Written Evidence submitted by the Joint Nature Conservation Committee (AQU0036)
06 August 2020
1.1 Air pollution is a significant long-term pressure on the natural environment in the UK. It has adversely affected plant communities, habitat resilience and ecosystem function, factors that are important for building nature recovery networks in England and other UK equivalent programmes. Environmental objectives and ecosystem function must be considered when designing and evaluating air quality objectives for human health to enable a truly green post-Covid recovery.
1.2 Impacts, especially of reactive nitrogen, continue to damage protected sites and habitats and will present challenges to government ambitions for the natural environment under the 25 Year Environment Plan.
1.3 Defra’s Clean Air Strategy provides impetus for co-ordinated effort on nitrogen pollution and realising and optimising the co-benefits for human health, biodiversity and our natural capital. The Environment Bill framework presents an opportunity to set long term statutory targets, focused on ecosystem as well as human health protection, and to drive forward the action needed.
1.4 Evidence indicates that policies for meeting the national emission ceilings for ammonia in 2020 and 2030 can maximise the associated benefits to the natural environment through the spatial targeting of planned mitigation measures. However, such evidence also shows that action beyond that currently planned will be needed if we are to meet objectives for protected sites and sensitive habitats.
1.5 People’s well-being is linked to healthy ecosystem function so managing air quality for environmental protection and enhancement should be explicitly included in clean air considerations for human health. Investment in natural capital can reduce air pollution, for example through uptake by vegetation, reducing impacts on human health to an estimated current annual value of £1bn.
1.6 The solutions therefore need an integrated approach across policy areas such as agriculture, energy and transport, to reduce emissions and address impacts both on human health and the environment in different environmental media (soils, water and air). This cuts across Government departments, programmes within Defra and government agencies.
1.7 A combination of effectively targeted regulatory, advisory and incentive programmes to deliver emission reductions are required both in the short and long term to achieve ambitions for human health and nature. Opportunities presented by Covid-19 recovery, leaving the EU, and the new Environment Bill that can lead to improved air quality and protect and restore nature.
2.1 JNCC is the statutory adviser to Government on UK and international nature conservation. Its work contributes to maintaining and enriching biological diversity, conserving geological features and sustaining natural systems.
2.2 JNCC facilitates collaboration on air pollution work across the four UK country nature conservation bodies[1] in order to:
2.3 This evidence is provided on behalf of Natural England[2] as well as JNCC. Our submission draws on evidence from across the UK and focuses on actions to reduce air pollution impacts on the natural environment. It builds upon the JNCC response to the EFRA Committee 2017 Improving Air Quality Inquiry and reinforces some of the issues raised in EFRA Committee report (EFRAC, 2016) including how clean air for human health should also be aligned with wider goals including those for climate change and UK ecosystems. This response pays particular attention to two linked issues: control of reactive nitrogen emissions and the air quality affecting both people and ecosystems. Our response addresses the first, second and fifth questions set out in the terms of reference.
3.1 Air pollution remains a major pressure on the natural environment in the UK as detailed in JNCC’s 2017 submission to the EFRA enquiry on Air Quality (NCC, 2015; ROTAP, 2012; Defra, 2019). The emissions, and subsequent impacts, of “reactive” nitrogen[3] pollutants are the main concern (ROTAP, 2012; Sutton et al, 2011) including oxides of nitrogen (NOx, mainly from transport and industry) and ammonia (mainly from agriculture). Ammonia emissions have increased in recent years and this is of particular concern for protected areas.
3.2 The impacts of nitrogen deposition on plant species and the quality of semi-natural habitats is widespread and well recognised (ROTAP, 2012; Emmett et al, 2011). Over 57% of the area of sensitive habitat in the UK, equivalent to 42,049 km2, receives levels of nitrogen deposition above the “critical loads”[4] for the protection of ecosystems from nitrogen deposition. In England this figure is higher at 95% of sensitive habitat area (Rowe et al, 2020). When considering protected sites, over 80% of UK Sites of Special Scientific Interest (SSSI) have nitrogen deposition rates above levels at which harm is expected.
3.3 Progress towards national biodiversity strategies and other biodiversity commitments is currently compromised through continued nitrogen deposition (IPENS 2015; Emmett et al, 2011; NRW, 2015). This includes risks to outcomes for biodiversity set out in the 25 year Environment Plan that will affect the ambitions for restoration of protected sites, priority habitat and facilitation of connectivity and resilience as seen in the proposed Nature Recovery Networks in England. The number of different plant species (known as “species richness”) of five widespread habitats in the UK is approximately one-third less than without nitrogen deposition (Payne et al, 2017). These losses due to excess nitrogen are associated with effects such as shading from more nitrogen tolerant plants, changes in soil chemistry, increased plant sensitivity to drought or frost as well as direct toxic effects.
