Leeds City Council                            AIR0060

Written evidence submitted by Leeds City Council

Response collated by Andy Hickford – Senior Project Manager (Climate, Energy & Green Spaces, Leeds City Council)

Inputs from CEGS Strategy & Communication Manager, Public Health Leeds, LCC Environmental Health Manager.

Questions answered:

What are major barriers and challenges to achieving national targets on air quality?

• The main barriers and challenges to meeting the PM targets is the lack of sufficient action to date to tackle emissions from domestic burning, lack of ring-fenced resources for Trading Standards and Environmental Health teams to take enforcement action to the extent that would have a deterrent effect, lack of clarity around the reform of the Planning system which could play a significant role in reducing emissions from transport and buildings, and a lack of action to address pollution caused by agriculture and horticulture which is significant.
• Local authorities compliant with legal air quality limits currently have little or no direct incentives to further tackle the sources of air pollution, yet a significant proportion of the air quality experienced by any district will have originated somewhere else, especially in the case of PM. The Government should publish stretch targets, informed by the work of the World Health Organisation, and support local authorities to continue prioritising action on air quality beyond the national targets. Doing so would also support efforts for the UK to achieve its target for population air pollution exposure.
• It is vital that efforts to tackle PM are managed in partnership with cross-border stakeholders too. The trans-boundary impact on PM means that more than just local action is required, as such the risk of localising action and targets risks missing the wider actions that are needed to be carried out by stakeholders who act outside of local authority reach.

• There may be a need for DEFRA to calculate and disclose the estimated contribution to pollution from natural/external or trans-boundary sources/causes every year alongside their annual statistics so that actions can be appropriately targeted. If the bulk of PM, for example is identified as being trans-boundary, local measures may have a limited impact. Effective action must be based on data and identification of causes/sources of pollution.

Does the Government provide sufficient funding and devolved powers to local authorities in England to improve local air quality? If not, what additional funding or devolved powers are required?

• There may not be an issue so much with devolving powers to LA’s, rather than national monitoring of air pollution needing to be made consistent. The benefits of effective handling, processing and analysis of that data can be optimised to model the changes that need to be made and inform strategy nationally. Government could review their entire approach to consider whether there are any changes that would improve the consistency, representativeness, and usefulness of the outputs of monitoring. Monitoring has the potential to achieve three aims—helping to determine population exposure to pollution, helping us better understand the sources of pollution, and supporting public engagement with air quality to support behaviour changes—but it doesn’t seem like the current approach is optimised for these. Strategy should follow data – rather than develop strategy and then create ways to measure if the strategy is delivering change. Nationally - enhancing monitoring would better inform the policies needed, data will inform what pollutants are present, where, their causes and how they need to be tackled.

• The Government could better resource Planning, Trading Standards, Environmental Health, and Public Health teams to enable local authorities to take more actions to improve air quality. They could also better resource the Environment Agency teams responsible for enforcing pollution control on larger buildings. They could also publish guidance clarifying the role they expect of local authorities to support the delivery of the Agricultural Transition Plan to help reduce emissions, pollutions, or carbon. Government should also review whether the relevant local authority teams (e.g., Asset Management, Parks) have the appropriate resources and knowledge as part of any guidance development.

• Fundamentally the nature of air quality monitoring, both indoor and outdoor needs to be updated in line with advances in technology and understanding of the issues. Greater granularity of data needs to be developed through increasing the concentration of monitoring equipment, with a concerted effort to consider how indoor air quality can also be assessed. There needs to be support for local authorities to be able to develop improved monitoring networks and support for creating national, data sharing models that allow for this data to be effectively utilised.

How well is the Government spreading awareness of the impacts of poor air quality and promoting action being taken to tackle the issue?

• Government should evaluate the effectiveness of the ventilation campaign that ran nationally as part of the COVID response and then re-launch a similar campaign to encourage uptake of ventilation behaviour changes that reduce exposure to air pollution indoors.

• Government should fund a trial of indoor air quality monitors in public spaces, particularly those most likely to be visited by vulnerable/at-risk individuals, to better understand the scale of the risk in these spaces and whether statutory or non-statutory limits for indoor air quality should be introduced.

• A public health campaign similar to those for seat belt use, or smoking in public spaces should be undertaken to enhance understanding of the impacts of poor air quality as well as advise on how to take action to reduce emissions and reduce exposure.

• I am not aware of any public communications explicitly related to air quality, funded by the Government, except in Clean Air Zones and those areas which have won grant funding. I believe that most citizens have a very limited understanding of outdoor air quality and negligible understanding of indoor air pollution.

What steps can the Government take to improve indoor air quality?

• Funding to create a network of indoor air quality monitoring especially in public spaces (hospitals, schools, GP surgeries etc). It is difficult to know how big a problem indoor air quality is and how to land messages without knowing what the main pollutants of concern are etc. The only way to get this information is it have better indoor AQ monitoring networks and then effective sharing of the data nationally to allow for profiling, modelling, and analysis to determine the actions needed to improve the quality of the air.
• Additional legislation on planning conditions regarding ventilation, use of gas for heating and cooking and other sources of indoor pollution need to be developed.
• Funding to improve housing conditions for those living with damp / mould and more legislation on the responsibility of private landlords to address these issues. Requirement for landlords to understand and monitor indoor air quality.

May 2023