (and 2006 and probably already in 2007)? When will these legally binding limits be achieved given that no derogations are allowed?

“Fourth, will the Government please confirm that environmental justice gives everyone the basic human right of free access to clean air of an acceptable quality?

“Fifth, will the Government please fight to ensure that there are no “knock-on” delays to the timing of benefits for citizens if the new European Union Air Quality Directive, now scheduled for a second reading on 13 December 2007, is not actually implemented until 2008 or 2009? Otherwise, protections that had been planned since 2005 could slip several years.”

Please note that replies have not been received yet to campaign letters sent to the Prime Minister, dated 23 December, inviting him to Pledge support to the Campaign for Clean Air in London or David Miliband, dated 12 November, asking further tough questions about the forthcoming National Air Quality Strategy. Responses to other correspondence have been posted on our website.

Simon Birkett
Principal Contact

Please contact Simon through the Campaign homepage.

TEXT OF LETTER RECEIVED ON DEFRA LETTERHEAD

CCU 6th Floor
Nobel House
17 Smith Square
London
SW1A 3JR

Email: ccu.correspondence@defra.gsi.gov.uk

11 June 2007

Dear Mr Birkett

AIR QUALITY & THE CLIMATE CHANGE BILL

Thank you for your email of 13 May to David Miliband regarding the need to treat air pollution holistically in the context of the Climate Change Bill, as well as the more specific air quality issues that you raise. I have been asked to reply.

With regard to the interface between climate change and air quality, we have emphasised in previous correspondence that the UK Government is fully committed to protecting the public and environment from the harmful effects of air pollution, and this commitment stands irrespective of the increasing attention that climate change is receiving.

What is changing is the need for even more co-ordination between the two policy areas. As you recognise, there are efficiencies to be had in implementing measures that reduce the impact of human activity on climate change, while also serving to improve air quality, and vice versa. It is important that we maximise these efficiencies. On the flipside, we of course also need to remain vigilant to instances where measures intended to address climate change, have the potential to work against our efforts to tackle air quality, and vice versa.

Your comments on the draft Climate Change Bill, including the need to incorporate air quality milestones, will be considered alongside the many others being received as part of the consultation process. It is nevertheless worth pointing out at this stage that we already have a series of challenging EU limit values and UK standards for air quality, and our main priority continues to be the design and implementation of measures that will enable us to meet them. Moreover, we are starting to see important linkages between the two policy areas develop, as evidenced by, for example, the review of carbon savings that will result from the measures set out in the soon to be published revised UK Air Quality Strategy (to be published summer 2007). And finally, the draft Bill aims to introduce a clear, credible long-term framework for the UK to achieve its goals of reducing carbon dioxide emissions and ensure steps are taken towards adapting to the impacts of climate change. It is not intended to go into the details of policy for which more appropriate vehicles already exist.

Concerning your view that annual budgets for CO2 would be more effective at tackling climate change than five year budgets, we believe that there are good practical reasons not to set binding annual targets. Five-year carbon budgets will provide a clear cap on carbon emissions not just for one point in time, but for the entire period. They will also provide UK business with greater certainty for future planning and investment. A carbon budget makes very clear that every year’s emissions count towards the overall budget, while also allowing for flexibility if carbon emissions spike in one particular year (for example, because of a particularly cold winter).

Your letter also raises a number of more specific air quality issues.

Concerning exceedances of EU limits for PM10, building on our previous correspondence with you on this matter, we are satisfied that local authorities and the Mayor of London are working hard towards meeting the challenging air quality standards for PM10. The revised UK Air Quality Strategy and new vehicle emissions standards will act as further drivers towards the achievement of the limit values in all locations, and we will continue our efforts in this area.

Concerning the proposed move to exposure reduction for PM2.5 in the new Air Quality Directive, this does not mean that the UK is not taking seriously exposure to PM2.5 in “hot-spot” areas, and we will be commenting on domestic action in this respect in the revised UK Air Quality Strategy, including monitoring for PM2.5. We also re-state that Member States have agreed to a limit value for PM2.5 beginning in 2015.

Concerning the delay in the publication of the revised UK Air Quality Strategy, we can confirm that this is not linked to the delay in the negotiation of the new Air Quality Directive. As you know, we expect the revised UK Air Quality Strategy to be published in summer 2007, and that the new Air Quality Directive is expected to be agreed towards the end of 2007 or early in 2008.

We also acknowledge the other air quality issues that you raise, and will give these our full consideration in our efforts to improve air quality and the environment.

Yours sincerely

Julius Hinks
Defra - Customer Contact Unit