Written evidence submitted by the British Heart Foundation (IAQ0136)

Introduction

Relevance for the British Heart Foundation

The British Heart Foundation (BHF) welcomes the opportunity to respond to this joint inquiry on air quality. We have a strong interest in air quality, having invested £3.2 million since 2010 in research to help us better understand the relationship between air pollution and cardiovascular disease (CVD).

Many people are unaware of the link between cardiovascular disease and poor air quality, yet globally, 80% of deaths related to outdoor air pollution are due to heart disease or stroke[1] Research has shown that both short and long term exposure to poor air quality can exacerbate and cause serious cardiovascular health problems. There is a particularly strong link between the smallest particles (known as PM2.5) and poor cardiovascular health.

Given the likelihood that many of the 7 million people currently living with cardiovascular disease in the UK[2] are exposed regularly to high levels of air pollution – which elevates their risk of hospitalisation – it is imperative that governments and administrations around the UK take action to deliver a reduction in air pollution, particularly high levels of PM2.5 in urban hotspots.

1. How effectively do Government policies take into account the health and environmental impacts of poor air quality?

1.1   Exposure to outdoor air pollution contributes to significant, avoidable economic and health harms: Each year in the UK, the equivalent of around 40,000 deaths can be attributed to outdoor air pollution,[5] and premature deaths and diseases attributable to air pollution in the UK result in over £20 billion in economic costs alone each year[6].

1.2   While we welcome the Government’s ambition for the UK to become a global leader in air quality and the commitment to ban new petrol and diesel vehicles from 2040, we believe that more must be done to make this vision a reality and to protect those currently put at increased risk of a heart attack or stroke.

1.3   We believe the introduction of the following measures (outlined in further detail throughout our response) will significantly reduce outdoor air pollution levels within the shortest time possible and in a lasting manner, thereby reducing the risk to health for those living with CVD:

• Adoption of World Health Organisation Guidelines for particulate matter in UK legislation
• Introduction of charging Clean Air Zones in all local authorities identified as in breach of targets, with funds reinvested in initiatives to further improve air quality.
• Introduction of a targeted diesel scrappage scheme to encourage a shift away from diesel vehicles and compensate drivers who purchased diesel vehicles in good faith
• Promotion of and investment in Ultra Low Emissions Vehicles and active travel, including investment in improved infrastructure
• Reliable emissions standards which reflect real word driving conditions - whilst the BHF welcomes the introduction of a Real Driving Emissions test, we believe that the UK should aim for a conformity factor of 1 rather than 1.5 by January 2020.

Adopting WHO limits for particulate matter (PM)

1.4   As outlined above, exposure to high levels of particulate matter has a significant impact on health – the Committee on the Medical Effects of Air Pollutants (COMEAP) estimates that exposure to PM2.5 contributes to 29,000 premature deaths in the UK every year. Even in the short term, exposure to particulate matter can be harmful to health. Research from Public Health England and the National Institute of Health Research looked at the impact of two air pollution episodes (related to PM2.5) over a 10-day period in March and April 2014. Across these two episodes of elevated air pollution, short-term exposure to PM2.5 was associated with over 1,500 emergency hospital admissions across the UK. An estimated 728 of these admissions were due to cardiovascular causes, with researchers estimating that cardiovascular causes would account for 364 admissions over a 10 day period with more typical PM2.5 levels. [7] 

1.5   Despite the clear impact of particulate matter on our health, the legal limits for PM in the UK (with the exception of Scotland) are much less stringent than those recommended by the World Health Organization (WHO). A comparison of the limits is outlined in the table on page 3.

Table 1: World Health Organisation and European Union limit values for nitrogen dioxide and particulate matter

1.6   A recent report from the Royal College of Physicians and the Lancet Countdown found that 44 of the 51 UK cities in the WHO’s 2016 ambient air pollution database exceeded the WHO’s recommended limit value for PM2.5 of 10µg/m­­3.[8]

1.7   While the WHO does provide guidelines on PM limits, it states that there is no safe minimum level of PM that can be inhaled. In order to protect the nation's health, this must be acknowledged in the UK legislation governing air quality. We believe this would be best achieved by enshrining the WHO's limits for air quality in UK legislation.

