January 2012
Air pollution & air quality:
policies & strategies and the
impact on Londoners
Introduction
The Department for Environment, Food and Rural Affairs (Defra) states that air
pollution causes annual health costs of approximately £15billion to UK residents.
According to Clean Air in London, levels of air pollution are more than twice the
recommended levels set by the World Health Organisation (WHO) for many of
London's busiest roads. London is now the only area in the UK which exceeds legally
binding EU regulations on particulate matter concentrations in the air (one measure
of air quality and pollution) and has the highest levels of other air pollutants in the
country.
Air pollution refers to substances in the air which directly affect human health,
welfare, plant or animal life. Air quality is measured in terms of the concentration of a
pollutant that is present in the air. Most pollution emitted in London is from road
transport and from domestic and commercial heating systems. By reducing these
emissions, air quality should therefore improve. Emissions from these sources are
also major contributors to climate change, so improving air quality is directly related
to efforts to reduce carbon emissions.
In recent years, a number of studies have established the link between poor air
quality and health in urban areas. In particular, it is clear that long-term
exposure (across the entire life span of an individual) can contribute to the
development of disease and can increase the risk of breathing problems. The
level of particulate matter in the air can aggravate respiratory and cardiovascular
conditions and some data indicates that air levels of nitrogen dioxide (NO2) can also
have a negative effect on lung function and respiratory and asthma symptoms.
A study commissioned by the Mayor of London, and referred to in his 2010 Air
Quality Strategy, suggests that around 4,300 deaths per year in London are partly
caused by long-term exposure to high concentrations of particulate matter. Research
has also shown that people living in deprived areas are disproportionately affected by
air pollution, in part because such areas tend to be near busy roads which have
higher levels of air pollution caused by road traffic.
The aim of this briefing is to raise awareness of the impact of air pollution on
Londoners and the policies that aim to improve air quality and reduce the
impacts of air pollution at a national and London-wide level. It summarises the
opportunities for the London VCS to support reductions in, adaptation to, and
mitigation against the impacts of, air pollution.
What works in improving air quality?
The Mayor of London states in his Air Quality Strategy that he has taken on board a
range of local measures that can improve air quality. They include: adapting buses to
make them cleaner; implementing a limit on taxi emissions; citywide Low Emission
Zones (LEZ); initiatives to encourage cycling and walking; smoothing traffic flow to
reduce fumes and promoting zero-emitting electric vehicles.
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January 2012
In addition, the Defra report on air pollution: Action in a Changing Climate (2010)
recommends the acceleration of clean technologies including retrofitment; behaviour
changes (including cycling and walking and safe driving); local measures and
delivery, including parking controls, bus management and local transport planning.
European legislation
European legislation is the main driver that manages, improves and monitors air
quality in Europe. The 2008 Ambient air quality directive (2008/50/EC) places “legally
binding limits for concentrations in outdoor air of major air pollutants that impact
public health such as particulate matter (PM10 and PM2.5) and nitrogen dioxide (NO2).”
The directive agreed a possible “time extensions of 3 years (PM10) or up to five years
(NO2, benzene) for complying with limit values, based on conditions and the
assessment by the European Commission (EC)”.
Monitoring stations are a European Union (EU) requirement by member states as
each station it monitors “information to assess compliance in the specific area and to
obtain further information as regards exposure, source apportionment that supports
further development of air policy as well as air pollution management in the area”.
The UK annual Air Pollution UK reports sets out how it complies with EU limit and
target values, including monitoring stations. The UK must have statutory monitoring
networks in place to meet the requirements of the EC directive “with air quality
modelling used to supplement the monitored data”.
The UK has exceeded the EU legally binding levels for NO2. The levels of air
pollution are particularly high in London. The government now faces a £300
million fine from the European Commission but had obtained an extension
from the EC to comply with its air quality targets until December 2011. The
London Mayor’s 2010 strategy also stated its intention to ask the EC for an extension
until 2015 to meet London’s NO2 limits.
