Defra consultation on its 'Less dirty air strategy'

Apologies for the length of this post which is intended to encourage readers to respond to the Government/Defra consultation on air quality  https://www.google.com/search?q=clean+air+strategy+2018&ie=utf-8&oe=utf-8&client=firefox-b by 14 August.

My responses to the consultation questions are in italics.

Consultation questions

1. Understanding the problem

Q1. What do you think about the actions put forward in the understanding the problem chapter? Please provide evidence in support of your answer if possible. The consultation should have described the reasons why previous strategies had been found to be illegal and the changes that have been made.

Q2. How can we improve the accessibility of evidence on air quality, so that it meets the wide-ranging needs of the public, the science community, and other interested parties? The technical aspects to air quality are clearly very complex and beyond the understanding of any but the specialists in this field.  It is these complex areas that Government should be trusted without its citizens having to check the evidence and scrutinise the actions.  However, this has become an area where the trust that is required of the public has been destroyed by a Government trying and failing to adopt strategies that even the courts could see were inadequate. 

2. Protecting the nation’s health

Q3. What do you think of the package of actions put forward in the health chapter? The most important question, not answered by this chapter, is why the Government is planning a delay in taking more effective action in a shorter time frame? It is difficult to think of a more urgent issue than preventing irrevocable damage to children’s brains and lungs.

Q4. How can we improve the way we communicate with the public about poor air quality and what people can do? All communications should be in the context of a Government being consistent in its own actions (ie not encouraging increases in air travel and road building). The public will not listen to a Government acting in ways that contradict the intentions of the Strategy.

3. Protecting the environment

Q5. What do you think of the actions put forward in the environment chapter? The issue of road traffic should not have been deferred to one more report.  The Government could rely on previous advice (including the Environmental Audit Committee, the Committee on Climate Change and DfT officers) to reduce the national speed limit.  This could be done immediately, at no public expense and with no unfairness.  Such a move would trigger a virtuous circle affecting the road transport system that would include substantial improvements to air quality. Waiting for a further report is a cause of unnecessary delay and dissimulation.  

Q6. What further action do you think can be taken to reduce the impact of air pollution on the natural environment? Tree planting/forest gardening in urban areas could have significant impact on filtering air but probably only after more stringent action should be taken while such planting matures.

4. Securing clean growth and innovation

Q.7. What do you think of the package of actions put forward in the clean growth and innovation chapter? ‘Clean growth’ could turn out to be a tautology. A strategy that exports its industrial pollution to other countries and continues to pollute after 2030 is not ‘clean’.  ‘Growth’ is currently calculated by GDP that does not measure ‘wellbeing’. The Strategy should concentrate on the health and wellbeing and not relate this to some outdated economic ambition.    

Q8. In what areas of the air quality industry is there potential for UK leadership? In acknowledging that the UK is responsible for air pollution caused in the production of imported goods and agricultural produce and that it will intervene so that clean up costs will be added to these imports.

Q9. In your view, what are the barriers to the take-up of existing technologies which can help tackle air pollution? The Government should shorten the timescale during which air pollution will be tolerated. Industry will find that barriers can be overcome.  The Government’s 2040 deadline for the sale of diesel cars is already in 2018 looking to be redundant.

5. Action to reduce emissions from transport

Q11. What do you think of the package of actions put forward in the transport chapter? A systemic change is necessary and a reduction in the national speed limit to 50mph (in accordance with expert advice) would trigger a virtuous circle that would include a substantial improvement to air quality in urban areas where 20mph is the appropriate speed. Currently this speed is responsible for increased pollution from conventional engines even if road, brake and tyre dust is reduced.  The decarbonising the rail sector is described as stretching and challenging that reads as an excuse for the failure to achieve this in the next few years.

6. Action to reduce emissions at home

Q13. What do you think of the package of actions put forward to reduce the impact of domestic combustion? The Government should not be advocating changes to consumer behaviour in the context of decisions that would undermine efforts being asked of the public (ie encouraging air travel and car driving).

Q16. What do you think of the package of actions put forward in the farming chapter? There is unwavering concentration on an agricultural industry that is systematically destroying soils (some of which goes into the air) and no awareness of the advantages of agroecology, agroforestry and permaculture that would have negligible impacts on air quality.  The transition could come from limiting the inputs to the industry but that should not prevent incentives being given to more benign forms of agriculture.  The land use planning system can assist with some of these changes.

Q17. See above

8. Action to reduce emissions from industry

Q19. What do you think of the package of actions put forward in the industry chapter? This should include emissions in countries growing and manufacturing imported goods and produce.

9. Leadership at all levels (local to international)

Q25. What do you think of the package of actions put forward in the leadership chapter? The Government should stop making claims about international leadership but put its own house in order (see the recent example of the Welsh Government accepting that the previous strategy was illegal and the Westminster Government trying and failing to persuade the courts).  Internationally the Government should be ensuring that we are not importing produce and goods ‘on the cheap’ due to the export of emissions. Nationally, a Government fit to lead would be open and honest about its attempts to adopt a strategy that would have failed/killed/maimed its citizens. Leadership is not possible without trust that is currently lacking and not helped by the Government positions on air transport, road building and speed limits.

Q26. What are your views on the England-wide legislative package set out in section 9.2.2? The Government should look at the potential of the land use planning system that has been obscured by the obsession with house building.

Q27. Are there gaps in the powers available to local government for tackling local air problems? If so, what are they? The fundamental gap is the failure of the national Government to prevent to purchase and use of ICEs and heavily polluting speeds.

Q28. What are the benefits of making changes to the balance of responsibility for clean local air between lower and upper tier authorities? What are the risks? Air quality is part of a number of systems and securing safe levels requires systemic action – implying central Government’s primary  responsibility. It is very unlikely that local actions would be (cost) effective and could be a diversionary tactic by central Government to devolve responsibility and delay effective national measures. Local charging for ‘licences to kill’ would obscure the real responsibility that lies with central Government.

10. Progress against targets

Q30. What do you think of the package of actions in the strategy as a whole? The lack of reasons for allowing the killing and maiming to continue make it difficult to judge whether the time lines should be shortened. It would have been useful to have been referred to the changes that have been made to address the recent court judgement(s). The suggestion that cleaning up the railway is a difficult challenge raises suspicions that the Government is raising a cover for its recent failure in that respect and that complexity is a camouflage for other delays.  The question should be does the strategy  encourage the public to trust the Government that it is proposing to adopt a strategy that prioritises and protects the health of its people (including its children)? Given the past failures and recent encouragement to air travel and road building the answer is probably “no”.

Trust is also damaged by doubts that the Government is acting in ways that are consistent with the 25 Year Environment Plan, the Clean Growth Strategy or the SDGs.