Dual health benefits of active travel

1.8   We are pleased to see the Government’s plan acknowledge the role of walking, cycling and public transport use in improving air quality. Active travel is healthy, flexible, cheap, and has virtually no emissions. The infrastructure, if planned well, can be very cost-effective, and a reduction in the number of car journeys taken will have a positive impact on air quality.

1.9   Reducing barriers to cycling and walking also contributes to good health by increasing levels of physical activity. Physical inactivity is a significant risk factor for cardiovascular disease – according to Public Health England, being physically active reduces risk of cardiovascular disease, coronary heart disease and stroke by 20-35%[9]. Yet nearly two out of five adults in the UK do not currently achieve the recommended levels of physical activity[10]. There is also evidence of a link between adult obesity levels and travel behaviour: countries with the highest levels of cycling and walking generally have the lowest obesity rates[11].

2. Do these plans set out effective and proportionate measures to achieve necessary emissions reductions as quickly as possible?

Introduction of charging clean air zones

2.1   The Government’s plan for tackling roadside NO2 identified charging clean air zones as the fastest way to achieve compliance with NO2 targets. However, charging has not been mandated for the 29 local authorities required to implement a clean air zone.

2.2   We would like to see the introduction of charging clean air zones in all local authorities identified as in breach of targets, as a means of providing a population level change in road use in the UK’s urban centres. We do not believe that the alternatives to charging will be enough to persuade drivers of the most polluting cars to stay out of these zones. Other forms of discouragement may have an effect over time, but as the Government’s own analysis identifies, charging will be the most rapidly effective.

2.3   In order to maintain public trust and support for charging zones, the funds accrued should be reinvested in initiatives that help to further reduce the effects of air pollution and mitigate the impact of charging on local businesses and residents.

3. Are other nations or cities taking more effective action that the UK can learn from?

3.1   There are a number of examples across Europe of cities taking bold action to improve air quality. A 2015 ranking of European Cities, conducted by Friends of the Earth Germany, evaluated measures taken by 23 European cities to improve air quality.[12] The ranking identified Zurich, Copenhagen and Vienna as the best performing cities, closely followed by Stockholm and Berlin.

3.2   The measures introduced by these cities range from increased public transport provision and the introduction of emissions tolls to cycling initiatives and car sharing schemes.

3.3   Evidence from Germany has shown that clean air zones have the potential to tackle poor air quality in a given location. One introduced in Berlin in 2008 and expanded in 2010 (inclusive of cars) led to PM and NO2 emissions 50% and 20% lower than the predicted trend.[13]

3.4   While it is not an example for the UK to follow, evidence from Beijing provides a helpful reminder that measures to improve air quality have a real impact on health. There are a number of studies showing that the cleaning up of air around the 2008 Beijing Olympics was associated with signs of improved cardiovascular health (and the reverse was true when the measures were taken away after the games).[14],[15],[16]

4. Is there enough cross-government collaboration to set in place the right fiscal and policy incentives?

Collaboration across government

4.1   The UK’s air quality has a major impact on health, yet responsibility for the issue and many of the policy levers required to improve it sit outside the remit of the Department of Health. The establishment of the joint Department for Environment, Food & Rural Affairs and Department for Transport air quality unit has been a helpful step in improving coordination. It is essential that effective coordination now extends across all relevant government departments and agencies, including the Department of Health, Public Health England, HM Treasury (for decisions on fiscal measures) and the Department for Business, Energy and Industrial Strategy (in relation to investment in Ultra Low Emissions Vehicles and the Clean Growth Strategy).

4.2   We believe that one way to ensure that health is seen as a key pillar of the Government’s air quality strategy would be to include targets linked to improved health outcomes. These targets should include a reduction in air pollution related hospital admissions in the next five years, and should be measured and monitored alongside emission reduction targets.

4.3   Collaboration with relevant health bodies is just as essential at a local level to ensure that measures introduced by local authorities have the maximum possible health impact.

