Cleaner Air for Scotland strategy: independent review

Conclusions and recommendations from the independent review of the Cleaner Air for Scotland strategy.


1. Pollution can affect the human body in many ways. Pollutants, especially fine particulate matter, appear to be able to penetrate deep into human organs via our circulatory systems. Whilst there are significant uncertainties around the mechanics of causation, application of the precautionary principle and our awareness of health effects urge us to take further action to deal with air pollution. The evidence base is developing globally and in Scotland and careful consideration is needed to shape public health policy and the messages to be deployed, including the strategy for sensitive receptors and how messages are conveyed to the public. There may ultimately be no such thing as a minimum safe level and we need to reduce pollution and protect the public from sources generally.

2. The LAQM system has the potential to drive further significant improvement. The report sets out LAQM recommendations in the Governance section and practical responses for local government in particular to deliver better performance in the Placemaking and Local Government section.

3. Targeting ammonia abatement, in relation to emissions from fertiliser, digestate and animal husbandry types.

4. Air Quality Policy, Legislation and Governance in Scotland, Scottish Government, 2019,

5. Cleaner Air for Scotland: the road to a healthier future, Scottish Government, 2015.

6. CAFS progress reports 2016/17 and 2017/18, Scottish Government

7. Progress on the existing targets/objectives contained within the current CAFS strategy and an assessment of their status, 2019, Scottish Government;

8. Measures implemented as a result of the current CAFS strategy and their outcomes and impacts towards improving air quality, 2019, Scottish Government;

9. Air pollution: Our health still insufficiently protected, European Court of Auditors, 2018. See also Annex 4.

10. Clean Air Strategy 2019, DEFRA, 2019.

11. NMF modelling pilot report for Aberdeen; CAFS – National Modelling Framework Air Quality Evidence Report – Edinburgh, SEPA, 2019,

12. Air Quality in Scotland Inquiry, ECCLR Committee, 2017/18.

13. Air pollution: Our health still insufficiently protected, European Court of Auditors, 2018. See also Annex 4.

14. Europe’s urban air quality – re-assessing implementation challenges in cities, EEA, 2019. See also Annex 4.

15. Net zero: The UK’s contribution to stopping global warming, Committee on Climate Change, 2019; including reference to the advantage of net-zero approach to improving air quality.

16. Final assessment: The first Scottish Climate Change Adaptation Programme, Committee on Climate Change, 2019; Table 1 includes reference to air pollution, somewhat minimally and indicates in the Society Adaptation priority, “mixed progress”.

17. CAFS Review Working Group reports

18. National Atmospheric Emissions Inventory, 2018.

19. Scottish Government, 2018,

20. State of air quality, environment and pollutant trends in Scotland, SEPA, 2019;

21. Health and Environment Working Group Membership can be found in Annex 2

22. Health and Environment Working Group Report;

23. Air Quality in Europe, EEA, 2018

24. Review of evidence on health aspects of air pollutionREVIHAAP Project, WHO, 2013

25. Reconsidering the Relationship between Air Pollution and Deprivation, Bailey et al, 2018, Int. J. Environ. Res. Public Health 2018, 15, 629

26. Association between active commuting and incident cardiovascular disease, cancer, and mortality: prospective cohort study, 2017, Celis-Morales et al., BMJ 2017; 357: j1456.

27. Active commuting and cardiovascular risk: a meta-analytic review, 2008, Hamer and Chida, BMJ 2017;357:j1456.

28. Systematic review and meta-analysis of reduction in all-cause mortality from walking and cycling and shape of dose response relationship, Kelly et al., 2014, International Journal of Behavioural Nutrition and Physical Activity. 2014 11:132.

29. Change in commute mode and body-mass index: prospective longitudinal evidence from the UK Biobank, Flint et al., 2016, The Lancet. 2016; 1:e46-55.

30. Effect of increasing active travel in urban England and Wales on costs to the National Health Service, Jarrett et al., 2012, Lancet. 2012; 379(9832): 2198-205

31. Can air pollution negate the health benefits of cycling and walking? Tainio et al., 2016, Preventive Medicine. 2016 87:233.