National policy context
In 2008, the Government passed the Climate Change Act that introduced the world’s
first legal framework to address the impacts of climate change. The Act set out a new
approach to manage and respond to climate change. It includes limits to the use of
carbon units and fines for offences relating to pollution. The Act has legally binding
targets including “green house gas emission reductions through action in the UK and
abroad of at least 80% by 2050, and reductions in CO2 emissions of at least 26% by
2020, against a 1990 baseline”.
The Environment Agency (for the UK and its equivalent for Scotland) was established
under the Environment Act (1995) The Act gives the Environment Agency
responsibility for regulating pollution control, general environmental and recreational
duties. The Act also established National Park Authorities (UK and Wales); requires
the Secretary of State to prepare a national air quality strategy for Great Britain and
expects local authorities to prepare air quality reviews.
As part of its legal obligation to the EC with regards to compliance with EU limits on
air quality, the Government publishes annual reports on air pollution. The most recent
report was published in 2010.
The annual reports measure the level of major pollutants across the UK and analyses
their impact. The 2010 report states that the UK “exceeded the limit value for hourly
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January 2012
mean nitrogen dioxide in three zones [including London], and for annual mean
nitrogen dioxide in 40 zones [also including London] (out of a total of 43 zones).
The Environment Audit Committee is a select committee that deliberates how far
government departments and non-governmental public bodies contribute to
“environmental protection and sustainable development; it audits their performance
against any sustainable development and environmental protection targets. Its remit
cuts across government rather than focuses on the work of a particular department”.
The Committee produced its ninth report "Air Quality: A follow on report" in
November 2011, following its 2010 committee reporting on air quality. Its evidence
states that the Government has not considered the full implications of “air quality
problems [being] concentrated in densely populated urban areas where the health
impacts are very large”. They suggested that the Government should state the
impacts of poor air quality in terms of premature deaths, as this is the most effective
way of engaging politicians and the public in measures to improve air quality. They
also recommended that the Government develop a new cross–departmental air
quality strategy that aligns climate change and air quality policies and assigns clear
roles and responsibilities for action within the different departments to maximise
results.
Last year, Defra produced its report, Air pollution: Action in a changing climate. This
emphasised the relationship between poor air quality and health and estimated
the economic costs of air pollution. It stated that “optimising climate change
policies for air pollution can yield additional benefits of some £14billion by
2050” in terms of improved health & wellbeing, as well as savings made
through general air quality improvements. Defra is working to integrate and coordinate local, regional, national and European policies on reducing climate change
and air pollution to maximise benefits. Its immediate priority though is to “work
towards compliance with current EU air quality limits.”.
London policy context
The Mayor of London has a legal responsibility to prepare and to keep under review
an Air Quality Strategy for London. The Greater London Authority Act 1999 requires
the Mayor to include in his Air Quality Strategy policies and proposals:
 for the implementation in Greater London of the policies contained in the strategy;
and
 for the achievement in Greater London of the air quality standards in the National
Environment Act, which sets out national air quality standards.
The GLA Act requires the Strategy to contain information about the following matters:
 Greater London’s current air quality and its likely future air quality;
 the measures which are to be taken by the Mayor, Transport for London and the
London Development Agency (now abolished with many of its functions
transferred to the GLA) for the purpose of implementing the Strategy; and
 the measures which other persons or bodies are to be encouraged by the Mayor
to take for the purpose of its implementation.
In preparation for a new London Air Quality Strategy, in May 2009, the London
Assembly produced its report, Every Breath you take: An Investigation into Air
Quality in London. The report explained the opportunity offered by the powers
and duties of the Mayor of London to develop a co-ordinated response to
improving air quality across the capital. These included linking air quality and
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January 2012
transport (including walking and cycling), but also climate change, planning, energy
use, health and economic development.
As mentioned in the introduction, the Greater London Authority's: Report on the
Estimation for Mortality Impacts of Particulate Air Pollutants in London (2010)
confirmed previous negative findings regarding the impact of air pollution on health
and related this to the figure of 4,300 preventable deaths per year attributable to air
pollution across London.
