The Government’s proposals are woefully inadequate to tackle air pollution and place far too much responsibility on the shoulders of our over-stretched local authorities. We stand on the cliff-edge of a national public health emergency and these plans are devoid of substantive proposals, timescales for addressing the key challenges, clarity around targets or even availability of resources to support necessary actions.

—Tony Lewis, Head of Policy at CIEH

Further grievances from CIEH focus on Clean Air Zones (CAZs) and the Government’s confidence that they are the panacea to solving air pollution.

CIEH is concerned that CAZ trials are taking place in only five English cities and have not been running long enough to demonstrate successful results. Also, CIEH points out, CAZs will lead to people seeking alternative routes to avoid the zones and will cause pollution in other areas.

The membership body has suggested that CAZs are similar to Air Quality Management Areas (AQMAs), which have been operating across the UK for many years. But rather than providing a solution to air pollution, CIEH states that AQMAs have demonstrated little success and often lead to problem hotspots being relocated elsewhere.

Other concerns CIEH has with the Government’s Air Quality plans:

• Leaving local authorities to come up with “novel and innovative solutions” will lead to incoherent and inconsistent approaches to a national problem.

• The Government’s cost/benefit analysis fails to consider the burden on the NHS and the health implications on people and local communities, concentrating solely on business impacts.

• Overlook particulate matter as the single biggest contributor to premature deaths and ill-health, placing too much emphasis on reducing NO₂ emissions.

• The two objectives of achieving NO₂ compliance in the short term and the wider actions necessary to improve air quality and achieve a zero-emission / low-carbon economy in the longer-term, need to be separated out.

CIEH adduces a number of proposals that the Government should consider in their final air quality plans in addition to ones that have already been suggested, including:

• Government should provide appropriate levels of financial support to target areas where air pollution is highest and where the largest number of people are exposed.

• Local authorities need to be supported to develop a better understanding of the issue through more and better ‘real-time’ monitoring of air quality and associated health-related data.

• Reduce the number of vehicles on the road or take action to remove vehicles that do not comply with EuroVI/6 or gasoline Euro 3 standards as a minimum.

• Remove tax incentives on diesel and transfer these incentives to Ultra Low Emission Vehicles and Zero Emission Vehicles infrastructure development.

• CIEH supports the moves by TfL to license only new ULEV or ZEV black cabs from 2018 and advocates national measures to ensure that this approach is taken by all local authorities across the UK.

• Better provision and incentives for sustainable travels plans for people to access towns, cities and workplaces via the use of public transport, cycling and walking.

CIEH is of the view that national problems require properly evaluated national solutions. This means conducting robust, properly funded and appropriately evidenced research to not only work out what currently works, but to also identify innovative solutions that will work. This is not the role of local authorities and it is, therefore, unfair of this consultation to expect local authorities to fulfil that role. Government must at least lead in this respect to ensure that we do not end up with a patchwork of local schemes, providing varying solutions with uncertain outcomes and, potentially, providing barriers and a lack of clarity to not only the operators of multi-site businesses but to consumers too.

CIEH will, however, support any proposals to ensure that, wherever possible, proposals for new urban developments include provision of infrastructure to support ZEVs; increase insulation standards of all new buildings to reduce energy use, restrict the use of wood burning stoves in domestic situations and require all new buildings to incorporate the use of ultra-low NO_x boilers.

… we would suggest that this is not an Air Quality Plan, but a NO₂ Compliance Plan (or a Transport Emissions Plan)—the problem with considering this as an Air Quality Plan is that it largely overlooks Particulate matter as the single biggest contributor to premature deaths and ill-health. The two objectives of achieving NO₂ compliance in the short term and the wider actions necessary to improve air quality and achieve a zero emission and low Carbon economy in the longer-term, need to be separated out. The latter should be the subject of a more comprehensive strategy and the former a more succinct, focused and properly funded plan.

—Consultation response of CIEH