"We agree that the system of Local Air Quality Management is in urgent need of reform and we are in favour of a simplified system which clearly allocates roles and responsibilities in order to deliver improvements in public health. However, none of the solutions proposed would deliver this. On the contrary, they seem designed to mask the true scale of England’s air quality crisis rather than make any real attempt to solve it.
The proposals assume that reduced monitoring and reporting would lead to increased action on air pollution but we do not see how this could happen. Local authorities are facing severe financial restraints caused by Government spending cuts and if they are not obligated to measure air quality, there is a serious risk that they would not take measures to reduce the levels of pollution. Moreover, it is entirely unhelpful to restrict the scope of the review to local air quality management without considering the role of national government. There are widespread breaches of air quality limits, leading to a public health crisis, which need to be addressed at the national level as well as at the local level.
We would support a revised system which reduced the administrative burden on local authorities while increasing the onus on all tiers of government to tackle air quality. Any such system would need to be based on the following principles:
- Local authorities must have legal duties to assess local air quality, designate Air Quality Management Areas and take action to tackle air pollution
- Local action must go significantly further than current EU standards in order to protect public health
- The public have a right to participate in local action plans and receive annual progress reports
Options 3 and 4, which remove the legal duty on local authorities to assess air quality and designate Air Quality Management Areas, would lead to an ‘out of sight, out of mind’ situation. We agree with Leicester City Council’s assertion that ‘It is not practicable to ‘take account’ of air quality without a real-world evidence base of current conditions and trends.’ Local authorities cannot be expected to take effective measures to reduce air pollution without quantifying the problem. They will be powerless to stop highly polluting new developments and the impetus to take urgent action will be lost. Furthermore, the public will be unable to exercise their legal right to be informed about local air quality and hold those responsible to account.