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Defra’s air quality review slammed

7 November 2013

The following letter was sent to Defra in response to its recent consultation reviewing air quality monitoring.

York Environment Forum opposes Defra’s proposal to close Local Authority air pollution monitoring stations and to remove the need for LAs to declare Air Quality Management Areas. The reasons given in your consultation are specious. Monitoring provides raw data on the air quality: the fact that measures to improve air quality are ‘difficult to quantify’ is not a reason to cease monitoring, but rather to improve the measures and the means of analysis. To remove the monitoring stations altogether – and, critically, the requirement for Local Authorities to act on levels of air pollution that breach EU regulations – is akin to shutting your eyes and pretending it isn’t happening.

Similarly, the fact that ‘few authorities have been able to revoke any Air Quality Management Areas as a result of their interventions’ is no more reason to remove monitoring. The ‘We haven’t fixed it yet, so let’s stop bothering’ approach is positively dangerous: is the Government really prepared to play Russian roulette with public health? It’s also unjust and, arguably, immoral. Areas of social deprivation tend to have worse air quality and it is the poor, who already have a shorter life expectancy, that will suffer the most.

The argument that LAQM is ‘ very administrative’ is risible as an excuse for removing monitoring stations. The establishment of LAQM’s has prompted local authorities to compile Low Emission Strategies and create Low Emission Zones and to take positive measures to reduce air pollution. If it were not for the administrative framework – and the legal implications – we doubt that LAs would make these actions such a priority.

We do indeed face a significant challenge in meeting health-based EU limits for air quality and there are legal and financial penalties for infraction. This, we suspect, is the real reason for wanting to remove air pollution monitoring (and it is why these regulations were drawn up in the first place). Of course, it is vital that that local authorities focus their actions on what is needed to achieve these obligations and to reduce the public health impacts of poor air quality, but if monitoring does not take place at the same time, how can any scientific rationale  be applied?

There needs to be scientific assessment and reporting alongside action to improve air quality, otherwise we will be working without criteria. We would like to think that Government will not be using the increase in premature deaths from heart failure, respiratory conditions and cancer caused by particulates as a more reliable guide to local air quality than the present monitoring arrangements.

If there is a need to ‘reinvigorate and refocus’ LAQM on helping the UK meet EU air quality standards (how will anyone know, without monitoring?) it is to take the issue of public health seriously. The costs supposedly ‘saved’ by closing monitoring stations will be miniscule compared to the costs incurred by the Health Service in treating people, especially the young, old and chronically sick, for the effects of our increasingly bad air pollution.

Here in York several AQMAs have been established and they are driving the City of York Council’s Low Emissions Strategy. We in York Environment Forum feel there should be more, not less, real-time, publicly available, local information available on air quality. This not only enables citizens to make informed decisions  about their own journeys but it stimulates and drives action and measures to improve air quality.

You cannot fight your enemy if you don’t know where it is, what it is doing and how strong it is.

We oppose the removal of air quality monitoring and the need for LAs to declare AQMAs in the strongest possible terms.

Kate Lock

Chair, York Environment Forum

13 September 2013

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