Environmental Protection: Air Quality

Summary of responses to the consultation in England on proposals for air quality objectives for particles, benzene, carbon monoxide and polycyclic aromatic hydrocarbons

Background

1. The Government and the devolved administrations in Scotland, Wales and Northern Ireland published a joint consultation paper ¹ on 17 September 2001 seeking views on proposals to introduce new objectives for four air pollutants into the national Air Quality Strategy for England, Scotland Wales and Northern Ireland ² published in January 2000.
2. The Strategy establishes the framework for achieving further improvements in ambient air quality in the UK to 2003 and beyond. It sets health-based standards for eight important air pollutants and objectives to be achieved in the short to medium term.
3. The consultation paper put forward proposals to strengthen the Strategy's current objectives for particles, benzene and carbon monoxide and to introduce, for the first time, a new objective for polycyclic aromatic hydrocarbons (PAHs). The proposals were in response to latest advice from health experts on the effect of air pollution and took account of developments in European legislation on air quality and of other technical and scientific developments.
4. Printed copies of the consultation paper were sent to a wide range of organisations, some of which had taken part in previous related consultations, and to a number of other interested parties. The consultation paper was also made available on the Defra website.
5. Air quality is a devolved matter. This summary includes comments from the responses received on the proposals in respect of England. Details of responses in Scotland, Wales and Northern Ireland are available from The Scottish Executive, Welsh Assembly Government, and Department of Environment for Northern Ireland.

Consultation Issues

6. The consultation paper invited comments on the following proposals.

   Particles:

   to supplement the Strategy's current particles (PM₁₀) objective with tighter provisional objectives for particles:

   • for all parts of England, except London, a 24 hour mean of 50 micrograms per cubic metre ((g/m³ ) not to be exceeded more than 7 times per year and an annual mean of 20(g/m³, both to be achieved by the end of 2010;
   • for London, a 24 hour mean of 50(g/m³ not to be exceeded more than 10 - 14 times per year and an annual mean of 23 - 25(g/m³, both to be achieved by the end of 2010.

   It was also proposed that London should work towards the annual mean target of 20 after 2010, with the aim of achieving it by 2015 where cost effective and proportionate local action could be identified.

   Benzene:

   to supplement the Strategy's current benzene objective and set as an objective the Strategy's current long term policy target of 3.25(g/m³ as a running annual mean to be achieved by the end of 2010.

   Carbon monoxide:

   to replace the Strategy's current objective for carbon monoxide with an objective of 10 milligrams per cubic metre (mg/m^{3 )} as a running 8-hour mean to be achieved by the end of 2003.

   Polycyclic aromatic hydrocarbons (PAHs):

   to introduce a new provisional objective for PAHs, taking benzo[a]pyrene (B[a]P) as a marker for the total mixture of PAH, of 0.25 nanograms per cubic metre (ng/m³) B[a]P as an annual average to be achieved by the end of 2010.

   A table of the Strategy's current and proposed objectives is at Appendix A.

   Regulations

   It was proposed to prescribe the new objectives for benzene and carbon monoxide in regulations to allow local authorities to review and assess concentrations as part of their air quality management duties. The need to prescribe the new provisional objectives for particles would be considered after the outcome of the European Commission's review of the corresponding European Union (EU) 1^st Air Quality Daughter Directive's indicative stage 2 limit value; the provisional objective for PAH would be kept under review in the light of further monitoring data being available.

7. The consultation paper also invited comments on:

• the overall package of proposals for objectives for particles, including the proposals to set a separate objectives for London than the rest of England;
• the level at which it would be appropriate to set an annual mean objective for particles in London for 2010;
• the proposal that London should work towards the objective proposed for rest of England with a view to achieving it by 2015 where cost effective and proportionate local action could be identified;
• the proposals that the particles objectives should not be placed in regulations for the purpose of local authority management for the time being.

Summary

8. The Department received 74 written responses to the consultation document with the largest number (47) coming from local authorities and groups of local authorities. Others received were from national environmental or health organisations, transport, industry and business sectors and from members of the public. A summary table is set out below. A detailed list of respondents to the consultation in England is at Appendix B. The responses can be viewed in the Department's Library at Whitehall Place West, London SW1A 2HH.

The majority of respondents welcomed the proposals to strengthen the Strategy's current air quality objectives to provide improved protection for public health. The following paragraphs highlight the main issues raised and set out the Government's response.