In December 2010, "Cleaning London's Air", the London Mayor's final version of his
London Air Quality Strategy was produced. The overarching aim of this Strategy was
to reduce air pollution in London in order to improve the health of Londoners. It
states that the most effective means to do this was to achieve the EU air
quality limit values as soon as possible, at the same time achieving
compliance with nationally prescribed air quality standards and objectives, as
required by the GLA Act. Failure to meet EU limit values could lead to the
European Commission taking legal action against Member States and possible fines
being imposed, adding an additional economic value to improving air quality in the
capital. As stated above in the European legislation section above, The Mayor of
London and the Government had received an extension to meet European air quality
targets.
The Mayor of London’s latest strategy sets out details on how Londoner's
health and quality of life can be improved by putting in a number of measures
to clean the city's air. Delivery mechanisms include age limits for taxis; promoting
low-emission vehicles and eco-driving; new standards for the LEZ; retrofitting older
buses; targeted measures for areas where air quality is poor; using the planning
system to reduce emissions from new developments and retrofitting homes and
offices to make them more energy efficient. Future proposals includes smarter travel,
more efficient ‘eco-driving’, ‘no idling-zones’ for parked vehicles especially targeting
buses, coaches, taxis and delivery vehicles.
The local policy context
The Mayor of London also has powers to ensure London boroughs meet their
statutory Local Air Quality Management requirements. Under the Local Air Quality
Management (LAQM) framework set by the Government under the Environment Act
1995 the boroughs must regularly review and assess air quality and designate Air
Quality Management Areas (AQMAs) where UK standards are not being met.
Where a borough has declared an AQMA, an Air Quality Action Plan (AQAP) must
be produced that works towards achievement of the air quality standards and
objectives. Currently all 33 London boroughs have designated AQMAs and the
associated AQAPs must have regard to the Mayor’s Air Quality Strategy. The Mayor
is a statutory consultee for all the documents produced by boroughs as part of their
LAQM procedures. This is the primary means by which the Mayor of London, through
the GLA, monitors the actions taken by boroughs to improve air quality and ensures
that they are consistent with his Air Quality Strategy. Ultimately, the Mayor has
powers to direct London boroughs in their air quality duties.
However, local authorities also have a number of legal powers that enable them to
tackle air pollution more directly, although most of these have limitations in
addressing the EU air quality measurements directly, as they were developed to
address different issues:
 Under the Road Traffic Regulations 2002 local authorities can issue Fixed
Penalty Notices to drivers who allow their vehicle engines to run unnecessarily
while the vehicle is stationary – however it is problematic to define ‘unnecessarily’
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January 2012
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and the penalty charge is fixed at £20, which is too low to be a powerful
disincentive.
Local authorities can control smaller combustion processes being developed in
their boroughs and can stipulate emission limits based on preventing, or where
that is not practicable, reducing air emissions through the Local Authority
Pollution Prevention and Control regime.
The Clean Air Act (CAA) covers emissions of dust, smoke and in some cases
fumes. It requires the use of approved biomass appliances in smoke control
areas (all of London is declared a smoke control zone) and also includes
provisions for local authorities to approve chimney heights for developments.
However, as emissions from the combustion of biomass are largely invisible and
odourless, the CAA does not include provisions to deal with the harmful pollutants
associated with these installations (such as NO2 and particulate matter).
Under section 80 of the Environmental Protection Act 1990, local authorities can
serve an abatement notice on those burning waste, once they are satisfied that a
nuisance exists. However, local authorities are often unwilling to proceed with this
prosecution option, as it is highly resource intensive to prove that the smoke
constitutes a statutory nuisance, or to prove conclusively the source.
