Cleaner Air for Scotland strategy: independent review

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

2. Summary of Recommendations

General Recommendations

A number of general recommendations arose from the Review:

1. A Precautionary Approach. The health evidence reviewed justifies adopting a precautionary public health approach to air pollution reduction. As a minimum, compliance is required with international air quality limits, including the WHO guideline standard for PM2.5, and practical efforts to reduce preventable air pollution further should continue.

2. Integrated Thematic and Organisational Strategies. Where strategies, policies and plans are being devised at national and local levels for climate change mitigation and adaptation and related purposes such as noise reduction, they should be closely co-ordinated and aligned with air quality action plans and with each other in order to maximise co-benefits. It is also clear that local government, which has major Local Air Quality Management (LAQM[2]), transport delivery as well as planning, public health and regulatory roles must act in a more coherent manner to ensure strategies and plans fit together and cross-professional and functional effort is strongly aligned. Similar integration is needed within central government too.

3. Impacts of New Developments. To protect against future health and environmental impacts generally, consideration should be given to a presumption that any major new development (e.g. a new road or housing development) must not lead to a net increase in carbon emissions, must not worsen air quality, and must not exacerbate existing health inequalities.

4. Better Data. The quality and coverage of data available on transport, environmental emissions and conditions, as well as on health all require consideration. Continuous and detailed traffic data would allow better modelling and management arrangements and appropriate interventions. Similarly high quality, reliable, well distributed, located and managed monitoring data on emissions and air quality across Scotland, available to all and in close to real time would allow not just good public information but good modelling, reporting and interventions on important issues. Health data also require careful consideration so that Scotland-specific interpretations, plans and interventions are strengthened.

5. Behavioural Research. Research is needed to provide clear contemporary Scottish evidence drawn from population representative information on levels of knowledge, attitudes, and levels of concern related to air pollution, as well as on willingness to change air pollution related behaviours. Behavioural insights around car use in particular continue to be vital if significant reduction is to be achieved.

6. Environmental Regulation. In relation to current and future environmental regulation, the requirements of European Union (EU) legislation on industrial and other relevant emissions control which have been transposed and implemented into domestic legislation should be retained and new EU requirements should continue to be implemented to provide as high a level of protection of Scotland’s environment as possible. High levels of compliance are to be expected and should be consistently achieved. It may also be beneficial to review whether all relevant sectors are subject to regulation and at the right level and in the right way to address air pollution pressures.

7. Tackling Under-regulated Areas: Domestic Burning and Agriculture are two sectors not considered in the 2015 CAFS strategy, but which this review has found, based on the evidence, to be significant contributors to air pollution in Scotland. Further developments of CAFS should include an appropriate Scotland-wide set of plans to improve the arrangements for regulating and managing domestic and agriculture sector emissions. Performance of domestic fires and stoves, appropriate fuel attributes and local authority powers to permit and control these issues as well as the management of farm fertilisers and manures, etc. have the potential to deliver significant improvements in air pollution beyond current regulatory and management approaches. Practical proposals are presented for these two areas in the recent DEFRA Clean Air strategy, which this review has concluded could provide a sound basis on which to build in Scotland.

8 Shifting to More Sustainable Transport Modes. It appears key to progress on transport emissions that modal shift to sustainable means is achieved. Efforts need therefore to be focussed generally on demand management, reducing personal private vehicle use as a priority. This will require strong leadership and clear understanding of demand management and behaviour change issues and the most effective interventions. It should also mean that, although not solely relying on technological solutions, we embrace new technologies, better public provision and constraints upon private use, especially in urban centres where pollution and congestion are most acute. Managing down aspects of traditional supply is necessary, as it is strongly suspected that new road building signals the acceptability of, and provides the opportunities for expanded use. Managing demand will therefore have to run alongside investment connected with safety, maintenance and modal accommodations, especially in rural areas. It is important too that existing complementary transport strategies, on cycling, walking, “Switched On Scotland”, etc. as well as plans for the freight sector are meaningfully integrated with proposals and plans for the bus and other sectors. Scottish Government and Transport Scotland should ensure appropriate leadership and an integrated approach to strategy are provided through the completion and delivery of a genuinely broad and transformative second National Transport Strategy, aligned with this review, and a set of Delivery Plans and Investment Programmes that reflect its spirit and detail into implementation.

9. Governance, Accountability and Delivery. Simple and effective governance arrangements and a real focus on practical joined-up delivery is imperative. The mission of further improving air quality is complex, involves many delivery and stakeholder bodies and affects all of us. With relatively scarce resources and separate delivery bodies it is essential that the final agreed implementation strategy for the next stage of CAFS makes it clear who is doing what, who is leading, who is supporting and who is ultimately responsible. Specific encouragement as well as supportive arrangements will be essential if a coherent integrated and successful strategy is to be delivered and seen to be delivered.

