Cleaner Air for Scotland 2: consultation

Consultation on a draft new air quality strategy for Scotland, taking into account the recommendations arising from the independent review of the Cleaner Air for Scotland strategy.


1. In November 2015 the Scottish Government published ‘Cleaner Air for Scotland – The Road to a Healthier Future’[1].  This was the first separate Scottish air quality strategy.  CAFS sought to bring together the major policy areas relevant to air quality - climate change, transport, planning, health and energy - within one overarching framework.  The strategy sets out around 40 actions relating to these policy areas. Progress in delivering the CAFS actions is summarised in a series of annual reports, with a final report reviewing the overall achievements of CAFS published in February 2020.

2. When CAFS was published, there was a commitment to review the strategy after five years.  However, given the significant number of policy developments with implications for air quality over recent years, alongside an increasing body of evidence demonstrating the human and environmental health impacts of poor air quality, it was decided to bring this process forward.  Therefore, in November 2018, the Cabinet Secretary for the Environment, Climate Change and Land Reform commissioned an independently-led review of CAFS.  The purpose of the review was twofold, firstly to assess progress to date in implementing the actions contained in the strategy and secondly to identify priorities for additional actions to deliver further air quality improvements.

3. The review was overseen by a steering group chaired by Professor Campbell Gemmell and supported by four specialist working groups covering health & environment; placemaking; agricultural, domestic & industrial emissions; and transport.  The steering group submitted its final report[2] to the Scottish Government in July 2019 setting out a series of conclusions and recommendations.  Between October and December 2019, an online survey allowed individuals and organisations to submit their views on the recommendations[3].  Both the review findings and these wider views have been used to inform development of this consultation.

The need for additional action on air quality

4. Over the last 50 years air quality has improved beyond all recognition. The choking smogs of the 1950s are a thing of the past, driven by concerted action, especially on energy use and transport.  Air quality in Scotland’s towns and cities is improving year on year, but there are still areas across the country where air quality standards for human health are not being met.  Road transport in urban areas remains a significant contributor to poor air quality.  Air pollution especially impacts on the more vulnerable members of society - the very young and the elderly or those with existing health conditions such as asthma, respiratory and heart disease.  This makes air quality an important health inequalities issue.  

5. As the CAFS review clearly demonstrated, additional work is necessary to ensure full compliance with legislative requirements, and to deliver further human and environmental health improvements.  Also, the rate of decline in most regulated pollutant sources is now reducing. This suggests that the easier actions or at least those deemed priority, urgent and important have been taken and we are now dealing with the harder issues, where interventions may be more complex and more focused on behaviour change as well as technological improvement.  An associated question is what our target levels for the key pollutants should be and how quickly do we wish to get there.

6. The majority of the 40 actions set out in CAFS, together with several additional actions not included at the time of publication have been completed; however some are still ongoing.  Those actions will continue to be taken forward in parallel with the new actions set out in this strategy.  The CAFS 2018/19 progress report[4] provides full details on completed actions and the status of those still being implemented.

7. Further reductions in air pollution will require concerted action across many sectors including national and local government, the private and public sectors, and by the public itself.  Increased awareness and understanding of the key issues and the interlinkages between them is needed, built on the foundation of good place design.  

8. At the outset it is important to state that air pollution, climate change, quality of the urban environment and mobility are strongly interconnected.  From this, it follows that effective policy co-ordination across these broad themes, at both central and local government levels, will deliver co-benefits greater than those possible by considering each in isolation.  Although there has been some progress in this regard, it is clear from the evidence presented in the CAFS review that more needs to be done if these co-benefits are to be fully realised.  Key to this will be embedding placemaking principles, with a strong focus on nature based solutions, across policy areas to guide our way to a cleaner, healthier and more attractive environment.  

Emissions trends – 1990 to 2018

9. Emissions of the eight main air pollutants are lower in 2018 than they were in 1990 (Figure 1), although the rate of decline for some of these has started to level off in recent years.  This rate of decline is relatively similar for particulate matter (PM10 and 2.5), oxides of nitrogen (NOx), non-methane volatile organic compounds (NMVOC), sulphur dioxide (SO2) and carbon monoxide (CO).  Lead (Pb) shows a much higher rate of reduction from 1990 to 2000 coinciding with the phase-out of leaded petrol from 2000. By contrast, ammonia (NH3) emissions have declined at a slower rate than other pollutants, and even increased slightly over recent years.  More detailed information can be found in the ‘Air Pollutant Inventories for England, Scotland, Wales and Northern Ireland: 1990-2018’[5]

Figure 1: Emissions trends for the main air pollutants in Scotland since 1990
This is a graph showing changes in emissions for 10 air pollutants in Scotland between 1990 and 2018.