Integrating policy
The 2010 EU Regulations designate the Defra Secretary of State as responsible for
securing compliance with the Air Quality Directive in England, and impose a duty on
them to secure compliance with EU limit values set under the Directive. London
boroughs have their local air quality management duties as regards national
objectives set under the 1995 Act; and the Mayor of London has his own
responsibilities under the GLA Act concerning his Air Quality Strategy. The Mayor
has power of direction over the boroughs and the Secretary of State has powers of
direction over both.
The Government intends to simplify all these provisions into one legislative
framework, to streamline the relationship between EU limit values and national
objectives. At the moment many commentators have suggested that the
systems in the UK are not sufficiently integrated across departments or
between different geographical areas. Client Earth presenting its evidence to the
Environment Audit Committee reported in November 2011 on a “systemic failure of
air quality policy and governance” They claimed that this is “partly due to the complex
and ineffective legal and institutional framework. The existence of two separate legal
frameworks creates confusion over legal duties. The legal framework also fails to
provide for effective and dissuasive sanctions in the event of breaches of its
provisions, as required by EU law.”
The Environmental Audit Committee follow up report agrees that the
“lack of joined-up thinking between departments is especially worrying while the
Government is undertaking the 'Red Tape Challenge' to reduce regulation. We
recognise that the existing legal framework is somewhat disjointed and could benefit
from reorganisation”.
London and the Olympics
The International Olympic Committee (IOC) can withhold up to 25 % of the expected
£700 million in broadcasting revenue if air quality exceeds EU levels during the
Games. According to the Olympic Delivery Authority’s Strategic Environmental
Assessment, the expected increases in traffic along the Olympic route network of 600
km of London roads during the Games may lead to further breaches of European
legal limits in areas that already suffer from poor air quality. Levels of small
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January 2012
particulate matter were above the legal limit in April last year and London still faces a
£300 million fine if levels are not reduced. The Mayor of London has still not met the
required EU air quality targets.
Concerns around meeting air quality targets in London
The Environment Audit Committee's ninth report criticised the Mayor of London for
not developing and implementing measures to achieve better levels of air quality in
the capital.
Government ministers have also "ignored" the London Mayors' proposals for national
action in his Air Quality Strategy. ClientEarth’s legal challenge forced the
Government to “concede that they are failing to meet their legal obligations to keep
air pollution within EU limits. The High Court has ruled that this is now a matter for
the European Commission.”
Moreover, Jenny Jones, the Green Party’s London Mayoral candidate and London
Assembly member has accused the Mayor of London of "fiddling the figures [on air
pollution] rather than tackl[ing] the problem, in order to stave off a potential
£300million fine from Europe", referring to the controversial “damping” measures
that the Mayor had implemented around EU air quality monitoring stations in the
capital, which are claimed to falsely lower the concentrations of air pollutants
measured, in the vicinity of the monitoring stations only.
However, the Mayor launched the following measures from his Air Quality Strategy
(to be implemented by Transport for London) in January 2012, in an attempt to cut
pollution from road traffic and so improve air quality in London:
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More restrictions (accompanied by financial penalties for breaking these) on
vehicles that can enter the Low Emission Zone to double the reduction of harmful
large particulate matter pollution;
The capital's first vehicle age limits for licensed black cabs and minicabs (as a
new taxi emits around 20 times less particulate matter than a 15 year old taxi)
A new campaign in early January to curb engine idling across the capital, as
turning off an engine and restarting it after a minute or longer causes less
pollution than keeping the engine idling and uses less fuel.
Charities including the British Lung Foundation are supporting the new initiatives.
VCS work to address air quality: a case study
London Sustainability Exchange (LSx), a VCS organisation that supports people and
organisations to be more environmentally sustainable, has launched a Cleaner Air 4
Schools project to support Transport for London’s Clean Air Fund. Three schools
from Marylebone, one of London’s top air pollution hotspots, have been selected to
take part in the project.
The project aims to improve the confidence, knowledge and skills of parents,
teachers, pupils and school governors, helping them understand the importance of
air quality and how it is affected, as well as influencing behaviours. Schools not only
account for a significant percentage of greenhouse emissions throughout the UK, but
are uniquely placed to inform and positively influence behaviours within wider
communities.