10. Further Progress Review. A review of progress on air pollution should be conducted no more than 5 years hence. This should occur prior to the end of 2024/25, in order to track and consolidate LEZ progress and general compliance in Scotland as well as allowing Scotland to keep abreast of changes in both societal attitudes, sector performance and technology. Remaining challenges and actions should be identified.

Specific Recommendations

The summary of specific recommendations which follows sets out how the general recommendations can be delivered.

Health (H)

1/H1. Further consideration of evidence on health impacts of low level pollution in countries with levels of ambient air pollution comparable to Scotland is needed.

2/H2. 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.

3/H3. An Air Pollution Action Plan aligned with CAFS should be developed and implemented with actions and investment, focussed on joint actions across all relevant government departments, agencies and local government functions to increase levels of active and sustainable travel. This should include integrated and complementary approaches to improve air quality, to reduce carbon emissions and to reduce related health inequalities.

4/H4. It is strongly recommended that, at all levels of governance, when actions are being taken to address air quality then they be screened to maximise the potential for co-benefits with climate change mitigation and adaptation. The reverse should also be the case. The screening should, at minimum, be against the 50 recommendations in the CAFS Governance Group (CAFS GG) Report on the likely co-benefits between climate change and air quality improvement actions.

5/H5. It is strongly recommended that a task group be convened to identify what, if any, actions might best be undertaken at Scottish level to address the issues associated with indoor air pollution.

6/H6. Consideration should be given to research on in-vehicle exposures and potential health impacts to provide a factual baseline

7/H7. Consideration should be given to a “habit survey” type assessment of actual exposures experienced by a representative sample of the population, assessing pollution exposures over a realistic “normal activity range over a normal period”.


Domestic Emissions (D)

8/D1. Implement a package of recommendations on domestic burning emissions in Scotland, similar to that recommended in the DEFRA Clean Air Strategy, including: the implementation of Ecodesign (ED); voluntary codes for stoves; appropriate standards for fuels (including regulation of wood for use in woodburners, house coals and arrangements for own-resource wood burning), and education to inform consumers.

9/D2. Consider with local government and SEPA how best to address the current permitted development status of flues for woodburning stoves and biomass boilers and incorporate permissions into development control and monitoring.

10/D3. Commission further work to clarify the level of PM (and other relevant) emissions in Scotland and the percentage attributable to domestic burning. This will require re-evaluating the volume of wood burnt.

Industrial Emissions (I)

11/I1. Build on SEPA’s sector plan approach to further reduce emissions where “beyond compliance” measures may be required to achieve these (e.g. NMVOCs and NH3) and seek to include any further air pollution sources or hazards identified.

12/I2. Consider inclusion in regulation of mobile and non-road plant emissions (road cutting, surfacing, digging, traffic management machinery and diesel and other generators etc.), especially given potential local impacts.

Agricultural Emissions (A)

13/A1. As a minimum, Scottish Government should urgently work together with SEPA and the agricultural industry to develop a voluntary code of practice (CoP) for Scotland. This should incorporate recent data from the UK agricultural ammonia emissions inventory, use relevant Scottish data, address management practices[3] and seek to engage the agriculture sector to achieve best delivery. The CoP should be subjected to an early review process to assess its effectiveness and compliance. If the review highlights through appropriate monitoring an inadequate impact, direct regulatory intervention should be considered.

14/A2. Scottish Government should undertake work on habitats and emissions to set appropriate targets in the current context of the UK reporting on the National Emissions Ceilings Directive (NECD). Consider related improvements to the current site condition monitoring of designated conservation sites, to improve on current method, which doesn’t detect air pollution effects and assess current terrestrial ecosystems monitoring to ensure it is fit for purpose.

15/A3 A specific assessment is needed of visible smokes and their health and amenity impacts. This should include both muirburn and stubble–burning. A specific assessment of pollution characteristics and downwind impacts into populated areas should be considered, along with appropriate management responses and interventions.

Transport (T)

16/T1. A robust commitment is needed on data and research support for transport planning. Consideration should be given to specific investment in transport supply and demand research. Additionally, both current pollutant and impact data capture should be reviewed and a commitment is required for continuous transport data provisionfrom the range of relevant locations across Scotland, building on the findings identified in SEPA and partners’ National Modelling Framework (NMF) work.

17/T2 The implementation of a second National Transport Strategy should lead to a permanent preference for more sustainable transport modes and infrastructure investments. Serious consideration needs to be given to reductions in trunk and motorway route expansion and priority given to electric and low emissions infrastructure and services for rail, bus and goods segments. A focus on reducing vehicle numbers, supporting electric and low emission vehicles and tackling congestion issues caused my private vehicles is necessary. There should also be further and coherent, expanded support for cycle and pedestrian/active modes.

