Cleaner Air for Scotland 2: equalities impact assessment

Based on the current body of evidence, there are no aspects of measures in CAFS 2 which will negatively impact people due to their age. However, measures within the strategy to reduce emissions and improve air quality will positively impact those disproportionately impacted by the health effects ofair pollution such as older people and children.

There is a wealth of good quality evidence linking outdoor air pollution with impacts on human health. It is now widely accepted by expert assessment groups (e.g. the World Health Organisation (WHO), the Global Burden of Disease (GBD) team, the International Agency for Research on Cancer (IARC), the (UK) Committee on Medical Effects of Air Pollutants (COMEAP), and the US Environmental Protection Agency (EPA)) that outdoor air pollution causes damage to human health across a wide range of conditions, from pre-birth to old age.

International epidemiological studies have formed the basis for estimating the size of the impacts on populations and for quantifying the likely health benefits of reducing pollutant levels.
Older People: There is consistent evidence that older people are particularly vulnerable to the adverse effects of air pollution. A systematic review of studies that examined deaths in association with exposure to PM for example, indicated a risk in older people of about twice that observed in younger persons. Similar findings are reported for hospitalisations. These comparisons are relatively crude ('older', variously categorised, versus 'not older') and probably obscure a stronger effect. The explanation(s) are likely to be several and have not been examined fully, but they will include the higher frequency of pollution-sensitive pulmonary, cardiovascular and metabolic diseases in older populations.

Sustainable transport options may be restricted, especially in rural areas, for older people so measures to reduce road transport emissions need to take this into account.

Young people: Few studies have explicitly compared risks in children with those in adults, but there is evidence of an adverse effect of air pollution on the health of children who spend a higher proportion of their time outdoors and are therefore at greater risk of exposure to ambient air pollution. There is little doubt that acute exposure to high levels of air pollution results in increased respiratory symptoms in children, including parent- and self-reported cough and wheeze, and increased visits to emergency departments with respiratory illnesses. Whether air pollution causes asthma in previously healthy children is a more contentious issue. Exposure of the young child to air pollution can produce definite harm and even increase the risk of death from lung infections. There is evidence that it may produce deleterious effects on growth, intelligence and neurological development. In studies that have examined 'dose' effects of air pollution, harmful effects have been detected at current regulatory levels and there appears to be no lower limit below which harmful effects do not occur.
Scotland specific evidence: There is a relatively small published literature on the effects of air pollution based on studies carried out specifically in Scotland. This evidence is important however, in developing an understanding of the local epidemiology of air pollution impacts and how this compares with the corresponding international findings. Differences in the types of study carried out in Scotland make cross comparison of their findings difficult. It is not therefore possible to provide pooled estimates of health effects in Scotland equivalent to those calculated in international studies. Nonetheless, valid conclusions can be drawn by assessing the balance of evidence provided by these studies of impacts on the Scottish population

Health and Environment Working Group Report 2019.

Health and Environment Working Group Report 2019.

Royal College of Physicians: Every breath we take: the lifelong impact of air pollution 2016.

Health and Environment Working Group Report, 2019.

There is some uncertainty from international studies about the scale of health effects associated with low pollutant concentrations typical of those found in Scotland today. The body of Scottish research, while relatively small, has repeatedly demonstrated impacts of pollutants on respiratory illness that are consistent with international evidence. There are two proposed actions within the revised CAFS strategy which aim to fill this evidence gap, these being:

• Assess the evidence on health impacts of low level pollution in countries with levels of ambient air pollution comparable to Scotland.
• Commission population research on the long term effects of air pollution using cohort methods to aid further understanding of health impacts and explain the apparently different epidemiology in Scotland.

We will seek views on these actions as part of the formal consultation process. We will also seek views on any additional equalities impacts of the measures in CAFS 2 to ensure we have correctly assessed potential impacts.

Based on the current body of evidence, we have not identified any aspects of measures in CAFS 2 which will negatively impact disabled people.

Achieving compliance with air quality objectives and reducing preventable air pollution will improve air quality for Scotland's population, protecting those more vulnerable to its health impacts, including disabled people.

A disability can arise from a wide range of impairments which can be organ specific, including respiratory conditions, such as asthma and cardiovascular diseases.

There is scientific consensus that exposure to air pollution is harmful to people's health, in relation particularly to premature mortality and morbidity,

Mainly related to respiratory and cardiovascular disease.

Improvements in air quality arising from the implementation of measures in CAFS 2, will therefore have a positive impact on disabled people living with respiratory conditions which are exacerbated by poor air quality.