3.4 Evidence is accumulating for effects of nitrogen deposition higher up ecosystem food chains, including impacts on pollinators, butterflies and ants. Flower-visiting insects depend on flowering plants for their energy and nutrients, and wildflowers become less common in a nitrogen-rich environment. Butterfly and moth species are very sensitive to changes in their habitat and habitat quality affected by air quality is a major factor influencing the success of populations (Carvalheiro et al 2019; Ceulemans et al 2017; Mabelis et al 2016; Ockinger et al 2006).
3.5 Air pollution affects a wide range of the services provided by ecosystems provide that benefit human well-being (ROTAP, 2012; Jones et al, 2014a and 2019). Jones et al (2014b) showed that the reduction in nitrogen deposition observed in 1987–2005 provided a net benefit for ecosystem services estimated as “Equivalent Annual Value” of £65 million per year. However, the evidence base relating air pollution exposure to the full suite of ecosystem services is incomplete; Jones et al (2014b) state that their valuation “provides only a partial picture of nitrogen impacts which may underestimate the benefits of reducing nitrogen deposition.”
3.6 As well as considering the evidence of impacts on the natural environment it is important to consider the role the natural environment plays in reducing the impacts on human health. The UK’s natural capital is important in the removal of air pollutants from the atmosphere, reducing exposure of the human population which is a service valued at an estimated £1bn in 2015 for the UK (Jones et al, 2017).
4.1 In responding to this question, we focus on policies in respect of the impact of air pollution on the natural environment.
4.2 Legislative mechanisms are largely in place through the country regulations (eg Environmental Permitting Regulations) to control the impacts of emissions from most new point sources alongside other domestic nature conservation and planning legislation (eg Habitats Regulations 2018). However, issuing permissions for new sources of pollution whilst protecting biodiversity and seeking to reduce pollution levels to achieve nature conservation objectives, is extremely challenging where “background” pollution levels already exceed critical loads. Rowe et al 2020 highlight that the majority of habitat area sensitive to nitrogen deposition is exposed to levels of atmospheric nitrogen that undermine ecosystem function. The effects of air pollution on protected sites has been a key factor in constraining the progress of strategic development planning in many areas, especially in the light of recent caselaw (see section 6.3 below) both in the UK and abroad, whilst strategic solutions to the pressures from air quality have yet to be developed and implemented.
4.3 Often, this is a result of elevated background levels of pollution due to diffuse sources which do not require a permit or attract other type of control. This includes ammonia emissions from agriculture. Only large pig and poultry installations over a threshold size are covered by pollution permitting regulation; other farm types are not included and yet most ammonia emissions come from the cattle/dairy sector (NAIE, 2019). The Clean Air Strategy commits to steps to consider regulation of ammonia from other agricultural sources including dairy and cattle although it is not yet clear what form this will take. Future environmental land management schemes, and other types of incentive and advice schemes, including through Catchment Sensitive Farming advice in England, should also have an important role in tackling diffuse ammonia pollution.
4.4 It is widely accepted that to reduce impacts of air pollution on the natural environment, the priority should be to significantly reduce ammonia emissions (ROTAP, 2012; Sutton et al, 2012; EFRAC, 2016). Reductions in ammonia will also bring benefits for human health through reducing concentrations of secondary particulate matter (e.g. ammonia nitrate aerosols).
4.5 The Clean Air Strategy commits to actions and targets based on the national emissions ceilings (NECR 2018). The Clean Air Strategy also commits to a target (2030) for reduction of nitrogen deposition on sensitive habitats, and to setting longer term targets beyond this. However further measures targeted in areas requiring specific air quality improvements will be needed alongside national emission reductions. The targeting of ammonia mitigation measures such as low emission spreading close to sensitive habitats is a cost-effective approach to reducing nitrogen deposition impacts. For example, targeting of some emission reduction measures in a zone around protected sites is predicted to bring protection from air pollution effects for approximately 117,000 ha more habitat than non-targeted actions under the National Air Pollution Control Plan alone[5].
4.6 Whilst significant progress has been made to pilot farm ammonia emission reduction programmes (for example through advice on ammonia emission reduction measures under Catchment Sensitive Farming in England), in order to maximise benefit from incentivised emission reductions, air quality measures must be a considered outcome for future environmental land management. Where air quality is included as an incidental co-benefit for programmes targeted at for example, water quality, evidence indicates there can be limited air quality benefits for ecosystem protection. Dedicated actions to tackle air pollution effects on ecosystems and supportive monitoring are required to achieve nature-based solutions.
