Local Government Association                            AIR0073

Written evidence submitted by the Local Government Association

Outdoor and indoor air quality targets

The Local Government Association (LGA), on behalf of local government, welcomes the opportunity to respond to the Committee’s inquiry into outdoor and indoor air quality targets.

Air pollution pollutants including particulate matter (PM), carbon monoxide, ozone, nitrogen dioxide and sulphur dioxide, as well as other chemicals and mould – damage lives with harmful effects on human health, the economy and the environment.

In the UK, air pollution is the biggest environmental risk to public health. Poor indoor and outdoor air quality can trigger and exacerbate a range of health conditions including respiratory diseases including asthma, ischaemic heart disease, chronic obstructive pulmonary disease, lung cancer, pneumonia, with certain groups, such as children, the elderly and pregnant women more susceptible to the impacts of poor air quality. The Office for Health Improvement and Disparities (OHID) estimates that the annual mortality of human-made air pollution is roughly equivalent to between 28,000 and 36,000 deaths every year. There are no safe levels of PM and impacts are observed below levels permitted by current legal limits. Deprived communities and those with existing health conditions are

disproportionately impacted by poor air quality and addressing it will be key to tackling health inequalities. As well as being more likely to experience poor health, deprived groups are also more likely live in areas with higher levels of ambient pollution and in poor quality housing with poor indoor air quality.

The Government’s Air Quality Strategy framework for local authority delivery highlighted the major sources of pollution: agriculture, industry, road transport, domestic appliances and burning. Councils are committed to improving air quality and limiting the impact of air pollution on their communities’ health. They have introduced a range of measures to tackle air pollution, such as clean air zones, encouraging the use of electric vehicles with recharging points, and facilitating a modal shift to active travel options. They are also investing in cleaner buses, managing borough-wide air pollution monitoring networks, planning for new developments and regenerating their places in ways that improve air quality, and engaging with businesses to increase awareness and reduce their environmental impact.

Councils are a key partner in reducing air pollution and have responsibilities to declare Air Quality Management Areas and publish action plans to resolve unacceptable levels of air pollution. They also have responsibilities for public health, and improvement of air quality is a key priority in local government strategies to tackle health inequalities.

Barriers to achieving national air targets on air quality

With regards to supporting the Government’s action to reduce harmful emissions, we agree that action needs to be taken by both central government, councils, individuals and industry to reduce harmful emissions and the impact on public health. However, local authorities are in a highly challenging position of trying to meet their statutory duties on air quality with few levers to manage the sources of pollution. Insufficient funding and national policy remain a major barrier to using any new duties to achieve national targets on air quality.

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For example, greater enforcement action to prevent engine idling or emissions from solid fuel burning would place further demand on existing limited resource budgets and staff time. The LGA has repeatedly raised concerns about the underfunding of local government’s regulatory services and the challenge of absorbing new regulatory duties without the ability to recruit more staff. We want to work with government on longer term plans that will place regulatory services on a financially stable footing and address the shortage of skilled staff.

Action against polluters by local councils is a priority. However, we do not believe that placing a statutory duty or targets on councils would be the right answer. This would only result in further-stretched resources as councils struggle to ensure attention to all services which councils and communities see as priority. Any statutory duty on councils would need to be accompanied by statutory powers to act against polluters and must be fully funded.

Instead, the Department for Environment, Food and Rural Affairs (Defra) should engage councils to shape a policy, delivery and investment framework to deliver outcomes around air quality and decarbonisation. This should be accompanied by long-term funding, which would enable local authorities to focus on delivering solutions to local circumstances and bringing expertise in-house, to effectively develop and deliver the pipeline of schemes required locally.



EV sales have grown well above projections and their growth risks increasing traffic levels by 22 per cent by 2060 (DfT National Road Traffic Projections 2022, core scenario). An OECD study found that when all particle sources associated with cars are counted, including secondary particles, EV cars contribute less PM2.5 and PM10 than diesel or petrol cars.

However, due to their weight and, through lower running costs, their higher mileage, EVs can still emit PM2.5 emissions from tyre and road surface wear. Therefore, road traffic needs to significantly reduce in towns and cities to hit national and local targets on decarbonisation, air quality and congestion. Local authorities need more support from central government in messaging, policy and funding to achieve this. Simply replacing expensive to run internal combustion engines (ICEs) with cheaper to run EVs in cities, is alone not the solution to achieving air quality targets.

The draft strategy implies that the Government would like councils to do more to deal with sources of PM2.5 emissions under its control. However, councils continue to lack adequate powers and funding to effectively decarbonise and reduce PM2.5 emissions within their local transport systems. It remains far too difficult for local authorities outside of Mayoral Combined Authorities to franchise local bus services, despite the potential of this to help upgrade bus fleets, improve services, and reduce carbon emissions. Greater consistency in Government policy and messaging would go a long way to delivering the desired outcomes, more efficiently and cost effectively.


The £3 billion funding and reforms promised to deliver better bus services under the National Bus Strategy remains, as identified by the Transport Committee, incomplete and underfunded even with the Government’s recent welcome commitment to 2025. The National Bus Strategy invited Local Transport Authorities (LTAs) to deliver Bus Service Improvement Plans to support a shift to greater public transport use, with an offer of £3 billion by the end of the Parliament. Rather than a national scheme, less than half of LTAs received any funding, while the total funding for the scheme ended up at just £1.1 billion after much delay. This will hold back the electrification of bus fleets and improvements in services that would help to reduce car trips and ownership rates that would contribute to PM2.5 and NOx reductions, especially in towns and cities. Future funding to councils for cycling and walking has also been reduced by over £200 million over the next two years, reducing the ability for councils to plan and invest in a pipeline of schemes to help increase

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active travel and reduce road traffic. At the same time the Government has continued to freeze fuel duty.