The EQIA undertaken for the National Transport Strategy 2 highlighted a number of issues that are relevant to measures to reduce emissions from road transport and shift travel to more sustainable options:

• insufficient wheelchair provision on public transport
• inherent design conflicts between public transport vehicles and the needs of disabled people
• ScotRail's passenger assistance service for people travelling with mobility difficulties is well regarded by most but the need to give 24 hours' notice of travel plans prevents spontaneous activities
• the reliability of help points and other critical features at stations designed to help vulnerable passengers
• lack of awareness and training for bus drivers to deal with people with mobility difficulties
• poor pavement surfaces and the siting of parking impeding walking and making use of mobility scooters dangerous
• lack of consideration for hidden disabilities in transport provision.

Equality Act, 2010 Guidance.

Health and Environment Working Group Report, 2019.

National Transport Strategy 2 Equality Impact Assessment.

National Transport Strategy 2.

As part of the consultation, we will seek views on whether the measures in the strategy are likely to have any disproportionate effects on this protected characteristic

Based on the current body of evidence, we have not identified any aspects of measures in CAFS 2 which will negatively impact due to their gender.

The issue of sex differences in vulnerability to air pollution is complex. The evidence is inconsistent in studies of adults, although research in older adults and studies that have used estimates of exposure based on place of residence suggest that the effects of air pollution are more pronounced in women. Any differences are likely to have several explanations that include biological differences between men and women (such as in the absorption of gases through the lung or hormonal differences in chemical regulation), the higher proportion of older and vulnerable women than men, sex-related behavioural differences in factors such as smoking and occupational exposures (that may mask, in men, the effects of air pollution), or simply that estimates of exposure may be more accurate in adult women

Royal College of Physicians: Every breath we take: the lifelong impact of air pollution 2016.

As part of the consultation, we will seek views on whether the strategy is likely to have any disproportionate effects on this protected characteristic, which we have not identified.

Based on the current body of evidence, we have not identified any aspects of measures in CAFS 2 which will negatively impact those covered under this protected characteristic.

However, the measures in the strategy could benefit pregnant women by reducing emissions and improving air quality.

Epidemiological studies suggest a link between air pollution exposure and premature birth, with the strongest evidence for gaseous pollutants (O3 and SO2) and weaker evidence for particulates (PM2.5 and PM10). The strongest evidence from epidemiological studies of pregnancy outcomes is that air pollution affects fetal growth and birth weight. There is consistent evidence that exposure to particulates during pregnancy increases the risk of low birth weight. It is important to note that high exposure to specific air pollutants is socially patterned and linked with other lifestyle factors, including smoking and diet. The effects described appear to be independent of these confounding influences, but there is some suggestion that socio-economic deprivation increases the adverse effects of air pollution on low birth weight.
Scotland Specific Evidence: Evidence regarding air pollution in Scotland and pregnancy outcomes is mixed. Significant associations of NO2 and PM10 with low birth weight were found using cohort data (1994 to 2008). Risks for very preterm birth (birth between 28-32 weeks) were raised but were non-significant. A separate individual level study in north-east Scotland reported mixed evidence linking maternal exposure to particles (PM10, PM2.5) and NO2 with measures of foetal growth.

Royal College of Physicians: Every breath we take: the lifelong impact of air pollution 2016.

Health and Environment Working Group Report 2019.

The body of Scottish evidence regarding air pollution in Scotland and pregnancy outcomes is mixed, and there are only a small number of studies. The actions proposed in the revised CAFS strategy (outlined below) aim to provide a better understanding of the impact of relatively low levels of pollution, such as those found across much of Scotland, on human health. We will seek views on these actions during the formal consultation.

• Assess the evidence on health impacts of low level pollution in countries with levels of ambient air pollution comparable to Scotland.
• Commission population research on the long term effects of air pollution using cohort methods to aid further understanding of health impacts and explain the apparently different epidemiology in Scotland.

We will also seek views on any additional equalities impacts of the measures in CAFS 2 to ensure we have correctly assessing potential impacts.

We are not aware of any relevant existing evidence at this time on gender reassignment in relation to the strategy.

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As part of the consultation, we will seek views on whether the strategy is likely to have any disproportionate effects on this protected characteristic

We are not aware of any relevant existing evidence at this time on marriage and civil partnership in relation to the strategy.

N/A

As part of the consultation, we will seek views on whether the strategy is likely to have any disproportionate effects on this protected characteristic.

We are not aware of any relevant existing evidence at this time on sexual orientation in relation to the strategy.

N/A

As part of the consultation, we will seek views on whether the strategy proposals are likely to have any disproportionate effects on this protected characteristic

We are not aware of any relevant existing evidence at this time on race in relation to the strategy.