32. Public Attitudes to Air Quality, DEFRA, 2018

33. Environmental Noise Guidelines for the European Region, WHO, 2018

34. Noise statistics, Scottish Government, 2012

35. Road traffic noise is associated with increased cardiovascular morbidity and mortality and all-cause mortality in London, Halonen J et al, 2015

36. Air pollution: outdoor air quality and health, NICE, 2017

37. Scottish Transport Statistics No. 37, Transport Scotland, 2018

38. CAFS Climate Change Sub-group 2016,

39. Gasping for Air, Curran J., The Ecologist, 2019

40. Workplace exposure limits, HSE, 2018

41. Modelling Relationships between Indoor and Outdoor Air Quality, Friejer and Bloemen, 2000, J. Air & Waste Management Assocn. 50:292-300.

42. There is potentially an all-users dimension to this issue as well as heightened risk for vulnerable passengers or drivers as well as Health and Safety and employment law dimensions for bus, haulage and other business employers if drivers are potentially exposed to dangerous pollution. This may be an issue likely to benefit from a collaborative research approach.

43. This would assess the home environment where someone might experience relatively clean air for 9-18 hours per day, through a commute by bike, car, bus, train or on foot, to a relatively clean or air conditioned work environment or school through a return commute and an evening in a public or private environment or in a street café with passing traffic and so on. Real exposures could be highly diverse and both peak pollution impacts and longer-term cumulative exposures could be relevant to health impacts, subject to prior health state and risk factors. Whilst highlighting the complexity of the situation, such work would offer assessment of boundary conditions for future policy effort.  This could also offer ideal opportunities for collaborative, multi-disciplinary international research.

44. Transport emissions and issues are addressed in Section 7.

45. AIDE Working Group membership is listed in Annex 2

46. AIDE Working Group report,

47. User surveys being completed in 2019 should deliver new information to produce a more accurate current figure than the 2015 BEIS survey.

48. Scottish Pollutant Release Inventory, SEPA

49. AIDE Working Group report


51. Air Pollutant Inventories for England, Scotland, Wales, and Northern Ireland: 1990-2016, National Atmospheric Emissions Inventory, 2018

52. All data are from 2016 unless otherwise stated.

53. See AIDE Working Group Full Report for a detailed overview on international and national policies addressing agricultural ammonia emissions

54. Code for Good Agricultural Practice for Reducing Ammonia Emissions, UNECE, 2015

55. Options for Ammonia Mitigation, UNECE, 2014

56. Code of Good Agricultural Practice (COGAP), DEFRA, 2018

57. Air Pollution from Agriculture, DEFRA Air Quality Expert Group, 2018

58. The impact of ammonia emissions from agriculture on biodiversity, Guthrie et al, 2018

59. Costs of Ammonia Abatement and the Climate Co-Benefits, Reis et al, 2015

60. Applying a process-based livestock model to predict spatial variation in agricultural nutrient flows in Scotland, Leinonen et al, 2019, Journal of Cleaner Production, 209:180-189

61. PEPFAA, Scottish Government, 2005 2.9/2.32 – ammonia; 2.19 nitrogen use



64. Targeting ammonia abatement, in relation to emissions from fertiliser, digestate and animal husbandry types.

65. Whether with current or future EU Directives or in relation to UK or Scottish air quality standards and limits drawn from international, general or local provisions.


67. Ricardo and Emission Analytics are using remote sensing equipment and compiling databases of vehicles and real-world emissions based on roadside monitoring. See e.g.

68. Transport Working Group Membership can be found in Annex 2

69. Transport Working Group report

70. Cleaner Air for Scotland: the road to a healthier future, Scottish Government, 2015

71. Lifestyle, efficiency and limits: modelling transport energy and emissions using a socio-technical approach, Brand, C. et al, 2019, Energy Efficiency, 12: 187-207.

72. CAFS – National Modelling Framework Air Quality Evidence Report – Edinburgh, SEPA, 2019,


74. Data provided by the main 9 bus operators in Scotland, at 17 April 2019, covering c 85% of all commercial mileage showed 1064 units now EURO VI, representing 26.8% of the fleet. Of the total of 3959 units, a further 121 were hybrids (98), hydrogen (10) or full electric, and 34.9% EURO V.

