Association of Directors of Public Health respond to National Air Quality Strategy

The Association of Directors of Public Health (ADPH) have managed to squeeze a response into the miserly 10 day window the government provided for feedback on their revised National Air Quality Strategy. The consultation ends today.

The ADPH are senior doctors and other professionals with specialist qualifications, employed by local councils to advise on health protection and health improvement and to lead on commissioning of services.

Making reference to the short response window, the APDH observe: ‘While we welcome the consultation, we are disappointed that we have only been given nine working days to respond to such an important issue. The consultation has a lot of focus on the role of local government, without any specific indication of funding, and little on the role of national government. It is not clear how the initiatives proposed in the strategy could be adequately funded and how this could make a real and significant difference to air quality, as has been seen in other countries.

The consultation document posed a series of questions, to which the ADPH have replied to at length. Here we have included only a small selection of their comments. A link to the full response document is at the foot of this page.

• To what extent do you agree or disagree with our commitment to better align air quality reporting zones with local government boundaries?

‘Strongly agree… Aligning air quality reporting zones with local government boundaries would facilitate coordinated action between key partners across LA boundaries (including transport, planning, health and education) to reduce the health impact, mortality and health inequalities associated with air pollution. 

‘Comprehensive, accessible air quality data within local government boundaries is important to facilitate an evidence-based approach to reducing air pollution. It would lead to an improved understanding of the trends and factors which influence air pollutants within local areas.’

•  What more could local authorities do within the existing regulatory framework to reduce pollution from inappropriate domestic burning?

‘Whilst the new powers to issue fixed penalties for clean air act offences are welcomed, the significant scale of domestic solid fuel burning requires action at a national level to control the fuel and stoves which are available. It should also be made easier for LAs to declare smoke control areas.’

• How do you feel local authorities can most effectively reduce pollution from industrial sources they are responsible for?

‘LAs should be supported with resources, adequate staffing and additional inspection capacity to enforce restrictions and reduce industrial emissions. Large industries have made it expensive for LAs to prosecute, and so the national Government plays an important role in supporting LAs in enforcing regulations. Only with sufficient funding can LAs effectively undertake enforcement activity to reduce pollution from industrial sources.’

• How do you feel local authorities can most effectively reduce pollution from transport and non-road
  mobile machinery (NRMM)?

‘More investment should be allocated to support walking, cycling and use of public transport (for example through wider pavements, cycling infrastructure, planting trees, and street furniture between footpaths and roads). Public transport should also be made more affordable and accessible. Road systems which encourage continual traffic flow rather than stopping and starting can help to mitigate the impact of diesel and heavy goods vehicles.

‘The strategy fails to consider the importance of promoting the use of low-emission vehicles in reducing pollution from transport. The Government should incentivise the use of low-emission vehicles and require housing developments to install infrastructure fit for new technological vehicles.’

• How do you feel local authorities can most effectively reduce pollution from agriculture?

‘We support the proposed Government actions on the continued investment in slurry storage infrastructure to reduce ammonia emissions. Moreover, we are delighted to see the proposal to consult on bringing dairy and intensive beef farms within scope of environmental permitting as well as a proposed consultation on new restrictions for lower emission techniques for slurry and digestate spreading and storage.’

• How do you feel local authorities can most effectively improve indoor air quality?

‘The Government should deliver strong public health messages so that the public could make informed choices on domestic burning and reduce the use of solid fuel burning.

‘The Government should support households to improve insulation to prevent mould from forming in the first place. The Government should also update the Housing Health and Safety Rating System (HHSRS) risk assessment which has been identified by the Government as a priority. This risk assessment framework enables property inspections to identify where damp and mould is likely to adversely affect residents. 

‘Ventilation in all settings should follow appropriate standards, therefore ensuring professionals are  more familiar with the best practice on indoor air quality including ventilation is a step in the right direction. It is vital to ensure housing has adequate ventilation and better insulation to prevent pollutants concentrating indoors and air quality worsening.’

• How do you feel local authorities can most effectively communicate air quality information?

‘Whilst it is important for LAs to share air quality information with their communities, it is also vital that this is backed up with strong and consistent national messaging relaying the detrimental impact of air pollution.’

• Do you feel that there are additional powers relating to air quality which should be available to local authorities?

‘Yes. LAs should be supported with resources, adequate staffing and additional inspection capacity to enforce restrictions and reduce pollution. Large industries have made it expensive for LAs to prosecute, and so the national Government plays an important role in supporting LAs in enforcing regulations. 

‘The Government could consider adopting the Polluter Pays Principle and fund LA interventions with fees and charges from the industry.’

• What further support could Government provide to help with actions taken locally to tackle air quality?

‘Guidance, face to face teach ins, virtual teach ins, enforcement pro-formas/templates, sharing space/website and knowledge hub are all useful. However, unless the Government can provide strong central messaging and enforceable regulations (not just guidance), with funded capacity for enforcement, these measures will have limited effectiveness.

‘Additional funding is also required for enforcement and education. The Government should provide more resources to place/environmental teams in LAs. More funding could also be allocated via an Air Quality Grant.’

The full response can be read here