15.30 Ethical considerations when determining air quality policies.pdf

1. Ethical considerations when
determining air quality policies
Dr Michael Bull

2. Air Quality Standards
• My career in air quality has almost always been based around a system
where air quality standards were the principal policy lever
• Saw the introduction of the first standards in 1989;
• The introduction of the air quality management in the 1990s which largely
was based on achieving air quality objectives;
• New standards being introduced and the WHO targets
• While emission reduction targets have been implemented, they have no
impact on local air quality assessments
• Never an obvious debate on whether the focus on standards is the right
approach

3. The ULEZ debate
• The London ULEZ implementation resulted in the media taking a great
interest in air quality issues and the nature of this debate is a great example
of some of the ethical issues that surround public health policy
• The costs of the scheme were highlighted
• The disbenefits of the scheme were highlighted (particularly personal costs)
• The restrictions on personal liberty were highlighted (see also 15 minute
cities)
• In particular, whether the ULEZ was “fair” and whether it is value for money

4. The press were not impressed

6. Some public reaction

7. But actually - ULEZ benefits

8. Rose’s Prevention Paradox
This recognizes that many public health strategies may have no benefit on an individual - e.g.
vaccinating 1000 people may save one life but has no apparent benefit for the other 999 (and
indeed carries some risk to those individuals).
“A measure that brings large benefits to the community offers little to each participating
individual”
Occurs when a measure provides very small health benefits when shared over the whole
community, or the measures only apply to a few vulnerable people.
People are not motivated to accept a measure if it has no apparent benefit to or because they
cannot know “ex ante” whether they will benefit.
Rose, G. (1981) “Strategy of prevention: lessons from cardiovascular disease”, Br Med J, 283:1847-51.

9. Ethical considerations for air quality standards
Going to consider the following ethical principles in considering whether air
quality standards are an appropriate policy lever:
• Utilitarian approach – a measure should maximize good
• Equality – a measure should aim to give everyone the same exposure
• Equity – a measure should target the more affected areas to “level up”;
• Personal Freedom – measures should respect the right to personal
freedoms – avoid paternalism

10. Utilitarianism
The principle that our policies should be designed to maximize good within
the whole community
• If we take this approach as being appropriate, air quality standards are not
a good policy tool where most of the country complies with the standard
• Some evidence points to the greatest health benefits from a reduction in
pollutants concentrations is in areas with lowest pollutant concentrations
• We believe that there is no lower threshold for adverse health effects for
some pollutants so reducing exposure in all areas would be more
appropriate.
• However, too simplistic approach as it can be reasonably argued that access
to personal transport, having a heated home and using the products from
polluting industries result in some health improvements

11. Equality
The principle that our policies should be designed to give everyone the
same exposure to air pollutants
Equality in Benefits
• Major issue with this is that it is simply not possible owing to geography
and the uneven distribution of pollutant sources, city centres will always
have higher pollutant concentrations than the suburbs, locations near to
roads will always have higher pollutant concentrations;
• However, air quality standards do not represent an appropriate measure to
achieve anything approaching equality;
• Only concentrate on areas of exceedance and once standards are achieved,
no further action is necessary and hence large inequalities remain.

12. Equality
The principle that our policies should be designed to affect everyone
equally
Equality in terms of who is affected
• Equality not achieved by imposing measures on only one part of the
population
• Restrictions such as Low Emission Zones and Smoke Control Areas allow
some of the population to carry on driving polluting cars and burning poor
quality fuels

13. Equity - Luck Egalitarianism
The principle that our policies should be designed to target the more affected
parts of the population – to provide the population with the same health
outcomes
Might aim to target measures at more vulnerable communities that suffer
proportionally greater health effects;
• As we know air pollution tends to affect those with existing health conditions,
would be more equitable to target measures with the poorest health outcomes;
• Should give priority to the worse off as they have the stronger claim for help;
• However, complicated by a further principle that it is indefensible to focus only
on those worse off now and not consider those worse off over a lifetime
• Results in air quality standards being a poor tool

14. Personal Freedom
The principle that our policies should attempt to avoid unnecessary
restrictions on personal freedom, there should be respect for personal
autonomy
• Achieving new air quality targets will require much more stringent
intervention in our personal lives, changing transport choices, ownership of
private vehicles, how you heat your home;
• Some commentators suggest that more extreme restrictions on personal
movement may be made (see 15 minute cities);
• Very difficult to convince the public to take such measures when
individually their contribution is very small – why should a farmer in Devon
cover their manure pile to very marginally improve PM2.5 concentrations in
London?

15. Policy further complicated by attribution of health effects
• We do not know exactly which parts of the community are affected by air pollution –
as COMEAP states:
“Given this complexity, it is not plausible to think of the figure of ‘attributable’
deaths as enumerating an actual group of individuals whose death is attributable to
air pollution alone, i.e. the victims of outdoor air pollution”
https://wintoncentre.maths.cam.ac.uk/news/does-air-pollution-kill-40000-people-each-year-uk/

16. The appropriate policy changes based on attribution and
interpretation
• Use of air quality standards works well if major health impacts are
considered to arise from acute exposure or exposure above thresholds
• Standards were largely conceived when we thought there were thresholds
to air pollution effects on health
• Use of standards focuses attention on specific areas where there may be
little exposure and can result in some worthless interventions
• If we consider air pollution affects a large proportion of the population or
there is no lower threshold then use of air quality standards are less
effective and their use results in measures are inequitable
• Emission reduction policies are more equitable, any restriction would affect
the population equally and achieve greater public health benefits
(providing we assume no lower threshold of pollutant effects)

17. We are not giving a real choice
• We advocate the use of standards but not the impact of how these will
affect how we live our lives;
• Meeting say the WHO air quality standards will require changes and costs
to the public but I can find little that clearly spells out what’s involved
• It is a community’s choice what policies to adopt, scientists are there to
advise
• If people are to be able to judge whether they support a policy, then we
need to clearly articulate the consequences of the policies – good or bad
• Use of standards is likely to create policies that are not equitable as the
burden will fall differently on various parts of the population
• National emission reduction policies are more likely to result in greater
health benefits and equity

18. It’s nothing new!

19. Michael Bull
Michael Bull and Associates Ltd
PO Box 667
Tunbridge Wells, TN9 9SD
mb@michaelbullassociates.com
michael.bull@odourconsultant.co.uk