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 »