4.7 Atmospheric nitrogen pollution arises from many sources and a number of different sectors have a role to play, both at national and local level. Action to tackle impacts at the site level will therefore require a strategic approach across several sectors. Natural England is piloting a SNAPS (Shared Nitrogen Action Plan) approach that encourages a stakeholder led coordinated approach to assessing sources and addressing solutions. JNCC commit to providing continued support for Defra, the country nature conservation bodies and devolved administrations in their efforts to address air pollution effects on ecosystems and to progress their strategic ambitions.
4.8 In summary the UK has several measures in place but should tackle as a matter of priority the following:
5.1 Currently a framework for development of targets is proposed in the Environment Bill. Future statutory targets or a comparable mechanism of assurance would be helpful to drive the necessary action to protect biodiversity.
5.2 For example, the Clean Air Strategy commits to setting a target for reduction of damaging deposition of reactive forms of nitrogen by 17% over England’s protected priority sensitive habitats by 2030 and reviewing longer term ecosystem based targets. The Environment Bill framework, and any resulting secondary legislation, could strengthen these targets by putting them on a statutory footing. In order to address impacts of specific air quality issues on UK protected areas, further localised reductions as well as planned widescale reductions are required[6].
6.1 The Covid-19 pandemic has given many people a renewed appreciation of the nature. It has also demonstrated how behavioural change has the potential to significantly improve air quality with associated benefits for human health and ecosystems. Actions to address the spread of Covid 19 have shown how behavioural change, particularly in relation to transport and shifts to low or no emission modes, has the potential to improve air quality for the humans and nature.
6.2 Opportunities to promote economic recovery that will benefit air quality include:
6.3 Emerging risks include challenges to current decision-making processes for future development. Recent case law (Cooperatie Mobilisation European Court of Justice joined cases C-293/17 and C-294/17) has alerted regulatory authorities to the need for robust strategic solutions to meet air quality impacts on internationally important protected sites. In the majority of cases such solutions do not yet exist and as a result many countries are experiencing significant delays in development planning whilst alternative approaches are developed. Accelerating efforts to reduce emissions and to develop strategic solutions will help to unblock such constraints on development as well as ensuring it takes place in a sustainable manner.
6.4 Green recovery ambitions provide opportunities to reinforce the consideration of the environment whilst pursuing sustainable development, in the planning process as well as in the local action required. It is important to use the evidence gathered about environmental and behavioural change under lockdown[7], to help people understand what that change means not only for their health but also for a natural environment that provides ecosystem services and supports well-being.
6.5 A cross-sector, transboundary approach is essential to address the combined pressure on ecosystems from all emission sources and to optimise action related to the opportunity for change post-Covid lockdown and EU Exit. This will require cooperation across UK countries and between both national and local governments. For example, sources typically associated with rural areas can affect urban areas. Estimates of rural ammonia contributions to urban particulate matter are 38% and 26% of PM2.5 and PM10 respectively for Belfast (Defra 2005 cited in Karagulin et al 2015). More integrated use of data and evidence is required to ensure clean air is established for people as well as the natural environment, particularly as the UK pursues a green recovery.
7.1 Air quality, especially nitrogen pollution, has significant impacts on sensitive species and habitats, and is causing damage to protected sites. As such it remains a constraint on the governments aims, as recently restated by the Secretary of State, to protect existing nature, to build back more diverse habitats and reverse species decline.
7.2 Consideration of such impacts needs to go hand in hand with action to address impacts on human health, both to ensure restoration of biodiversity to meet governments ambitions under the 25 Year Environment Plan, but also to optimise the synergies between human health and environment quality.
7.3 Where possible the Environment Bill framework, and resulting secondary legislation, should provide a statutory grounding for future air quality targets that are needed to underpin ecosystem function alongside those for human health.
7.4 There is good evidence that such action will need to go beyond existing commitments and targets for biodiversity under the Clean Air Strategy. This will need to include locally targeted actions to protect and restore designated sites, alongside national and international measures. Statutory targets to reduce atmospheric nitrogen impacts on sensitive habitats would help to drive the action needed.
7.5 Further regulation as signalled under the Clean Air Strategy will be needed, alongside enforcement, advice and incentive under the future environmental land management scheme.
7.6 Coordinated, stakeholder-led strategic action at regional level is likely to be necessary to ensure different sectors play their part in meeting the necessary emission reductions.