Separate particles objectives for London

9. Seven respondents supported this proposals. Forty-five respondents were not in favour, mainly local authorities, of which 9 were London boroughs and 27 local authorities from outside London. Also not in favour were the Mayor for London, the Greater London Assembly, three environmental organisations and one health group, one industrial association and two members of public. Their main concern was that London should have the same health benefits as elsewhere. There was one suggestion that London should have a split objective - 20 µg/m³ for background and 23 µg/m³ at roadside locations - and another that London should have an objective of 25 µg/m³ to be met by 2015.

The decision to set a different particles objective is based on detailed modelling. This clearly shows that even if the Government implemented the illustrative package of measures, as set out in the consultation document, or if ever vehicle was taken off the roads in the capital, London would still not meet the 20 µg/m³ particles objective by the objective date of 2010 as set for the rest of England. Apart from the Mayor for London, respondents generally did not put forward comprehensive or meaningful proposals as to how London could in practice achieve the stricter objective of 20 µg/m³ by the end of 2010.

Whilst the Government acknowledges these concerns it believes that it would be unrealistic and inappropriate to set the same objective in London as in the rest of England. To do so would either mean setting an objective which could not be met in London, or setting one which could be met far too easily everywhere else. In the light of the comments received, however, the Government have brought the new objectives for London as close as possible to the objective of 20µg/m³ set for the rest of the country by adopting the tightest objectives from the ranges proposed in the consultation document - a daily mean of 50µg/m³ not to be exceeded more than 10 times a year and an annual mean of 23 µg/m³, both to be met by the end of 2010.

The challenge for London to meet its objective is just as challenging as that posed for the rest of England. The level of reduction in pollution in London is at least as great as that needed in the rest of England. Therefore if the objectives are met in London, people there should experience the same health benefits, if not greater, than people in the rest of the country.

To delay putting the new provisional objectives for particles into regulations for the time being.

10. Six respondents, mainly local authorities, commented in favour of the proposal. One commented that the delay in putting the objective in regulations was helpful as this would allow local authorities to complete their stage 3 air quality reviews and assessments against the Strategy's present objective for particles. Twelve other local authorities, the National Society for Clean Air and Environmental Protection and a member of the public considered the particles objective should be included in regulations with immediate effect.

So far, about 50 air quality management areas have been declared by local authorities in England where the Strategy's current particles objective of 40µg/m³ is unlikely to be met by the end of 2004. The Government consider that the local authorities concerned should have time to take action towards the present objective before starting to review and assess a new objective.

The Government will also need to look again at the provisional objective after the European Commission has completed its review in 2003-04 of the indicative limit value for particles in the 1^st Air Quality Daughter Directive, and to take into account the outcome of that review.

To adopt the Strategy's long term target for benzene as an objective and place in regulations now.

11. Forty-one respondents, of which 31 were local authorities, supported the proposal for adopting the tighter objective. Twenty-seven of those respondents agreed that the objective should be placed in regulations now to enable local authorities to review and assess the objective as part of their air quality management duties. Five respondents were concerned about placing an additional burden on local authorities at this time and considered the objective should be put into regulations in 2004-05, after authorities current stage 3 reviews and assessments have been completed.

12. However, several respondents, while supporting the proposal, recognised it would be unachievable on current trends and difficult to meet in some locations, and not just roadside locations but at some industrial sites. This was supported by two industry respondents who considered the proposed objective was too tight and suggested the objective should reflect the EU 2^nd Air Quality Daughter Directive's limit value for benzene. Two respondents suggested separate objectives for rural and urban areas should be considered to recognise the different situations between those areas.

Whilst the Government recognises the general support for the proposal, it also considered the concerns expressed by other respondents that the objective did not precisely reflect the EU Directive's limit value for benzene. The EU limit value of 5 µg/m³ is only slightly different from the proposed objective of 3.25µg/m³ . While there are no quantifications available of the health benefits of achieving a target of 3.25µg/m³ rather than 5µg/m³ , any measurable gain is likely to be extremely small.

On balance, the Government have therefore decided to set an objective of 5µg/m³ as an annual mean to be met by the end of 2010 throughout England. This objective is still more than 3 times tighter than the Strategy's current objective of 16.25µg/m³ for benzene. The new objective will be placed in regulations later this year. The Government will keep the long- term target for benzene under review.

To adopt the proposed objective for carbon monoxide and place it in regulations now.