18/T3. Encourage the introduction of a workplace parking levy in LEZ areas. Consider use of funds generated for improvements in sustainable transport provision.

19/T4. Develop and communicate a Transport and Mobility Hierarchy applied to public policy and individual behaviour.

20/T5. Economic stimulus for scrappage of the most polluting vehicles with behaviour change focus including options for e-bikes, public transport season ticket contributions and other incentives which reduce car ownership.

21/T6. Consider appropriate incentives for cycle, electric cargo and other “last mile” vehicle delivery approaches and appropriate supportive infrastructure.

22/T7. Greatly increase bus-based Park and Ride provision alongside LEZs with chargers for electric/plug-in hybrid vehicles and appropriate fiscal charging for more polluting vehicles.

23/T8. Spatial planning and transport planning need to work together to be effective in ensuring local decision-making does not undermine national objectives for air quality.

24/T9. Make Supplementary Planning Guidance on Air Quality mandatory.

25/T10. The revised CAFS should have a commitment to a nationally funded and coordinated programme of citizen science and community engagement developed to improve the understanding of air pollution and how citizens can make informed decisions to reduce their impacts on the environment and improve their health.

Placemaking (P) and Local Government (LG)

26/P1. Urgent consideration should be given, by Scottish Government and Local Government, involving all relevant functions, to how to achieve a pragmatic and integrated strategy for placemaking in policy-making and implementation generally.

27/P2. Local government should examine its functions and consider how to ensure better recognition and integration of the different disciplines and inter-connected policy and delivery areas related to air pollution.  Stronger alignment of functions and better engagement between them would more effectively and efficiently deliver air pollution reduction actions and benefits.

28/P3. A review and report on current air quality policy effort in local government should be undertaken. This would provide a clear map of who is doing what, how it is working and how linkages are being applied across local authorities.

29/P4. A forward plan for how local government engages, delivers, measures progress, resources and communicates in relation to placemaking and delivering change on air pollution issues is needed. This would address Delivery, Governance, Performance and Communications issues.

30/LG1 Realising effective Placemaking in practice – much of which relates to a higher degree of coherence in the land use planning system in strategic and development planning terms combined with aligned development management/control processes. Commitments to, and processes to achieve, integration will be needed.

31/LG2 LEZs. The four first round LEZs need to follow legal and policy timetables and be in place and delivering within four years. Visible commitments to this and evidenced delivery will be required.

32/LG3 Local Air Quality Management. Where AQMAs have been declared, these need to have active plans that deliver the intended outcomes within a reasonable timetable.  When done they need to be revoked. If not delivered, powers of intervention by SEPA/Scottish Government can and should be applied. Also issues of permitted development and domestic combustion, and public health, etc., as well as identified increasing pressure from wood burning stoves, for example, or previously approved developments that have not yet been implemented but where no public transport or active travel provision was made, highlight specific policies that may require to be addressed for local air quality.

33/LG4 Robust monitoring and reporting. A review of air quality monitoring may be needed to ensure that we are consistently gathering meaningful data in a uniform and appropriate way to meet current EU and Scottish/UK requirements as well as being future-proof in both a Brexit context and in relation to such future Scottish Government environment and climate strategy as may apply.

Behaviour (B)

34/B1.Specific demand assessment and behavioural research should be commissioned. This should then be integrated into strategic mobility planning and delivery effort as well as with work to establish how the public would wish to engage in future developments. This could be integrated too with efforts at developing an engaged approach to placemaking.

Governance (G)

35/G1. Implement the suite of improvements suggested on LAQM arrangements.

36/G2. Establish a broad(er) ministerial group, meeting regularly to oversee the delivery of the new air quality strategy. This group would ideally be led by the Cabinet Secretaries for Environment, Climate Change and Land Reform (ECCLR) and Transport, Infrastructure and Connectivity (TIC) (and periodically Health and other relevant portfolios) as well as appropriately senior local government representatives and would be attended by senior officials from relevant areas (e.g. health, planning, etc., as appropriate) and SEPA, and external advisors. This oversight model would be supported by an appropriately resourced officer body to bring and take advice and action reports as well as escalate action delivery and performance issues to the ministerial group.

37/G3. If the current CAFS Governance Group is to continue it should be called an Advisory or Working Group and adopt a clear remit, including a description of how its advice is conveyed to Scottish Ministers and/or serve as described at G2. The group will need a clear remit, clear performance targets and key performance indicators (KPIs) and appropriate authoritative membership, reflecting the stakeholders needed, not least representation from across the powers and responsibilities of local government.

38/G4. Given the multi-departmental and multi-organisational dimensions of policy and implementation responsibility, there may be merit in considering independent chairing and appropriate overall accountability for progress of these groups.



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