With clearer national guidance and adequate funding, local authorities could do far more to reduce air pollution produced through transport. The new Local Transport Plan guidance, which has yet to be published, should be the framework that guides local planning, intervention and investment into measures that reduce transport related PM2.5 emissions. Defra should be engaging with the Department of Transport to produce this guidance, to review the balance of measures to maximise the decarbonisation of transport, as well as limiting PM2.5 from electric vehicles (EVs) in towns and cities. The government should commit to using the new Local Transport Plan system to provide full five-year funding for local transport authorities with focused outcomes on improved accessibility, decarbonisation, and better air quality to enable investments in the cleaner car and non-car transport systems.


Domestic burning

In national emission terms (as opposed to urban pollution hotspots) approximately 38 per cent of particulate matter (PM2.5) is produced by UK householders burning wood, coal and other solid fuels in open fires and stoves.

The LGA supports measures in the draft Air Quality Strategy to reduce the sales of the most harmful types of solid fuels and make it easy for residents to choose the cleanest source of fuel. It is good that action has already been taken on the design of stoves and that Defra is looking at new standards for fuels entering the market. Defra could look at further measures to reduce harmful domestic burning, including further restrictions and educational campaigns to raise the awareness of the dangers and mitigating measures.

Councils can set up Smoke Control Areas (SCA) and new air quality enforcement powers will enable them to issue fines to households that break SCA conditions through domestic burning. There is an important place for enforcement action in tackling air pollution from solid fuels. However, this must be part of a broader package of measures that support manufacturers, retailers, and consumers to switch to cleaner fuels.

Any new air quality enforcement responsibilities for councils, such as those ambitions set out in the Environmental Improvement Plan to challenge councils to address areas of specific hotspots, must be supported with additional resources for local governments regulatory services to ensure they can be implemented effectively.


Councils, in having air quality duties, and as planning authorities, and as soon to have lead responsibility for developing Local Nature Recovery Strategies (LNRSs) will be important partners in creating approaches to land-use that balance the economic production and environmental impact. It is important the Environment Agency and Natural England properly engage with councils on these matters, and the development of LNRSs be the central local strategy shaping investments into the nature recovery and associated benefits such as improved air quality.

Indoor air quality

Exposure to mould and other indoor pollutants such as smoke and common household chemicals can have a serious and fatal impact on human health. The air quality strategy: framework for local authorities specifies that local authority teams, including environmental, planning, housing, health, and social care staff are aware of best practice on indoor air quality. The indoor air quality at home guidance on indoor air quality, produced by Public Health England (now the UK Health Security Agency) and the National Institute for Health and Care Excellence, provides a summary of actions that can be taken to improve air quality in the home. The government has recognised that there is a specific gap in guidance tailored

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to the housing sector. They are reviewing existing guidance on damp and mould and have committed to issuing new guidance later this year, which is welcome.

Councils are determined that all tenants should have the security of a safe, well-maintained and healthy home. Nearly a quarter of private rented homes do not meet basic decency standards. The LGA welcomes the Renter’s Reform Bill, which aims to help renters better hold landlords to account and redress housing issues more swifty. We also welcome the introduction of a legally enforceable Decent Homes Standard for the private rented sector.

Councils manage more than 1.6 million homes, carry out millions of repairs each year and invest billions in housing services. The majority of social housing landlords are responsible and provide high quality homes for people to live in, and councils are determined to ensure that poor conditions and repairs are swiftly and satisfactory addressed. The LGA is working with Government and professional bodies on possible solutions to poor housing conditions, including to address damp and mould.

Sustainable funding remains vital to ensure that councils have the ability to invest in and regenerate their housing stock, fulfilling our ambition of ensuring everyone has access to a safe, healthy and high-quality home. We continue to raise with Government the challenges created by mounting financial pressures on Housing Revenue Accounts (HRAs) and the challenges in investing in regeneration and improving housing quality, alongside other priorities including building safety, fire safety, decarbonisation and building new stock. We are keen to work with the Department to explore solutions to the finance challenges and put HRAs on a more sustainable footing, which will need to include increased flexibilities to raise additional income, as well as additional national investment.

Public health

Directors of public health and local public health teams play a critical leadership role in assessing the local air pollution public health risks and possible interventions, ensuring integrated and coordinated action across local government and health services, and communicating with the public about indoor and outdoor air pollution. In 2017, the LGA – alongside Defra, Public Health England and the Association of Directors of Public Health - published a toolkit for directors of public health, to support them to take action against air quality, which outlines their role in this space in detail.

The public health grant has been cut by 26 per cent on a real-terms per person basis since 2015/16. We continue to call on Government for an uplift to the public health, as well as multi-year funding settlements. This will be crucial to improve communities’ health outcomes, tackle health inequalities and ensure public health teams are effectively resourced to contribute towards whole-system approaches to reducing and mitigating the health impacts of air pollution.

I hope the information outlined above is useful. If we can assist the Committee’s work with anything else on these issues, please do not hesitate to get in touch with my colleague Megan Edwards.

Cllr Linda Taylor

Interim Chair of the LGA’s Environment, Economy, Housing and Transport Board



May 2023