13. There was wide support, particularly from local authorities, for the proposal. Three respondents suggested that the new objective should not be put into regulations until 2004-05, after local authorities had completed their next stage 3 reviews and assessments.

The work already undertaken by local authorities in reviewing and assessing the Strategy's current objective for carbon monoxide should allow them to check achievement of the new objective without the need for significant further work. It is therefore proposed to place the new objective in regulations later this year.

To adopt the proposed provisional objective for polycyclic aromatic hydrocarbons (PAHs)

14. There was wide support to set a provisional objective for PAH which should not be include in regulations for the time being. There was a suggestion that the present national monitoring system should be extended to improve our information on PAHs. Six respondents, including two local authority groupings, considered the objective should be put into regulations now for the purpose of local authority reviews and assessments. Several respondents commented there could be problems in meeting the objective in domestic coal burning areas.

There is at present limited data on current and future concentrations of PAHs in the UK. A programme of work is underway to improve our understanding of sources and identify key areas of uncertainty. Since the consultation document was launched a further 7 monitoring sites measuring PAHs have been added to the national monitoring network and 3 more will be added shortly.

Monitoring PAHs is expensive. The Government consider that it would be inappropriate, in view of the present uncertainties over PAHs, to require local authorities to devote resources to review and assess PAHs at the present time. It is therefore proposed to incorporate a national objective for PAH into the Strategy which will not at present be set in regulations for the purposes of local air quality management.

Guidance on the new air quality objectives

15. Several respondents, mainly local authorities, were concerned that guidance and advice on the new objectives proposed should be available to assist with their air quality measuring and management duties.

The Department is currently revising local air quality management policy and technical guidance which takes account of the new objectives and other developments and recommendations, following evaluation of the first round of local authority reviews and assessments. Full consultation on the revised guidance notes will take place this Autumn.

Measures to meet air quality objectives

16. Nine respondents considered that the latest review of the Strategy should have concentrated more on the measures to meet the Strategy's current objectives, rather than on the objectives themselves.

The Air Quality Strategy 2000 indicated that future reviews would focus more on meeting the objectives, subject to new evidence emerging which indicated objectives should be amended or new ones introduced. This latest review and proposals for tighter objectives represents the Government's response to the concerns by the Department of Health's Committee on the Medical Effects of Air Pollution (COMEAP), published in its report in May 2001. The Committee suggested that the health effects of long-term exposure to particles air pollution may be ten times greater than the day to day effects from particles air pollution on people's health.

The Government will set out a package of measures to meet existing air quality objectives and EU Directive's limit values in the air quality action plan which it is likely to submit to the European Commission in September 2003. It believes that the role of air quality objectives is to inform and drive future policies and that these changes to the objectives will serve that purpose.

Particles as PM _2.5

17. Three respondents considered that a new objective for particles as PM _2.5 ,rather than PM₁₀, should be set as an objective. Eight respondents considered that further research and evidence was needed and that local authorities should have a period of stability before a separate particles objective, for PM_2.5, for example, was introduced. Two respondents suggested this issue might be looked at after the EU review of the air quality limit value for particles, due to be completed in 2003-04.

The Strategy's present and proposed objectives is for particles as PM₁₀. This includes all smaller particles, including PM_2.5. The Expert Panel on Air Quality Standards considered which size particle provided the most appropriate basis for an air quality standard in 2001, taking account of the latest evidence. The Government took account of the Expert Group's advice, that PM₁₀ remained the most appropriate means of measurement, in proposing the new objectives for particles. The Government will keep the need for a separate objective of PM _{2.5 ,}or smaller fraction, under review in the light of emerging health evidence.

Air and Environment Quality Division
Department for Environment, Food and Rural Affairs
August 2002

1 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland. A consultation document on proposals for air quality objectives for particles, benzene, carbon monoxide and polycyclic aromatic hydrocarbons. Department for Environment, Food and Rural Affairs in partnership with the Scottish Executive, The National Assembly for Wales and the Department of the Environment for Northern Ireland. September 2001.

2 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland. Working Together for Clean Air. Cmnd 4548. January 2000. ISBN 0-10-145482-1. The Stationery Office.

Appendix A

Table 1: Air Quality Strategy 2000 - Air quality objectives

Table 2: New air quality objectives in England for inclusion in the Air Quality Strategy

*µg/m³ : micrograms per cubic metre, mg/m³ : milligrames per cubic metre, ppb/ppm: parts per million/billion, ng/m³ : nanograms per cubic metre.

Appendix B

Respondents to consultation in England