LSx aims to achieve this by delivering a focused campaign to the schools, helping to
reduce the problem of idling by empowering participants to measure air pollution
using ‘citizen science’ methods and educate others on the problem of air pollution. It
will do this by:
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January 2012
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Establishing Air Quality Teams formed of parents, teachers, pupils and school
governors will be set up in each school. Each team of eight will hopefully
influence the behaviour of around 250 parents.
Using tried-and-tested citizen science methods, the Air Quality Teams will be
trained to use equipment such as diffusion tubes and ghost wipes to measure
pollution levels. This will be linked to the school curriculum.
Peer-to-peer social marketing: the Air Quality Teams will promote awareness
using materials such as posters and stickers, some of which will they will develop
themselves.
Conclusion
Poor air quality has a negative impact on everyone who lives and works in the
capital. People living in the poorest areas are also more badly affected by poor air
quality, as they often live in areas with higher levels of air pollution, and are more
likely to suffer from other health conditions that make them more vulnerable to the
impacts. It is only by working across Government departments at individual, local,
regional, national and European levels, and tying this work in with plans to adapt to
and mitigate against the impacts of climate change, that we can hope to begin to
reduce air pollution in London.
By their nature, many London VCS organisations provide community-based
preventative services to the most vulnerable people in London. They also engage,
and develop the trust of, service users for whom language, culture or knowledge
prove significant barriers to engagement with mainstream and/or statutory sector
agencies This puts them in a unique position to ensure that information relating to air
quality and pollution is accessible to all communities.
The London VCS can also support their service users, staff and volunteers to change
their behaviour to contribute to an overall improvement air quality across the capital.
Many of these behaviours have the advantage that they also reduce carbon
emissions and so address climate change. For example they could promote and
make it easier to use energy-saving modes of transport, such as walking and cycling.
Finally the VCS has a strong tradition of lobbying and campaigning for changes in the
status quo, from votes for women to civil partnerships. VCS organisations can learn
from such successful campaigns and develop them so that continually working to
reduce carbon emissions and air pollution becomes part of the everyday culture of
London.
Economic decline has been shown to be positively correlated with reduced energy
consumption, and energy efficiencies can create major financial savings. The current
poor economic climate, therefore, represents a major opportunity to address climate
change and the associated problems of air pollution in London.
LVSC will….
…..continue to work with its partners on raising awareness about climate change
within the sector. One of the pages on our website is dedicated to the work of VCS
organisations in London on this issue and the resources they produce.
We are currently in the process of setting up a one-day training programme with
Global Action Plan targeting London's infrastructure (or support) organisations in April
/ May this year. The training will aim to help environmental performance and provide
guidance on how to develop climate change action plans.
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January 2012
We are also working with our funder City Bridge Trust to support Councils for
Voluntary Services (CVSs) and other support organisations with a free eco-audit.
Further reading & resources
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Friends of the Earth produced a report on how to put environmental justice into
campaigns
The Campaign for Clean Air in London has produced “Ten steps to clean air”
Just Act has a range of useful resources for the VCS environmental justice,
creating green action plans, transport and the environment and others
London Air monitors air quality in each London borough It also provides
information on the effects of air pollution on health and a 30 second guide on
what you can do to mitigate the impact of air pollution.
The Joseph Rowntree Foundation has produced a report on the social impact of
climate change
LVSC’s Climate Change Leaders project
Leaders for a Low Carbon London is London Voluntary Service Council (LVCS)’s
new initiative to actively engage the mainstream VCS in carbon reduction
activities. It aims to work with infrastructure organisations to help them to become
leaders and advocates on climate change. The work is being carried out with a
number of partners to support the link between expert green organisations and
the mainstream VCS.
Sandra van der Feen & Alison Blackwood
LVSC
January 2012
Leaders for a Low Carbon London is funded by City Bridge Trust
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