August 2020
Air Quality Consultants (AQC) (2020) The Effect of COVID-19 Social and Travel Restrictions on UK Air Quality – 27 March Update. https://www.aqconsultants.co.uk/CMSPages/GetFile.aspx?guid=76276080-6c02-489f-97f2-5da0a2fe6bdf
Carvalheiro, L. et al 2019. Soil eutrophication shaped the composition of pollinator assemblages during the past century. Ecography 43: 209–221 doi:10.1111/ecog.04656
Ceulemans T. et al (2017) Nutrient enrichment is associated with altered nectar and pollen chemical composition in Succisa pratensis Moench and increased larval mortality of its pollinator Bombus terrestris L. PLoS One 12(4): e0175160. https://doi.org/10.1371/journal.pone.0175160
Defra Report (2005) Summary of the second report produced by the Air Quality Expert Group, Department for the Environment, Food and Rural Affairs, London. Cited in Karagulin et al (2015) Supplementary Material: Contributions to cities’ ambient particulate matter (PM): a systematic review of local source contributions at global level. Atmospheric Environment 120:475 - 483.
Department for Environment, Food and Rural Affairs, UK (2019). UK Biodiversity Indicators 2019. Indicator B5a: Air Pollution.
https://hub.jncc.gov.uk/assets/9be943eb-3066-4e8e-82d3-b1348d7ce9b9
Dragosits, U. et al (2014) Future patterns of ammonia emissions across the UK and the potential impact of local emission reduction measures. [Final report on Defra project AC0109]. NERC/Centre for Ecology & Hydrology, 34pp. http://sciencesearch.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&Completed=0&ProjectID=14938
EFRAC (2016) Air quality Inquiry: Report, together with formal minutes relating to the report. House of Commons Environment, Food and Rural Affairs Committee. https://publications.parliament.uk/pa/cm201516/cmselect/cmenvfru/479/479.pdf
Emmett, B.A. et al (2011) Interpretation of evidence of nitrogen impacts on vegetation in relation to UK biodiversity objectives. JNCC Report, No. 449.
IPENS (2015) Atmospheric nitrogen theme plan. Developing a strategic approach for England’s Natura 2000 sites. Improvement Programme for England’s Natura 2000 Sites – Planning for the Future’. http://publications.naturalengland.org.uk/category/5605910663659520
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Jones, L. et al (2014b) A review and application of the evidence for nitrogen impacts on ecosystem services. Ecosystem Services. 7:76-88
Jones, L. et al (2017) Developing Estimates for the Valuation of Air Pollution Removal in Ecosystem Accounts. Final report for Office of National Statistics, July 2017 https://www.ons.gov.uk/economy/environmentalaccounts/articles/developingestimatesforthevaluationofairpollutioninecosystemaccounts/2017-07-25
Jones et al (2019) Urban natural capital accounts: developing a novel approach to quantify air pollution removal by vegetation, Journal of Environmental Economics and Policy 8(4): 413-428, DOI: 10.1080/21606544.2019.1597772
Mabelis, A. A. and Korczyńska, J. (2016) Long-term impact of agriculture on the survival of wood ants of the Formica rufa group (Formicidae). Journal of Insect Conservation 20 (4):621- 628.
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[1] Natural England, Natural Resources Wales (NRW), Northern Ireland Environment Agency (NIEA), Nature Scot formerly Scottish Natural Heritage (SNH).
[2] Natural England is the government's adviser for the natural environment in England, helping to protect England's nature and landscapes for people to enjoy and for the services they provide.
[3] Most nitrogen is stored in the biosphere in the unreactive ("unfixed") form of N2 and is not directly accessible to most organisms. “Reactive” nitrogen refers to biologically, photochemically and radiatively active N compounds, which are essential for life. It includes the following: nitrogen dioxide (NO2), nitrous oxide (N2O), nitrate (NO3 -), ammonia (NH3), and ammonium (NH4 +) amongst other compounds. In this evidence, the term “nitrogen” refers to reactive forms.
[4] Critical loads are the threshold “below which significant harmful effects on sensitive elements of the environment do not occur according to present knowledge” (Nilsson & Grennfelt 1988)
[5] Nitrogen Futures optimised scenario to reduce critical level exceedance of ammonia using area-weighted 1 method which assumes sensitive habitat is present across the entire protected area.
[6] The JNCC Nitrogen Futures project quantified the benefit of reducing reactive nitrogen emissions to meet the 2020 and 2030 emission ceilings for individual protected areas (in publication). It confirms the conclusion of previous work that providing measures set up by the National Air Pollution Control Programme are implemented, the extent of critical load exceedance and the magnitude of damage will be reduced (e.g. Dragosits et al, 2014). This could potentially lead to modest improvements in habitat quality in some areas. However, it is likely there will still be widespread exceedance of critical loads (ROTAP, 2012) and further impacts in areas subject to long term and severe exceedance (Payne et al, 2017). Therefore, further reductions in emissions beyond those committed for 2030 will be required to protect biodiversity and ecosystem services.