Introduction of a targeted diesel scrappage scheme

4.4   As mentioned previously, decisions on some air quality-related measures lie with HM Treasury. One such decision is the introduction of a targeted diesel scrappage scheme. As older, privately-owned diesel vehicles produce a large proportion of PM2.5 emissions, and as a result have a significant impact on cardiovascular health, we believe that a targeted, Government funded diesel scrappage scheme is an effective way to improve air quality. Such a scheme should be based on the following principles:

• It should seek to incentivise the purchase of ultra low emissions vehicles (ULEVs) rather than encouraging a shift back to petrol or to newer diesel engines.
• It should either be tested in one locality before wider investment is rolled out or lessons should be sought from examples of successful scrappage schemes abroad, which have already been evaluated as reducing emissions.  It is hard to predict whether a scrappage scheme will have the desired effect, and some real world experience and data would be beneficial in order to construct models on which to base the scheme.
• It should be targeted at those least able to afford a replacement for their vehicle and those with the most polluting vehicles living in the most polluted areas, for both PM2.5 and NO2.
• As a policy, it should be developed in conjunction with tax incentives to encourage the purchase of less polluting vehicles and investment in adequate infrastructure to support the uptake of ULEVs.

4.5   While we acknowledge that there are challenges with designing and delivering a fair and cost effective diesel scrappage scheme, we believe this is a necessary policy intervention to deliver the required improvements in air quality in highly polluted areas, compensate drivers who purchased diesel vehicles in good faith, and encourage a sustained shift away from diesel vehicles

5. How can those charged with delivering national plans at local level be best supported and challenged?

Adequate support for local authorities

5.1   We agree that local authorities are best placed to identify solutions likely to be effective in their local context. However, to do this effectively, they must be provided with adequate evidence, resource and national support. It is widely acknowledged that local authorities are currently under significant financial pressure – a survey earlier this year found that over three quarters of councils had little or no confidence in the sustainability of local government finances.[17] In light of this, the requirement for local authorities to explore all other clean air zone options before a charging zone (as outlined in the Government’s NO2 plan) seems unnecessarily resource and time intensive and will leave communities suffering with poor air quality for far longer than is required.

Access to high quality data

5.2   To ensure local authorities can accurately monitor the impact of measures to improve air quality, they must have access to high quality data. We know that diesel vehicles do not currently meet the Euro emission standards, with Euro 6 diesel vehicles producing emissions 2.5 to 7 times higher than the standards that they are required to meet[18].

5.3   We welcome the introduction of the new Real Driving Emissions (RDE) test by the European Commission, to ensure that vehicles emit low levels of air pollution on the road as well as the laboratory. Through the RDE test, ‘conformity factors’ will regulate the extent to which vehicles can produce higher levels of emissions in real-world conditions compared to laboratory testing. We believe that we should aim for a conformity factor of 1 rather than 1.5 by January 2020, which would mean that the real-world conditions meet the Euro standard levels.

Increased awareness of the health impacts of poor air quality

5.4   Our ultimate aim must be to improve the quality of the air that we breathe through comprehensive local, national and international action. However, in the short-term, air pollution information systems play an important role by raising public awareness of the importance of good air quality, encouraging a shift in behaviour when it comes to transport use, and helping vulnerable groups take measures to protect themselves.

About the British Heart Foundation

The BHF is the UK’s leading heart charity. We are working to achieve our vision of a world in which people do not die prematurely or suffer from cardiovascular disease. Thanks to modern treatments built on our research, huge progress has been made in saving lives. Most babies born today with heart defects survive and seven out of ten people survive a heart attack. However, heart and circulatory disease still kills one in four people and affects 7 million people in the UK, so there is so much more to do.

The BHF is the largest independent funder of cardiovascular research and the third largest charitable funder of medical research in the UK. Each year, thanks to the generosity of our supporters, we are able to fund around £100 million of new research across the UK and in all four nations. Our funding portfolio extends from laboratory science to clinical trials and population studies.  We fund people from PhDs to professors as well as investing in large programme and project grants.

November 2017