N/A

As part of the consultation, we will seek views on whether the strategy is likely to have any disproportionate effects on this protected characteristic

We are not aware of any relevant existing evidence at this time on religion or belief in relation to the strategy.

N/A

As part of the consultation, we will seek views on whether the strategy is likely to have any disproportionate effects on this protected characteristic

There may be an impact on remote/rural and island communities arising from measures contained within the strategy to tackle emissions from domestic combustion. Particularly controlling the supply of the most polluting fuels. This may disproportionately impact remote/rural and island communities due to the potentially higher proportion of households relying on solid fuels as a primary heat source in these areas.

In 2018 Defra sought information on the use of solid fuels such as house coal, manufactured solid fuel and wood for domestic heating, and the impact that changes to the availability of these fuels would have on consumers and businesses. The call for evidence was UK wide and included Scotland. The results were used to inform Defra's Clean Air Strategy for England proposals for addressing domestic combustion emissions. The intention is that these will form the basis for action in Scotland also.

An impact assessment for proposed legislation to deliver the commitments in Defra's Clean Air Strategy to phase out the most polluting fuels from domestic burning has been completed. One of the policy options considered in the impact assessment was "Regulating the sale of fuels in urban areas only". However as approximately 50% of PM pollution comes from outside a local area; restricting legislation to urban areas would deliver less air quality benefit across the country.

The proposals in CAFS 2 cover both appliances and fuels, and focus on three key areas: the right appliance burning the right fuel, consumer education and proper installation/maintenance.

Due to the transboundary nature of air pollutants, a consistent national, as opposed to local, approach will have a large impact on reducing domestic combustion emissions. It should also be noted that it is not the CAFS 2 strategy itself that will cause the impact but the regulations which follow on. Any such regulations will be required to undergo further equalities assessments.

Defra consultation responses, Air quality: using cleaner fuels for domestic burning, August 2018.

Defra Impact Assessment for proposed regulation to phase out the most polluting fuels from domestic burning, October 2019.

Air Pollutant Inventories for England, Scotland, Wales, and Northern Ireland: 1990-2017.

As the measures in Defra's Clean Air Strategy for England to reduce emissions from domestic combustion will form the basis for action in Scotland, impacts have been assessed at a UK level. However, there may be Scotland specific impacts which have not been fully addressed. The consultation on CAFS 2 will seek views on the actions to tackle emissions from domestic combustion Scotland. Response to the consultation will be analysed to further inform this impact assessment and any disproportionate impacts on remote/rural and island communities. Further equalities assessments will/may be needed as more detailed regulations follow on from the strategy.

To inform our proposals on behaviour change, we commissioned a review of evidence around public attitudes and behaviour relating to air quality. The review was undertaken by the University of the West of England (UWE). The report highlighted the need to engage effectively with communities, particularly those in deprived areas during the design and implementation of pro-environmental policies, to minimise negative impacts.

The literature review showed that for those living in rural areas and in lower socioeconomic households, reducing private vehicle ownership/use is a challenge as there is a (perceived) reliance on the car to manage complex needs (e.g. work, family, caring, health concerns). In the most deprived areas, this is compounded by a fear of crime, as well as a lack of infrastructure, which restricts perceived abilities to use active travel modes. As the policies in CAFS 2 aim to encourage a shift towards more sustainable transport modes, focus on engagement with these communities will be critical to mitigate any disproportionate impacts.

On the domestic energy side, solid fuel burning wasn't covered in the literature reviewed, however two key studies revealed very different issues on energy management from either end of the economic spectrum. In both, solutions were focused on energy saving measures rather than the much more effective reduction of energy demand. For the most affluent, although householders were keen to install insulation, new windows and efficient heating systems, the demand for space and desire for bigger houses created an increase in per person energy demand. For those in social housing, a lack of consideration of users' needs and limitations in renovating the heating system led to a greater economic burden for many, and a lack of (perceived) control over their energy usage. Both cases illustrate the need to consider the lived experiences of individuals when seeking to influence their energy usage to reduce emissions.

University of the West of England (UWE), Cleaner Air for Scotland Air Quality Public Attitudes & Behaviour Review, August 2020.

As part of the consultation, we will seek views on whether the strategy proposals are likely to have any disproportionate effects on low income households. Particularly in relation to the action to legislate to restrict the sale of the most polluting fuels, as this may impact those living in fuel poverty.

In regards to sustainable transport policies, the UWE literature review highlighted that even where urban regeneration has improved infrastructure, active travel remains low, signalling a need to better understand the complex needs of these societies and the barriers that prevent them from shifting to more pro-environmental behaviours.

Developing a public engagement strategy on air quality in Scotland, taking into account the recommendations from the evidence review, is an action in CAFS 2.