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LB of Hillingdon Air Quality (Pollution) Action Plan West London FOE Comments |
We would like to complement LB of Hillingdon on the thorough approach and the detailed analysis that has gone in producing the Action Plan (AP). However, we have major concerns about the plan as drafted:
Our concerns are explained below.
We do not feel this is a proper summary. It gives an introduction to the AP and outlines how it has been developed. But, crucially, it does not summarise the conclusions - for example what the situation is now, how it is likely to evolve, what the plan is and what effect it will have. Without these, it does not present a useful a summary for those who do not have time to study some 100 pages of detailed text. This means in practice community groups, councillors and virtually all other parties will not be able to gain insight into the issue of air pollution or the AP.
3.1 The plan does not explain why air pollution is a problem in general terms; for example that it kills some 24,000 pa in the UK, causes acute and chronic ill-heath, corrodes and damages buildings and structures and damages biodiversity and costs billions of pound. Nor does it describe the impacts in LB of Hillingdon, which are probably worse than in most of the UK.
3.2 We believe that the present air pollution levels are an important public issue and that people should have a right to breathe clean air. This ought to be the context of the plan (and indeed other strategies and policies in LB of Hillingdon). Only if people are aware of the gravity of the issue will they become interested and prepared to take action or support action by others.
3.3 In contrast, the AP seems to be regarded just as a bureaucratic exercise which has to be carried out because central government says so and because there is a set of air quality objectives that the government says ought to be met. There is nothing to engage the populace, local groups or councillors which would make them think it is an is issue which needs their attention. The very expression "air quality" in the title seems designed engender lack of interest. The issue is air pollution, which is more emotive and quite rightly so.
4.1 Box 1, p22 states an objective "To pursue the air quality objectives laid down in the national Air Quality Strategy, whilst .. improving the quality of life and health of the residents and workers in Hillingdon.. " We do not understand the relevance of "whilst". The object of the air quality objectives is precisely to protect quality of life and health - these are not things to be achieved simultaneously with some other (unstated) objective of meeting the standards.
4.2 Box 2, p22. We do not agree that the object should be just to "pursue" standards. It should be to achieve them. If the objective is only to pursue them, it means that any action or lack of it, and any amount of air pollution, however harmful and however many people it kills, can be construed as consistent with successful implementation of the strategy.
4.3 The strategy only refers to UK and EU objectives and standards set to protect human health. While these may be considered the most important, they are not the only considerations. Of particular relevance is the WHO guideline for NO2 of 30ug per m3 annual average to protect vegetation, which has been accepted by the UK government. In a detailed strategy over around 100 pages, the absence of even a mention is serious omission, which could lead one to infer that LB of Hillingdon has no interest in protection of open spaces, Green Belt or preservation of biodiversity.
4.4 There is no discussion of pollutants other than NO2. Particulates are a serious health issue and while the UK and EU standards may not be breached, the levels are close enough to the limits to merit discussion and an explanation as to why they are not addressed in the AP. Of particular relevance is the fact that it is only because standards for PM10 have been weakened such that pollution levels well above the levels needed to protect human health are now allowable. While we understand that LB of Hilllingdon may not wish to address PM10s because they do not breach the current objectives, we believe that it nonetheless has a duty to be open and inform people about the issue.
4.5 Following from 4.3 and 4.4, we consider that the scope of the objectives is too narrow. The aim should be for all citizens to have air that is fit to breath and which protects man-made structures and biodiversity. While we recognise that protection of human heath should be the most important objective, it is not only one. Nor do we accept that the object should be just to achieve the current government objectives - as noted above these alone will not fully protect human health, let alone achieve other objectives.
5.1 We do not understand the basis on which the effects of the various options have been estimated. Firstly, it is not clear what baseline the change in emissions and concentrations refers to. Is it the change from the present levels or the change from the expected level at some point in the future in the absence of the action?
5.2 Secondly, many of the options consist not of actions 'on the ground' but something such as an evaluation or pursuing an aim. That action cannot of itself have an effect on air pollution - it is only the tangible action that might result that could do so. This being so, it is necessary to state what outcome has been assumed and why. For example action 4.06 is "Evaluate best practice from European and International airports with regard to the minimisation of air quality impacts and assess feasibility of application at Heathrow." This is estimated to lead to a reduction in NOx emissions of 2.9%, so clearly some tangible (and significant) outcome is assumed. But action 4.07 is "Work with National Government to ensure the use of all relevant fiscal measures to reduce emissions from Heathrow in order to achieve the 2010 EU limits." This is estimated to have no effect, which implies that no tangible outcome is envisaged.
5.3 There is a huge improvement shown - 14.5% reduction in emissions - for action 4.10 "Audit progress on the BAA Heathrow Air Quality Action Plan (2001-2006)." We question how the figure can be so large since BAA has no plan to control emissions from aircraft, the main source of pollution from the airport. Equally as important, we question whether it is appropriate to register any benefit. If it is already a BAA plan, then surely it is a component of the baseline against which this AP is evaluated. In this case no improvement should be shown. Only further measures, ie action 4.13, that can be assessed as potential improvements. We are very concerned that the 14.5% reduction, taken in conjunction with the low figures for all the other actions, could lead people to conclude that no action is needed other than what BAA is already planning to do. Such 'greenwash' may suit BAA and some others, but it would be quite wrong for a borough strategy to give credence to such a view.
As Hillingdon Council is well aware, a huge incinerator at Colnbrook, just
west of the borough boundary has been granted planning permission by Slough
council. This would be one of the biggest incinerators in Europe and would emit
large quantities of pollution. However, Grundon, the recipients of the planning
permission, have not decided whether to build the plant. It seems likely that
the incinerator would make a difference to air pollution levels in the borough.
We therefore consider that there should be explicit mention in the AP. The forecast
contribution of the incinerator should be shown. Also, as it has not been decided
whether it will go ahead, the incinerator ought to be shown as an option in
its own right so that readers of the AP can see its potential impact and the
effect of stopping it.
7.1 There is reference to the cost and cost-effectiveness of actions in AP. The costs will undoubtedly be a constraint on action and will almost certainly be used as a reason (excuse?) not to take action. Anything which can be claimed to impact adversely on business costs or the economy is used to try and forestall action on any form of environmental protection, air pollution being no exception. This being so, it is important that the economic costs of air pollution and the corresponding economic benefits of reducing pollution are mentioned.
7.2 If reference is made only to the costs of action and by implication economic costs, but no reference is made to the economic benefits, the AP contains what is, in effect, a built-in bias against action. It ignores the 'Polluter Pays Principle'. Polluter Pays specifically addresses the economic cost of pollution, it requires that polluters should pay to reduce their pollution and should pay compensation for pollution that remains, and it has a sound economic basis.
Although there are some 100 pages and a comprehensive selection of options evaluated, there is no clear conclusion from all this study and analysis. The reader will surely want to know at least the following:
Nov 2004
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