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Department for Environment, Food & Rural Affairs

Response to Consultation on
The Draft Air Quality Strategy for England, Scotland, Wales and Northern Ireland

Published by the Department of the Environment, Transport and the Regions,
in partnership with the Scottish Executive,
The National Assembly for Wales,
and the Department of the Environment for Northern Ireland

The Government and devolved administrations published their draft Air Quality Strategy for England, Scotland, Wales and Northern Ireland for consultation in August 1999. Separate consultations were carried out in England, Scotland, Wales and Northern Ireland. This overview summarises the responses received to all four consultation exercises, which were broadly consistent in their views. It does not provide a detailed analysis of each response received.

Those responding represented a cross-section of local authorities, environmental organisations, industry, business, health organisations and individuals. Of the responses received throughout the UK, (83 in England, 20 in Scotland, 2 in Wales and 8 in Northern Ireland, the largest group responding was local authorities. The non-confidential responses an be viewed at the following libraries:

Summary

Broadly, the majority of those responding supported the new Strategy, although there was continued opposition (although less strongly expressed than in the past) to the proposal to replace the particles objective. Respondents felt that the draft Strategy's presentation of the objectives was considerably simpler and so improved.

In general, there were very few issues relating specifically to England, Scotland or Wales. A number of Northern Ireland responses expressed concern at the absence of the necessary air quality framework legislation and it was felt this undermined Government's commitment to improving air quality.

General comments

The comments were in general favourable. The majority of those commenting welcomed the revised Strategy, with its improved presentation of the objectives, harmonisation with the EU Air Quality Daughter Directives and the stronger emphasis on delivery mechanisms. Where issues raised in the previous consultation had not been addressed in the draft Strategy, eg, UK having tighter standards than EU for some pollutants, these were generally raised again.

Presentation of objectives
The improved presentation and simplification of the objectives – the use of number of days exceedence, mass per unit volume and deletion of indicative levels – were very much welcomed by all sectors responding. There were still some concerns about the provisional status of the NO2 objective, but also some calls for new provisional objectives to be set in advance of agreement on EU limit values (see PAHs below). Again, there was some concern from local authorities (although considerably less than before) that amending the objectives made the timing of their review and assessment of local air quality difficult and that some stability for the objectives was needed in future.

Tighter UK standards
Industry repeated their concern that the UK should not have tighter objectives than those set by the EU since this made UK industry uncompetitive and was not justified in costs and benefit terms. Industry also felt that tighter objectives could not be justified by the health benefits. Others, for example environmental and health groups, welcomed the tighter objectives.

Compliance dates
Generally, the responses welcomed bringing the objectives forward, although there was some feeling that this was purely presentational. Some local authorities did, however, mention that bringing the dates forward might cause some difficulties with keeping to the review and assessment timetable. There was much less comment on the range of dates than in the previous consultation, perhaps because the simplification of the objectives generally has made this aspect less of a problem, although the view was expressed in Northern Ireland that the compliance dates should be standardised to 1 January 2005, in agreement with the EU Air Quality Daughter Directive.

Cost/benefit analysis
There was little comment on this aspect. A small number (mainly local authorities) welcomed that the draft Strategy had less emphasis on costs and benefits than the review report. There was clear support for cost/benefit work continuing and agreement that future reviews of the Strategy should take it into account, but that it should be only one contributing factor in determining objectives. Industry on the other hand (where they raised it) considered that objectives should be set only if justified in cost/benefit terms.

EPAQS recommendations
There was concern, mainly from local authorities but also other environmental and health groups, that since the EU limit values had been incorporated as objectives, the link between the objectives and EPAQS standards had been weakened. A few felt that this was undermining EPAQS' role. One or two expressed the view that this weakening had led to anomalies, ie objectives being tighter than EPAQS standards. It was also felt that the different "safety factors" which have been applied by EPAQS to the different pollutants studied had led to significant inconsistency between pollutants and the thresholds being adopted.

Future inclusion of objectives for new pollutants
A general point made by only a few local authorities was that the inclusion of objectives for new pollutants in future reviews would have resource consequences for them which needed to be taken into account.

Pollutants

Benzene, 1.3-butadiene and CO
There was general support for bringing the dates forward for these objectives. Industry in general did not welcome the longer term policy aim for benzene, feeling that it had not been subject to cost/benefit analysis and also was not justified on health grounds. There was some suggestion that the proposed EU limit values for benzene and CO should be set now as long-term objectives (as with the lead objective for 2008).

