Cleaner Air for Scotland strategy: independent review
Conclusions and recommendations from the independent review of the Cleaner Air for Scotland strategy.
11.1 This review has established that air pollution is a complex and serious continuing issue and significant steps towards taking it seriously have been made.
11.2 There is also clearly much more to do to achieve the desired outcomes across Scotland that ensure public health is comprehensively protected and a suitably integrated approach to transport, environment, planning and health is taken. This approach is essential for the health and wellbeing of society, its mobility for economic and social needs as well as for the delivery of the high standards of quality of life that we all expect.
11.3 Scotland is generally performing quite well by EU and global comparison, with ambient and regulated pollution levels generally continuing to fall. The rate of decline in pollution is now reducing and this suggests that the easier actions or at least those deemed priorities, urgent and important have been taken and we are now dealing with the harder issues, where interventions may be more expensive, disruptive or unpopular. To achieve the progress and improvements sought, and some are still required in legal terms, these interventions may also be necessary. How we deliver them and how quickly and extensively we progress will now be critical.
11.4 Key air quality attributes are largely EU compliant and some are already below WHO recommended levels.
11.5 There are however localised poor quality areas and particular challenges around: transport pollution, provision, constraints, and NOx and PM performance; and ammonia levels relating primarily to agriculture; and the pace of change in some areas, particularly public behaviour around the car, given options available and perceived.
11.6 Given what we know and continue to learn about the harm represented by breathing polluted air, the main question is how much lower should our target levels for pollutants be and how quickly do we wish to choose to get there. We have failed to deliver elements of the suite of relevant EU and domestic standards currently in place. Meeting these would and should be an urgent priority for Scotland.
11.7 It is too early to make meaningful observations about the impact of LEZs but valuable lessons are being learned for the second wave cities from Glasgow’s early experience. Potentially radical plans for Edinburgh became visible during this review and its LEZ should achieve significant improvements. However, a final plan for the city is not yet clear and efforts have been made that could limit its effectiveness and displace serious pollution impacts. It is also clear that our four major cities are all different and require bespoke solutions while not confounding the need for and benefits of coherence, especially for the goods sector and for public understanding and overall delivery of improvement generally.
11.8 The air pollution and transport data on which key conclusions can be reached and upon which modelling to design and manage LEZs and other interventions is based are however less than perfect and require at least some modification to improve their robustness and utility. There then needs to be more effective use of data and modelling, based on a. the need for and quality of continuous traffic monitoring data, and b. improved air pollution monitoring.
11.9 There are questions to answer on the design and implementation of LEZs. This includes decisions under consideration to exclude any of the main polluting vehicle categories. It is critical that the main polluters are prioritised and that careful consideration is given to the nature and consequences of the restrictions applying, and their fit with AQMAs, including ensuring a positive impact of interventions overall.
11.10 CAFS appears to have had a positive impact in raising the profile in public policy and the wider consciousness of air pollution. It has begun the process of integration of the elements of a genuinely joined up strategy to tackle air pollution. A significant proportion of the original actions has been delivered or is progressing to the 2020 target dates. Progress has been slower however in several areas and needs more focus and energetic implementation.
11.11 Specific problematic areas in relation to urban NOx and PM, and locations where congestion is prevalent and older diesel engines still dominate, require to be addressed by reduction in vehicles, improving fleets and better management of access and flow of all motor transport. Improvements in some areas should not lead to deteriorations elsewhere, either through fleet “cascade” effects or displaced congestion or pressures.
11.12 Active transport and overall mobility fit still clearly require significantly improved public engagement, behaviour change and improved options and information. In the shorter term, management and information alongside planned and necessary vehicle changes can help if vehicle numbers do not increase. In the longer term spatial planning and mobility provision needs to be significantly improved.
11.13 There is constructive engagement between stakeholders but more focus is needed in order to ensure effective delivery in areas of overlapping operational and performance management areas. Local government monitoring and transport management and spatial and transport planning need to fit more effectively with the responsibilities and operational activities of Transport Scotland and SEPA. Visible and politically empowered as well as simpler partnership between the key players is needed in policy and operational areas. When the next plan is clear, it needs to be owned and understood by all delivery bodies and responsibility and accountability for the components must be equally clear.
11.14 There are challenges around the leadership and management of transport context: achieving modal shifts; the speed of cleaner engine uptake; counteracting car numbers increasing and sole occupancy; tackling congestion, not least at specific pinch-point locations and reducing it as well as managing effects; greatly enhanced infrastructure and support for goods and active segment options, etc. It is to be hoped that appropriately aligned, constructive and complementary arrangements and actions will be forthcoming from the imminent NTS, thereby maximising fit with and impact of the recommendations of this review.
11.15 The fact that, almost unique among air pollutants, ammonia levels have not fallen suggests that interventions are now urgently required to tackle issues in the agriculture sector. This concerns the need to ensure better management of fertiliser application and management in relation to dairy and beef as well as pig and poultry units. This matters generally but is most acute where these may be located close to and upwind of urban areas, receptors and monitors and may also act in conjunction with particulates to exacerbate pollution issues. Tackling these might also address odour complaints. Modifications are necessary to agricultural management guidance, to training and support, to basic animal housing and management practices and to the handling of wastes, manures, and fertilisers.
11.16 It remains clear that poor air quality damages health and there is increasing evidence of population-level and specific impacts that require to be addressed. Evidence is growing but causation is hard to prove, given the multi-dimensional nature of the air we breathe and the other pressures on health we are all exposed to. There are philosophical and practical issues around precaution versus certainty on causation around health effects but precaution supports action on the basis of current evidence. Care will be needed to develop the evidence base and public health policy and messages to be deployed, including the strategy for sensitive receptors. Reducing levels of pollution, especially PM and NOx remains the priority. Where possible active transport users, pedestrians and vulnerable groups should be separated from areas of exposure risk.
11.17 Actions on any individual component of our recommendations need to be taken in the broad context of public policy. This means specifically, for air pollution actions, that they are planned in conjunction with climate management and public safety and resilience effort, for example, as well as around higher amenity approaches for recreation, work, commercial and retail activities.
11.18 Air pollution appears disproportionately to affect the already disadvantaged and vulnerable. Inequalities appear to be compounded in that existing deprivation and low access to economic opportunity, combine with poor health and poor activity levels, poor access to affordable mobility and likely exposure to air pollution. These component issues necessitate an integrated strategic approach.
11.19 There is a clear need to help with public choices by means of more and better public information on pollution and transport options. Over time, tackling the cultural issues around modal shift and behavioural change, including greatly enhancing understanding of effective, tolerable and affordable incentives and disincentives seems crucial.
11.20 Further effort and delivery is needed on the design and increased utility of the public realm - planning and designing our way to a cleaner and healthier environment, maximising safety, amenity and ease of movement as well as minimising exposures especially for sensitive receptors.
11.21 Effort is also required to tackle governance and performance management – who does what, is held responsible for delivery and collaboration, and how do we know how we are progressing. Existing structures are overly complex and inadequately accountable and effective.
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