Consultation response: Local Air Quality Management in England: review
Dear Lord de Mauley
We write on behalf of the Healthy Air Campaign in response to the above consultation. The Healthy Air Campaign is a broad coalition of organisations which support the need for urgent action to improve air quality. This is a joint response representing shared concerns about the proposals contained in this consultation. Individual partners will make separate and detailed responses where appropriate.
We agree that the system of Local Air Quality Management (LAQM) is in urgent need of reform and broadly support the four aims of the review, with some important caveats. We do need a simplified system which clearly allocates roles and responsibilities for taking action which delivers improvements in public health. However, the solutions proposed would not deliver these aims. On the contrary, they seem designed to mask the true scale of England’s air quality crisis rather than make any real attempt to solve it.
We are particularly concerned that Defra’s favoured option is Option 3, which would remove the legal duty on local authorities to assess local air quality and designate Air Quality Management Areas. This would be nothing short of a disaster for air quality, risking the loss of hundreds of local monitoring sites across England. Option 4 would be worse still.
A fundamental weakness underpinning the proposals is the assumption that reduced requirements for monitoring and reporting would automatically translate into increased action planning. Without any legal obligation to assess air quality, there is a great risk that local authorities, faced with severe financial constraints imposed by Government spending cuts, will be forced to close local monitoring sites and make local air quality officers redundant.
Without accurate data about local air quality:
- The true nature and extent of local air pollution will be hidden, and the impetus for urgent action to tackle air pollution will be lost;
- The public will be unable to exercise their legal right to be informed about local air quality and hold those responsible to account;
- Local authorities will be powerless to stop highly polluting new developments;
- Increases in harmful pollutants would exacerbate a public health issue already having an effect on mortality equivalent to 29,000 deaths.
As a broader point, it is wholly unacceptable to restrict the scope of the review to the local air quality management system, without any consideration of the role of national government. There is no doubt that LAQM could be improved so that it plays its part alongside national policies, but it was never designed to address widespread breaches of air quality objectives/limits. The current public health crisis is the result of policy failures at all levels, but particularly at the national level.
For these reasons the Healthy Air Campaign cannot support any of the options put forward in this proposal. However, we would support a revised system which reduced the administrative burden on local authorities while increasing the onus on all tiers of government to act to tackle air quality. Any such system would need to be based on the following principles:
- Local authorities must have legal duties to assess local air quality, designate Air Quality Management Areas and take action to tackle air pollution
- Local action must go significantly further than current EU standards in order to protect public health
- The public have a right to participate in local action plans and receive annual progress reports
- Local authorities can only take action over pollution sources they control: national government must ensure that regional plans and national policies deliver strategic change.
We are extremely opposed to the possibility of option 3 remaining as the preferred option and request an urgent meeting with you before the next phase of this consultation to discuss our concerns in more detail.
Finally, we must also register our deep concern that a consultation of this significance and complexity has been allocated only eight weeks falling mainly over the summer holidays. This will markedly reduce the extent to which many relevant stakeholders are able to meaningfully respond.