Lead
Most comment on this came from industry. They generally felt that there was no justification for the tighter 2008 objective since it was based on the EPAQS recommendation which had too high a safety margin, it was not justified in terms of the health benefits and it had not been subject to any economic analysis. The general feeling from industry was that this objective, which was tighter than any EU objective, would affect UK industry's competitiveness. Those local authorities, environmental and health groups commenting generally welcomed this longer-term objective.

NO2
There were some comments, mainly from local authorities, although fewer than before, that this should not be provisional since this suggested that the objective had a weaker status that those for other pollutants. One or two responses questioned whether the provisional status would affect the way that NO2 was treated for purposes of LAQM. There was some concern from industry that while the Government's aim of allowing industry the flexibility to make their own choices about reducing emissions was welcomed, this is contradicted by the imposition of prescriptive technologies (FGD and SCR). In Northern Ireland, there was some concern expressed about the timescale for compliance with the NO2 objective, which was seen as unjustified and it was felt that a deadline of 2010 should be adopted.

Ozone
This was raised by only a few responses. Of those that did, industry thought that it should be excluded from the Strategy until an EU limit value was set. One or two responses compared the treatment of ozone with that of PM10, the other transboundary pollutant. Why was one in regulation and therefore action to be taken at local level, but not the other? They should be treated consistently. But this was a small minority. One or two responses felt that a more strategic approach to ozone was needed and that the Strategy should adopt a complimentary approach to that in the National Emissions Ceilings and Ozone Directives.

SO2
Very few responses commented. Of those that did, the general view was that there were too many objectives, particularly with those for ecosystems. Broadly speaking, of those that commented, industry felt that the 15-minute mean was unjustified as it went beyond EU standards and should therefore be deleted. Others wanted to retain the tighter UK objective.

PM10
As expected, there were more comments on this objective than any other, although not as many as before and the comments were generally less robust.

As before, industry and a few local authorities welcomed the relaxation. One or two local authorities thought that it should not be in regulation, as it would not be cost-effective to take action at local level. But environmental groups and the majority of local authorities who responded were not in favour of relaxation. While recognising that the Strategy had to incorporate the EU limit values, and that the existing objective might be unachievable, this was no reason to discard the existing objective. The reasons given for this were the same as before: most authorities would then not have to take any action to reduce local levels and it was sending out the wrong message about the importance of this pollutant.

PM2.5
There was some, but not much, comment on this. Industry considered that the Government should not set an objective until more evidence was available on its health effects, or until an European limit value was set. Some local authorities and other bodies, on the other hand, wanted an objective based on any EPAQS recommendation introduced in the next review.

Vegetation and ecosystems
Most responses commenting (generally local authorities and environmental groups) welcomed these new objectives. Some responses wanted the objectives to be applied to wider areas of the country and others wanted the Strategy to expand on how these objectives would be applied and monitored. One or two felt that it should be made clear that under the terms of the Directive, the measuring sites were to be representative of areas of at least 1000km2.

PAHs
There were some calls for an objective to be set now, or at the earliest opportunity, based on the EPAQS recommendation. One or two responses suggested it could be set now as a provisional objective, to be reviewed in light of the EU limit value once agreed. Where raised, industry, on other hand, favoured waiting until an EU limit value was agreed.

Future work/next review
There was general support for the future research, modelling and cost/benefit work identified to support the next review. There were also calls for the next review to consider a number of other issues, including indoor air quality (as raised in last consultation), interaction with climate change policies and setting an objective for ammonia (because of its impact on nature conservation).

Other Views

A broad range of other views were expressed, both relating to the draft Strategy and Government policy more generally. Those listed below are just a few of those expressed.

Conclusion

In general, responses were supportive of the draft Strategy, particularly the simpler presentation of the objectives and harmonisation with the EU. As in the previous consultation, industry were concerned about the UK going beyond EU limit values, but were content with the proposals to relax the particles objective. Local authorities and environmental groups on the other hand were generally in favour of the tighter standards and against relaxing the particles objective. But there was less strength of feeling on both sides than previously.

Published 19 January 2000
Air Quality Strategy Index
The Air Quality Strategy for England, Scotland, Wales and Northern Ireland Consultation Paper
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