Cleaner Air for Scotland strategy: independent review

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

3. Introduction

Mission and SCoPe

3.1 Late last year the Scottish Government decided to undertake a review of its air quality strategy ‘Cleaner Air for Scotland – The Road to a Healthier Future’ (CAFS) which was published in November 2015. The review was a commitment in the 2018/19 Programme for Government and was launched by the Cabinet Secretary for the Environment, Climate Change and Land Reform on 6 November 2018. A Steering Group and an independent chair were appointed and tasked with reviewing the progress of the CAFS Strategy to date, assessing the current state of Scotland’s air quality and possible future trajectories, identifying evidence and activity gaps and finally, providing advice and recommendations on priorities for further action.

3.2 The Steering Group has shaped the content of the review and agreed to the establishment of four specialist working groups to examine specific areas of interest. The review sought to cover transport, industrial, domestic and agricultural emissions as well as health, planning and relevant business issues. Membership reflected expertise from a range of disciplines and perspectives in these fields, drawing on deeper technical support and detailed input from the working group members and one off inputs from specific individuals and sources. The composition of the groups and process followed as well as the launch and other sCoPing materials are presented in Annexes 1 and 2.


3.3 The policy and legal framework for managing air quality is complex and responsibilities lie with a number of bodies. A useful background paper was prepared by the Scottish Government to summarise the position[4]. This paper describes the main aspects of air quality protection and improvement, and where strengths and weaknesses may exist. An overview of the key statutory measures, policies and programmes framing air quality in Scotland is also provided in Annex 3.


3.4 CAFS was published in November 2015[5]. The strategy sought, for the first time, to bring together the major policy areas relevant to air quality - climate change, transport, planning, health and energy - within one overarching framework. CAFS sets out around 40 actions relating to these policy areas, with the primary focus being on urban air quality. The strategy also covers the LAQM system. Progress in delivering the CAFS actions is summarised in a series of annual reports[6].

CAFS Implementation

3.5 CAFS was described as a national cross-government strategy setting out “how the Scottish Government, working together with partner organisations across the public and private sectors, will deliver cleaner air across Scotland, in order to help create and maintain a strong, healthy and fair society that is capable of living within environmental limits.” Its ambition was to achieve integration and coherence across government. It stated “Scotland’s air quality will be the best in Europe”.

3.6 In the last three years, regular meetings have taken place of the CAFS Governance Group established to oversee delivery and several subgroups focusing on specific issues. Progress has been made by the various actors identified in the strategy on the 40 or so actions set out. Progress has been presented in annual reports and various quarterly and periodic reports and updates within the governance structure. This is set out in Scottish Government reports and overview documents.[7]

3.7 In summary, 14 actions out of 40 are complete, 12 are ongoing with revised timetables, two are partially complete, three are on hold, eight are ongoing and on schedule, etc. All identified actions were and are expected to be completed by the end of 2020.

3.8 It should be recognised that many actions listed within CAFS were contributed to or by other Government strategies (e.g. National Transport Strategy, Cycling Action Plan etc.) and so CAFS should not be viewed in isolation. This also demonstrates the cross-disciplinary nature of CAFS and acknowledges that many of the solutions to improve air pollution cut across a number of policy areas. Measures have also been developed outwith the CAFS process, primarily the Programme for Government commitment in 2017 to the development of Low Emission Zones (LEZs) for Glasgow, Edinburgh, Aberdeen and Dundee by 2020 and other locations by 2023 (where evidence demonstrates the need).

3.9 An assessment of the measures involved and their impact is given in a Scottish Government overview document.[8]

Relevant major events since 2015

3.10 Although CAFS is less than four years old, there have been significant policy developments during this period which have implications for the future direction of the strategy.

3.11 Whilst not intending to be a comprehensive research report on the issues framing this review, a number of significant developments over the last four years are relevant:

  • EU Court of Auditors Report, “Air Pollution: Our health still insufficiently protected”, September 2018[9].
  • Client Earth cases - Supreme Court case against UK Government April 2015 for the lack of an overall compliance delivery plan and failure to achieve minimum standards, and High Court case February 2018 - against the inadequacy of “illegal air pollution plans” by local government.
  • UK Clean Air Strategy[10], published by DEFRA in January 2019 (which, labeled a UK Strategy, principally proposed a range of new arrangements and initiatives, new England-wide and local powers and controls and Clean Air Zones in England.) Much of what is proposed in Chapter 7 aligns with Scotland for transport and industrial issues. Proposed actions for agriculture and domestic combustion are of particular interest to the Scottish context, including permitting the dairy and beef sectors, controls on manure application, further codes of practice for “low emission farming”, ammonia management and guidance on fertiliser use. For domestic burning, new enforcement powers for local government as well as actions on Ecodesign of stoves and fuel quality controls were proposed.
  • Initial stages of implementation of Glasgow LEZ in December 2018, principally seeking to transform the bus fleet and enhance streetscapes.
  • Modelling pilot report for Aberdeen, modelling development projects for LEZs proposed for the four cities and CAFS National Modelling Framework Report[11].
  • Fleet changes (new Euro VI vehicles) for Scotland’s private bus fleet.
  • Progressive electrification of central Scotland’s rail network during 2018 and 2019.
  • The Scottish Parliament’s Environment, Climate Change and Land Reform Committee Inquiry on Air Quality during 2017/2018[12].
  • VW/”DieselGate” – the reforms and profile given to the issue of false emissions data initiated by the US EPA’s notice of violation of the US Clean Air Act against VW in September 2015 has been considerable. A range of consequential changes in engine management and design, data availability and actual emissions performance measurement and reporting etc. as well as a shift for passenger vehicles away from diesel engines has continued to flow from this origin.
  • Completion of some major road network developments, including Queensferry Crossing, Clackmannanshire Bridge, Aberdeen Western Peripheral Route (City Bypass/AWPR) and parts of the A9, M8/M73/M74, etc.
  • Reorganisation of public health bodies in Scotland towards the creation of Public Health Scotland.
  • The next EU Environment Action Programme, due to run from 2020, is likely to consider progress on air pollution across Europe, including taking account of the findings of the EU Court of Auditors report[13].  A more recent report by the European Environment Agency (EEA) on urban air quality implementation challenges[14], provides further context.
  • Recent progress and announcements on climate change – notably the declaration of a “climate emergency” by the Scottish Government - are also relevant.
  • Uncertainties around the UK’s exit from the EU remain at the time of writing. The Scottish Government has committed to remaining aligned with EU environmental regulation in any circumstances. However if there are changes to EU membership and compliance standards etc. over the implementation period for the CAFS review there will be implications for the recommendations in this report.

This Review and Report

3.12 In the report that follows, the aim is to set out the status of CAFS now; consider why it is important that we continue to act; present and analyse the current air pollution drivers, state and apparent trajectories; consider the causative components and issues identified and then set out actions we would recommend to address these. The sCoPe of CAFS moving forward has also been broadened to consider the wider impacts of air pollution on the environment as a whole, rather than the previous focus on urban air quality (although improving urban air quality is still a key area for action).

Assessment of Progress and Lessons Learned since late 2015

3.13 The actions already taken and underway, through CAFS and local government action plans, have resulted in welcome progress towards lower pollution levels in most areas.

3.14 Within the constraints of available data (whereby 2016 EU compliance data have just been published in May 2019), in the last four years, using LAQM data, we have seen broadly continuing trends of modest reductions in pollutants, with local and temporary elevations, apart from in ammonia where there have been modest rises.

3.15 Arguably, albeit new policies and measures have been constructed which complement air pollution effort in transport planning and land use planning (such as the revision of the National Transport Strategy and the Transport and Planning Bills), there are still steps to be taken to achieve a more fully cohesive system. Actions taken to tackle climate change should also contribute favourably to reducing air pollution[15],[16].

3.16 Some of the causative drivers of change - the closure of large combustion plants and continued regulatory management of other emissions, continuing rail electrification, bus fleet renewal and new Euro IV/V/VI uptake across all vehicles, increases in active travel etc. - will continue to deliver improvements over coming years subject to actual rates of change and other factors such as car numbers and goods and bus fleet replacement, engine mix and numbers, etc.

3.17 However, in spite of recent progress, a number of questions still need to be raised, for example:

  • Is this progress far or fast enough?
  • Will congestion and vehicle numbers overall, contributing to pollution loads, rise or fall?
  • What impact will the Glasgow LEZ have and how will the four cities’ LEZs work together to influence the general transport picture and impact pollution overall?
  • Will other sources of pollutants, especially particulates, result in further reductions being slower or harder to achieve?
  • Why is ammonia such a notable exception to the general downward trend?



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