Coronavirus (COVID-19

10. Since the CAFS review and during the drafting process for CAFS 2, the COVID-19 pandemic has changed the way we work, socialise and travel.  Although CAFS 2 will have a five year lifespan, the current state of knowledge and lessons learnt at the time of publication will be reflected in the strategy.  Any future developments relating to the pandemic which have implications for the policies set out in CAFS 2 will be addressed as updates to the delivery plan which is being developed to complement the strategy. 

11. The unprecedented changes in living and working patterns are likely to have had a significant, but as yet unquantified, effect on air pollution.  In Scotland, during the main lockdown period, nitrogen dioxide (NO2) levels declined.  Analysis of eight urban air quality monitoring stations showed peak decreases from 49% at Atholl Street, Perth to 72% at Hope Street, Glasgow[6].  Although detailed data are not available at the time of writing, it is likely that pollution levels will have increased again since lockdown measures began to be relaxed.

12. At the beginning of July 2020, the Air Quality Expert Group, which advises the UK Government and devolved administrations on air quality, published a report of its call for evidence on changes in air pollution emissions, concentrations and exposure across the UK during the pandemic[7].  This provides a useful overview of the available evidence at that point in time.  However, long term data covering the full period of the pandemic and beyond will be required in order to draw robust conclusions.  

13. As the lockdown restrictions are eased it is recognised that green recovery must form a central part of Scotland’s emergence from the pandemic. The report of the Scottish Government’s Advisory Group on Economic Recovery, published in June 2020, sets out a number of recommendations on how this might be achieved[8].  Such an approach will help Scotland meet its climate change targets and improve air quality, whilst supporting economic recovery. 

Air Quality Legislation

National Emission Ceilings Directive

14. The National Emission Ceilings Directive (NECD) (2016/2284/EU) sets national emission ceilings for certain atmospheric pollutants (nitrogen oxides, non methane volatile organic compounds, sulphur dioxide, ammonia and (new in the 2016 Directive) fine particulate matter PM2.5).  It  implements at EU level obligations under the United Nations Economic Commission for Europe (UNECE) Convention on Long-Range Transboundary Air Pollution of 1979 (CLRTAP) and, in particular, its 1999 Protocol to Abate Acidification, Eutrophication and Ground-level Ozone of 1999, which was revised in 2012 (the revised Gothenburg Protocol).  The NECD transposes 2020 targets agreed under the revised Gothenburg Protocol, along with more ambitious targets for 2030.

15. The NECD has been transposed into domestic law through the National Emission Ceilings Regulations 2018[9] and the requirements will be implemented at UK level through a National Air Pollution Control Programme[10].  Although the UK is on course to meet the 2020 targets for all pollutants (other than ammonia), new policies will be required to ensure 2030 compliance.  Further information is set out in the joint UK National Air Pollution Control Programme (NAPCP)[11]. The actions set out in this strategy will make an important contribution to the NAPCP and Scotland’s wider role in securing compliance with international commitments.

Local Air Quality Management

16. Under the Environment Act 1995 and associated regulations, all Scottish local authorities are required to regularly review and assess air quality in their areas against several air pollutants of concern for human health.  If this assessment indicates that any objective is not being met, the authority concerned must declare an Air Quality Management Area (AQMA) and produce an action plan setting out measures to address the issues identified.  At the time of publication of this consultation, 38 AQMAs were in place in Scotland, all but two of which were declared for transport related exceedences of nitrogen dioxide and/or PM10.  The majority of issues in these AQMAs relate to localised pollution hotspots within urban centres.  The remaining two AQMAs have been declared for industrial emissions of sulphur dioxide and PM10 respectively[12].

17. Data from the Scottish air quality monitoring network, which consists of around 100 sites across the country[13], show a clear downward trend in pollutant concentrations in recent years.  In some cases declared AQMAs are already compliant with the objectives; however the Scottish Government requires at least three consecutive years of compliance before revocation can proceed.  The Scottish Government is working closely with relevant authorities to ensure revocation can take place as soon as possible.  In remaining cases, further progress with action plan implementation is needed to secure compliance.

Ambient Air Quality Directive

18. Under the Ambient Air Quality Directive and transposing regulations, the UK is required to meet limit and target values for a range of air pollutants.  In Scotland, full compliance has been secured with all of these limit and target values, with the exception of a small number of nitrogen dioxide exceedences.  In 2017 a joint UK action plan on nitrogen dioxide[14] was submitted to the European Commission, outlining how compliance will be achieved in the shortest time possible.

National Nitrogen Balance Sheet

19. The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019, requires the creation of a nitrogen balance sheet (NBS) for the country by March 2022.  Once established, the NBS will quantify nitrogen flows across economic and environmental sectors, including agriculture, waste, production and consumption, and between water, land and air. It will provide a baseline on Scotland’s current nitrogen use efficiency, i.e. the proportion of nitrogen used for its intended purpose vs. losses to the environment. This baseline creates a new type of cross-sectoral evidence base that quantifies the uses and losses of nitrogen and enables identification of more and less nitrogen use-efficient processes, and will inform future decision-making across a range of policy areas, including air quality.



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