Hillingdon Publishes Air Quality Action Plan

The borough of Hillingdon has published its 'Air Quality Action Plan' (AQAP). Comment has been invited by 'stakeholders' including West London Friends of the Earth.

Hillingdon's AQAP follows on from the government's 'Air Quality Strategy' (ie air pollution strategy), which was launched in Jan 2000. That strategy sets out air quality targets for the main air pollutants, which each local authority has to work towards.

'Air Quality Management Areas' have to be declared if pollution is forecast to exceed standards set by the government to protect human health. 'Action Plans' have to be instituted to bring the air to within standards. However, there is wonderful 'get-out'. While local authorities have to produce Action Plans, the Act places them under no obligation to succeed in reducing air pollution to safe levels !

Hillingdon's officers have worked very hard in producing this long and detailed document. But it is not really a plan. It consists largely of a catalogue of possible actions which in most cases show a predicted effect on emissions of nitrogen oxides (NOx). The effect on actual air pollution is not shown. There is no analysis of what needs to be done to bring air within standards across the borough, let alone a plan to actually to do so.

HIlingdon's current air pollution

Much of Hillingdon's air is not fit to breathe. About one third in the south the borough (mainly red and yellow on the map) suffers from air which breaches the government's standards for NO2 set to protect human health. The middle third fails to meet the standards to protect vegetation (mainly green on the map below). Only the northern third is of reasonably good quality in respect of NO2 (blue and grey).

Hillingdon's Estimated NO2 Air Pollution (Ack. to Hil Council)

There is also some concern about levels of 'small particulates' or 'PM10s'. These are tiny particles which penetrate deep ino the lungs and may cause heart disease or cancer. While the air is not forecast to breach the current UK standards, those standards have been weakened from the original standards which were set to protect human health. The issue is not mentioned in the AQAP.

What does Hillingdon's air pollution come from?

The Action Plan very helpfully shows the main sources from within the borough of air pollution:

Sector	Emissions (tonnes/year)	% of total emissions
Domestic combustion	320	5.0
Commercial & small industrial combustion Sector	165	2.6
Council heating	15	0.2
Non-Council heating	15	0.2
Regulated industry (note 1)	215	3.3
Airport on-site activities (note 2)	3570	58.2
Public transport	515	8.0
Road transport - Heavy Goods Vehicles (HGVs)	605	9.4
Road transport - Light Duty Vehicles (LDVs) other than cars	145	2.3
Road transport - Cars	645	10.0
Road transport - Council fleet	30	0.5
Road transport sub-total	1690	26.2
Other	20	0.3
Total	6440

Notes:
1. 'Regulated industries' are usually medium or large industrial plants which are monitored and controlled by the Environment Agency.
2. 'Airport on-site activities include, in order of importance: aircraft, airport road traffic and other airport (fixed) sources.

The relationship between the emissions (distributed as in the table above) and the actual concentrations at any point (as shown on the map above) is complex. It depends on atmospheric chemistry, patterns of dispersion and on pollutants emitted outside the borough but carried in. Nonetheless, it gives a general indication of where action to reduce emissions is most likely to be effective in reducing level of pollution in the air.

Comments on the Action Plan

Hilingdon Council undertook a 'consultation exercise' over the original draft and West London Friends of the Earth attended and made extensive comments. Sadly, however, virtually none of our comments have been incoporated in the draft Action Plan now published.

Hillingdon Council has little control over the operations of the biggest source of pollution, Heathrow. It also has little control over the amount of traffic on the trunk roads that run through the borough. It therefore has a major problem in producing a meaningful Action Plan. But whatever the reason, and whoever is to blame for the situation, the fact remains that the AQAP is not a real plan and that there is no intent to bring air pollution levels to within the standards necessary to protect human health. This fundamental point must not be fudged and it underpins our response to the draft AQAP.

West London Friends of the Earth has submitted a response to the draft AQAP - see our comments (web page) or Word document.

Links to Related Pages

Updated Dec 04