75. Evaluating the impact of a workplace parking levy on local traffic congestion: The case of Nottingham UK, Dale, S. et al, 2017, Transport Policy, 59: 153-164.

76. Sustainable Vehicles-Based Alternatives in Last Mile Distribution of Urban Freight Transport: A Systematic Literature Review, De Oliveira, C. et al, 2017., Sustainability, 9, 1324; doi:10.3390/su9081324

77. E-bikes in the Mainstream: Reviewing a decade of research, Fishman, E., Cherry, C., 2016. Transport Reviews, 36(1): 72-91.

78. We highlight that the Freight Transport Association did not support this recommendation.

79. Dec 2024 is a critical environmental compliance date including concerning LEZ full implementation. The National Infrastructure Commission for Scotland will be making recommendations for the period from 2024 and we would expect the National Transport Strategy in its next form as well as the Investment Plans that follow will shape road network developments. In terms of the current Infrastructure Investment Plan, it would seem that the A9 and A82 project should be (largely) complete. Consideration would have to be given to dualling the A96 and potentially other intercity routes previously identified as strategic commitments. Examination of regional benefits and projects already in the Infrastucture Investment pipeline will be needed.

80. Does Reducing Journey Times Improve the Economy – and, if not, what are the Implications for Transport Assessment? Rye T. and Scotney D., 2011, Paper to Scottish Transport Applications and Research Conference, Glasgow.

81. The NSL (Nationaal Samenwerkingsprogramma Luchtkwaliteit) is a statutory programme that coordinates the Dutch government’s work on air quality. It requires all levels of Dutch government to work together to carry out air quality improvement duties. The objective of the NSL is to deliver compliance with air quality standards and to ensure that development does not adversely affect current and future compliance. The NSL has created a national model of air quality, similar to the planned regional NMF set out in CAFS, however the NSL approach also coordinates the collation of traffic data, which is the big limitation to the development of the regional NMF. In addition the NSL identifies early in the planning process any spatial developments that could potential make a significant contribution to air pollution through scale and increased traffic-related effects. This results in direct requirement to include mitigation measures to maintain or improve air quality before approval can be granted. The model used within the NSL is developed and maintained centrally, built using robust traffic data, emission and air quality monitoring data. The model is updated annually to take account of new monitoring (air and traffic) data and developments/mitigation measures.

82. Europe’s urban air quality – re-assessing implementation challenges in cities, EEA, 2019. See also Annex 4.


84. Membership of the Placemaking working group can be found in Annex 2; also see the full Placemaking Working Group report.

85. Placemaking Working Group report

86. Creating Places – A policy statement on architecture and place for Scotland, Scottish Government, 2013


88. CAFS Project, Place Standard Air Quality pilot, PAS, 2018

89. Place Principle, introduction, Scottish Government, 2019. See also Annex 8

90. See also Annex 9/ the full working group report

91. See also Annex 9/ the full working group report

92. Place-based Approaches to Joint Planning, Resourcing and Delivery: An overview of current practice in Scotland, The Improvement Service, 2016

93. Health Impact Assessments in Planning Toolkit, Worcestershire County Council, 2016

94. Supplementary Guidance: Air Quality and planning (consultation draft), Perth and Kinross Council, 2019

95. Planning, economy, place: literature review, Scottish Government, 2019; Public Health Priorities for Scotland, COSLA, 2018

96. Submission from a meeting of SOLACE and others responding to the Infrastructure Commission for Scotland’s Call for Evidence.

97. Air Quality Policy, Legislation and Governance in Scotland, Scottish Government, 2019;

98. Current powers emanate from EA95 and require Ministerial permission. Delegation of this power would streamline procedure and hasten improvement.

99. Some have already dubbed what needs to happen next as CAFS2. This is possible of course but a simpler or new brand might arguably be better.

100. Given recent developments as well as legitimate locus, SOLACE and CoSLA engagement would be vital. This could be supplemented too by periodic input from REHIS, SCOTS, HOPS, etc. as well as those best placed in the reformed Public Health Scotland arrangements.



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