The document discusses the Institute of Air Quality Management Committee's views on what should be included in the UK's upcoming National Clean Air Strategy. Key points discussed include: 1) Ensuring the strategy aligns UK and EU air quality legislation and establishes independent oversight of policy effectiveness after Brexit. 2) Setting exposure reduction targets in addition to air quality standards to better protect public health. 3) Providing clear plans and timelines to meet emission ceilings for particulate matter and ammonia from sectors like transportation, agriculture, and domestic burning. 4) Strengthening the planning system to give more weight to air quality considerations in development. 5) Committing to continued research on air pollution sources,

1. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
National Air Quality Strategy:
IAQM Committee’s View
Dr Claire Holman
Brook Cottage Consultants/University College London
Chair, Institute of Air Quality Management
IAQM Discussion Meeting:
London 6 January 2018

2. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Clean Air Strategy
Contents
1. 2016 Amended National Emissions Ceiling Directive
2. Environment Act 1995
3. Government’s 25 year Environment Strategy
4. What should be in the Clean Air Strategy?
5. Conclusions
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3. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Why a National CleanAir Strategy?
• 2016 amendments to National
Emissions Ceiling Directive
(NECD)
• Directive (EU) 2016/2284 of the
European Parliament and of the
Council of 14 December 2016
on the reduction of national
emissions of certain atmospheric
pollutants, amending Directive
2003/35/EC and repealing
Directive 2001/81/EC
• To be transposed into UK
legislation by 1 July 2018.
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4. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• ...to move towards achieving levels of air quality that do not give rise
to significant negative impacts on and risks to human health and the
environment
• Emission reduction commitments for anthropogenic atmospheric
emissions of
• SO2
• NOx
• NMVOC
• NH3
• PM2.5
Aim of Directive 2016/2284
Directive to contribute to achieving:
• the EU AQ objectives set in legislation
• progress towards EU long-term objective
of achieving levels of air quality in line with
the WHO air quality guidelines;
• EU biodiversity and ecosystem objectives
• enhanced synergies between EU's AQ
policy and other relevant EU policies (in
particular climate and energy policies)
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5. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• Directive requires NAPCPs to be drawn up, adopted and
implemented
• To comply with emission reduction commitments, and to contribute
effectively to the achievement of the air quality objectives
• Emissions and impacts to be monitored and reported
• Should take account of the need to reduce emissions, in particular
NOx and PM2.5 in zones and agglomerations affected by excessive air
pollutant concentrations
• National air pollution control programmes should contribute to the
successful implementation of air quality plans established under the
Ambient AQ Directive
• 1st NAPCPs to the Commission by 1 April 2019 (after BREXIT!)
National air pollution control programmes (NAPCPs)
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6. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
2020-2029 From 2030
UK EU UK EU
SO2 59% 59% 88% 79%
NOx 55% 42% 73% 63%
NMVOC 32% 28% 39% 40%
NH3 8% 6% 16% 19%
PM2.5 30% 22% 46% 49%
Emission reductions from 2005 (Directive 2016/2284)
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Greatest risk - not meeting emission ceilings for PM2.5 and NH3

7. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
NAPCPs should consider measures applicable to all
relevant sectors, including:
• Agriculture
• Energy
• Industry
• Road transport
• Inland shipping
• Domestic heating
• Non-road mobile machinery
• Solvents
• Waste.
Sectors
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8. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
EnvironmentAct 1995 - NationalAir Quality Strategy (NAQS)
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9. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• 1997
• 2000
• 2003 addendum
• 2007
NAQSs
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10. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Government’s 25 year Environment Strategy
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11. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Government’s 25 year Environment Strategy
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12. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
2017Air Quality Plan

13. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• Focus should be on improving air quality and reducing
public exposure
• Recognition needed that emissions and concentrations
are not linear, especially for secondary pollutants, and
therefore an emission strategy would be inadequate
• The CAS is a great opportunity to look develop a holistic
approach encompassing at a wide range of air pollutants
(all there reported to the EC?)
• Need clarity regarding what policies and measured will
be included (Government’s Environment Strategy is
grossly inadequate wrt air quality)
Clean Air Strategy – General Comments

14. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
1. BREXIT
a) How will European Commission’s scrutiny role will be
replaced?
• Statutory Air Quality Committee responsible to Parliament similar in
structure to the Climate Change Committee?
• New powers of the Environment Agency? (but not independent of
Government)
b) Role of BAT Reference (BREF) documents?
c) Vehicle emission legislation – UK likely to follow EU to
enable trade
d) Role of EU air quality limit values? Mandatory vs non-
mandatory UK objectives.
e) Ensure all EU AQ legislation is incorporated fully into UK
legislation
f) Seek on-going UK/EU co-operation e.g. UK to remain
member of European Environment Agency
What should be included in CAS?
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15. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
What should be included in CAS?
EU legislation :
Defra:
• Monitoring
• Modelling
• Reporting (to
Commission)
• Everywhere with a
few exceptions
National legislation
Local authorities:
• Monitoring
• Modelling
• Reporting (to
Defra)
• Where there is
exposure
Same Pollutants- Same Concentrations
Same aim but completely separate processes
Applies in different places
Two systems = Poor legislation
Public (and others!) are confused
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2. Greater alignment of ambient air quality legislation

16. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
3. AQ standards + critical loads
• Regularly review AQ standards to take account of new data
What should be included in CAS?
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Source: Prof Frank Kelly, Routes to Clean Air 2017

17. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
4. Exposure reduction targets
a) In addition to, not instead of, AQ standards to protect
public health
b) To be based on the WHO guideline values?
c) Applicable for the major non-threshold pollutants (e.g.
PM2.5) ?(will evidence show in the future there no air
pollutant has a threshold below which there is no
effect?)
d) Applicable to all air pollutants where there are
significant background concentrations (e.g. NO2)?
What should be included in CAS?
17
Source: Prof Frank Kelly, Routes to Clean Air 2017

18. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
5. Road transport
a) Real world NH3 emissions from diesel/SCR vehicles –
urgently needed to develop emission factors
b) Control of NH3 emissions from road transport
(especially diesel light duty). Also primary NO2?
c) Control of non-exhaust PM emissions
d) Continuous programme of testing on-road vehicle
emissions to enable UK emission factors to be
developed (historically UK did this; Netherlands still do)
e) Random testing of in-service emission performance
(evidence of SRC systems immobilised). Prosecution
where deliberate and/or persistent.
What should be included in CAS?
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19. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
6. Clear plan to achieve PM2.5/NH3 ceilings
a) How will UK meet emission ceilings?
b) How will UK ensure that PM2.5 concentrations decline to
the WHO guideline value? International co-operation
required (see BREXIT slide
c) Explain how NH3 emissions from agriculture will be
controlled including timescales
d) See road transport slide re. vehicle emissions
e) Address domestic burning of solid fuel
What should be included in CAS?
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20. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
7. Planning system
a) Ensure more weight is given to AQ in the planning system
b) Revise NPPF and air quality PPG? SPG/SPDs
c) AQ focus areas where wide AQMS declared; with tighter
planning requirements?
d) Cumulative impacts of boiler NOx emissions in urban areas
not well considered?
e) Short term exposure under-estimated?
f) Consider links between land-use, transport an air quality
What should be included in CAS?
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21. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
8. Research
a) Re-examine source apportionment for the five NECD pollutants
b) Continue to fund and extend monitoring networks (ambient air quality
and deposition)
c) Fund the analysis of monitoring data
d) Undertake measurements of emissions from domestic fuel
combustion, NRMM and agriculture to develop more robust emission
factors for inventories
e) Fund local authority to resource enforcement of smoke control areas
f) Review the research gaps
g) How does policy development deal with future uncertainty (ignore it?).
h) Role for expert groups to make help make good policy judgements
i) Examine environmental justice of changes in transport policy and air
quality (social, health and environmental inequalities)
What should be included in CAS?
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22. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
9. Other issues
a) PM Constituents of PM
• Black carbon?
• Particle number?
• Metals?
• Plastics?
b) Indoor air quality
c) Exposure on public transport and other modes of
transport
d) Effect of physical barriers, including vegetation, on
dispersion of air pollution
What should be included in CAS?

23. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
10. Uncertainty
a) Policy must be based on good quality and up-to-date scientific/
medical evidence
b) There will always be uncertainty
c) Uncertainty must not be an excuse to paralyse decision making
d) But should be an important consideration in policy development
and decision making.
e) Role for expert groups to make help make good policy judgements
What should be included in CAS?
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24. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
11. New Clean Air Act
a) Geraint Davies, the Labour MP for Swansea West – proposed new
Clean Air Act (22 November 2017)
b) Clean Air for London drafted a Clean Air Act with support of
Baroness Jenny Jones (Green) and others
c) New legislation would be a clear commitment from Government
that air pollution is a high priority.
What should be included in CAS?
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25. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
a) Need for a new AQS – a lot has changed since 2007
b) CAS needs to comprehensively address how adverse
health/ecological effects will be reduced.
c) Improved LAQM system with mandatory limit values
d) Independent scrutiny of the effectiveness of air quality policy
e) Must explain post BREXIT strategy
f) Key current issues are NH3 and PM2.5 (black carbon in longer
term?)
g) International co-operation remains essential
h) Revision of NPPF/PPG wrt to AQ
i) Policy must be evidence based
j) Funding commitment for AQ research, and development of
evidence and fit for purpose policy tools.
k) Need for a new Clean Air Act to demonstrate Government
commitment to improving air quality
Conclusions
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