DEFRA’s plans to set long-term targets for air quality under the Environment Act 2021 have caused uproar among stakeholders, with the tight deadline to respond to the goals and a dearth of detail leaving them struggling to respond.
Under the Act, at least one long-term target must be set for air quality, for attainment within 15 years, with the law adding that a specific goal for fine particulates (PM2.5) “may, but need not, be a long-term target”.
DEFRA opened a consultation on the targets a month ago. Ignoring the leeway granted for shorter-term attainment, it proposed that PM2.5 would reach an annual mean of no more than 10 micrograms per cubic metre in England by 2040. This would be accompanied by a ‘population exposure reduction target’, requiring a 35% drop in average exposure to the pollutant by the same date.
The twin approach is intended to address pollution hotspots and lower exposure across the country as a whole, says the paper.
But stakeholders have described the plans as falling “well short of expectations”, presenting “lots of loopholes” and the consultation itself being a stumbling block for meaningful engagement.
“Every stakeholder I have spoken to says it is not ambitious enough,” said Tamara Sandoul, policy and campaigns manager at the Chartered Institute of Environmental Health.
Michael Lunn, policy manager at the Environmental Industries Commission, said that the targets fall disappointingly short. As a missed opportunity to drive growth in green jobs, the paper is, “not just stunning, it’s shockingly embarrassing for the UK not to be at the forefront of mitigation. We have the technologies – and why we are not promoting that astounds me”, he told ENDS.
Veteran air quality campaigner Simon Birkett, founder of Clean Air in London, described the annual mean target as “about as pathetic as it could be”.
Their central objection is that the proposed limit is seriously outdated, reflecting what the World Health Organization (WHO) recommended in 2005. Knowledge of the dire effects of air pollution has since moved on considerably, leading to the body backing a 5µg/m3 annual average limit last year.
The deadline for meeting it is also too distant, according to critics. “It adds a whole generation of kids exposed to pollution above the amount the WHO thinks is acceptable,” said Katie Nield, ClientEarth’s UK clean air lawyer.
The WHO’s older 10µg/m3 limit is already in force in Canada, Switzerland and even Afghanistan and Malawi, according to the UN body.
But such countries are in a very different position to the south-east of England, said Air Quality Consultants Ltd director Stephen Moorcroft. Tightening it to 5µg/m3 should be welcomed “but it has to be regarded as an ambition. I cannot see any point in setting a target that cannot be achieved, despite the excellent sound bite it offers,” he added.
Its revised suite of guidelines also recommend a 24 hour average limit for PM2.5 of 15µg/m3, intended to address pollution spikes. The current limit applying in England is 50µg/m3, not to be exceeded more than 35 times a year, although that applies to the coarser and less dangerous PM10 fraction rather than PM2.5.
DEFRA’s proposals ignore such short-term threats. The consultation also entirely disregards other pollutants of concern such as nitrogen dioxide (NO2), the WHO having slashed its recommended limits on the gas from 40µg/m3 to 10µg/m3 as an annual average and from 200µg/m3 to 25µg/m3 over 24 hours.
Moving the goalposts
Another problem is that DEFRA appears to want to move the goalposts.
The consultation refers to assessing attainment only at monitoring sites, rather than using modelling, as used currently. Data from monitoring stations operated by local authorities would be disregarded, coming only from DEFRA’s Automatic Urban and Rural Network.
The paper also proposes a further departure: averaging attainment over time. “If the target was met in three out of the four previous years, then the target will be considered to have been met,” it says.
Nield described the mechanism as “a get out of jail free card”.
Moorcroft told ENDS the averaging would be a “blunt approach”, there being better ways to address unusual events than ignoring them. The UK currently only removes sea salt from air pollution data, though an EU directive allows other natural sources of particulates to be accounted for too, he noted.
The exposure reduction target has attracted similar criticisms. The consultation says that attainment would be judged as the average of three calendar years, “based on the average of representative monitoring sites across the country”. This is comparable to the system established under regulation 23 of the Air Quality Standards Regulations 2010.
But how many sites would be used, where they will be and what “representative” means exactly is left hanging, the paper saying that the arrangements will be specified in forthcoming regulations. The paper therefore offers “a real lack of clarity” on the plans, according to Nield.
Assessing compliance would again set aside modelling data, though as models change continually, a consistent methodology is needed. Moorcroft gave the example of emissions from domestic solid fuel burning, on which a great deal of work is currently being done.
Birkett said that exposure reduction in general is “an incredibly unsatisfactory approach” more suitable as an indicator for internal use than a legal standard. It can only be calculated by the government, long after the year in question, making it “incredibly opaque”, he told ENDS.
Putting aside the merits of either target, perhaps the most fundamental objection to the consultation is that it offers no explanation for why the draft targets were chosen – a situation Nield described as “bonkers”, a view echoed by other stakeholders.
There is no impact assessment, background paper or modelling results, the paper itself devoting only five pages to air quality. It is thus “nigh on impossible” to see how stakeholders can properly engage with the decision-making process, she said.
“A target value of 10µg/m3 by 2040 may well lack ambition, but without seeing the science that is behind this, it is impossible to say,” said Moorcroft, noting that it does not chime with an Imperial College study that found it could be achieved by the end of the decade.
DEFRA has since promised to publish the missing evidence and extend the consultation period. More than half the original two-month period to respond to the targets consultation has already elapsed.
When asked, its press office declined to defend the targets or explain why the missing impact assessment was not published in the first place.