Dear Mr O’Byrne,
I wish to respond to Defra’s current consultation “Review of Local Air Quality Management (England) – regulatory and guidance changes”. Your ‘preferred option’ is one which was condemned by 18,000 respondents to your 2013 consultation. As your impact assessment shows, your proposals could see local authority air quality monitoring slashed by 75% and spending on air quality reporting by 60%. Local authorities are encouraged to rely on Defra’s air quality monitors but there are on 137 of those across England, compared to over 2,500 air quality monitoring devices run by local authorities.
Without detailed local air quality monitoring, many ‘hotspots’ of air pollution will be missed and local authorities will have no incentive to reduce pollution in those areas. The National Planning Policy Framework emphasises the importance of taking existing or likely breaches of air quality standards into account when assessing new planning applications.
The recent Environmental Audit Committee’s Air Quality report calls for stronger measures to protect clean air and public health through the planning system. Yet without detailed local authority air quality monitoring and reporting, communities and planning authorities will have no way of knowing where standards may or may not be breached.
In many places, air quality monitoring is already insufficient – it needs to be strengthened, not decimated, while air quality reporting requirements must not be watered down.
I am further concerned about the proposal to abolish air quality objectives for four pollutants, two of which happen to be of particular concern in relation to fracking. I believe that the UK’s Air Quality Objectives must be strengthened, not eroded. The air quality objective for PM10 is twice as high as that recommended by the World Health Organisation (WHO) for protecting public health while the PM2.5 objective is 2.5 times as high as that recommended by the WHO.
Your consultation claims to encourage local authorities to take more action to reduce PM2.5 emissions, which are especially harmful to human health, but proposes that PM2.5 should not be incorporated into air quality regulations and that local authorities should not have to monitor and report on it.
Without comprehensive monitoring and reporting, nobody can know what PM
2.5 levels are and whether they are going up or down and whether EU Air Quality Standards will be met.
Air pollution is a significant cause of illness and premature death in the UK and the country is facing infringement procedures for having failed to meet EU air quality standards since 2010. I therefore urge Defra to withdraw the current proposals and to draw up genuine plans for reducing air pollution, ones which must incorporate the Environmental Audit Committee’s recent recommendations.