Introduction

83% of roadside air pollution is caused by the exhaust, tyres and brakes of road vehicles. Electric vehicles will still create fatal levels of particulate air pollution - which is the most insidious of all - so whilst it will help, this is not the answer.

To reduce air pollution we need to reduce the number of vehicles. Which means using the car less. To do this we need available alternatives such as safe healthy walk and cycleways, clean air zones, an integrated and low pollution public transport system, etc.

Only our councils can deliver this.

This will help us to make the few changes to the way we live and work will bring benefits to health and wellbeing, boosting the local economy, whilst curbing climate change and reducing health inequalities.

If you just want to read one official document on air pollution A Briefing for Directors of Public Health 2017 is recommended.

Ipswich has had illegal air pollution for decades.  The worst areas are around Woodbridge Road, Crown Street, St Margarets Street, St Helens Street, the one-way system next to the Waterfront, Norwich Road and Chevallier Street. Link to all Ipswich Borough Council pollution documents

In 2015 Public Health England reported Ipswich as the 3rd worst place in the England for PM2.5 particulates. 

The health impacts of air pollution are starkly described by Public Health England, the World Health Organisation, Ipswich Borough Council and Suffolk County Council.

Public Health England has published a detailed evidence-based document describing the actions necessary to deliver healthy air.  Other towns and cities are starting to embrace the necessary changes.

Legally Ipswich Borough Council and Suffolk County Council must act together yet they have taken no effective action for 12 years.

Both councils recognise the illegal levels of air pollution and the health impacts but, although they are required to, they have no plan to deliver legal air in their latest Air Quality Action Plan, 2019-24 

The Director of Public Health is also expected to take a leadership role.

Health impacts of air pollution

World Health Organisation tells us worldwide ambient air pollution accounts for:

·       29% of all deaths and disease from lung cancer

·       17% of all deaths and disease from acute lower respiratory infection

·       24% of all deaths from stroke 

·       25% of all deaths and disease from ischaemic heart disease

·       43% of all deaths and disease from chronic obstructive pulmonary disease

·       Adverse birth outcomes, such as low birth weight, pre-term birth and small gestational age births. 

Public Health England (PHE) have produced a new tool to calculate NHS and social care costs of air pollution. Using this tool, it has calculated the cost in England could reach £5.3 billion by 2035 unless action is taken. All local authorities can use the tool to estimate the impact on health and the savings to the NHS and social care under different air pollution scenarios.

A Briefing for Directors of Public Health 2017 describes the various pollutants is a really good introduction to the subject and the role of local authorities and the Director of Public Health. If you only read one document, read this one. It states;

·       Particulate matter (PM) air pollution in the UK in 2008 to be responsible for the equivalent of 64,000 deaths. Of course, traffic has significantly increased since 2008….

·       Tackling air pollution is a priority for this government and that is why they have agreed legally binding UK targets to reduce emissions of the five key primary air pollutants1 by 2020 (through the UNECE Gothenburg protocol) and 2030 (as part of the National Emission Ceilings Directive).

·       Legal limits are in place to protect human health. However, it is recognised that there are no absolutely safe levels. Evidence suggests that health effects can still occur well below these limits.

Suffolk County Council Healthy Suffolk states;

·       The Department of Public Health estimated in 2014 that 118 people die early in Suffolk every year directly because of particulate air pollution.  63 people a year die in Ipswich.

·       Car drivers are exposed to nine times as much as cyclists.

·       The negative effects of air pollution impact on everyone in society, but the effects are disproportionately felt by those at extremes of age (young and old), as well as the socioeconomically disadvantaged.

·       Taking action to improve air quality is crucial to improve population health, and the optimise the public’s ability to benefit from Suffolk’s growth and prosperity.

·       The local authorities are legally required to collect data on the concentrations of specified air pollutants. They must declare an “Air Quality Management Area” (AQMA) where the concentration is predicted to exceed the legal limits. Government mandate local authorities take effective action to reduce these levels to legal limits and government targets.

·       There are currently 9 AQMAs across Suffolk, with 5 of these in Ipswich.

What needs to be done

 In 2019 Public Health England produced an excellent and comprehensive evidence-based  Review of interventions to improve outdoor air quality and public health.  This supports the HM Government A Green Future: Our 25 Year Plan to Improve the Environment, whose number 1 goal is ‘clean air’.

Recognising that each year 36,000 deaths in the UK are due to air pollution, and that most of the pollution is due to vehicles, these documents place children’s health and general health equality as top priorities. 

Unlike Ipswich, several UK cities and towns are embracing the actions necessary to protect its citizens.

Acknowledging that vehicles are overwhelmingly responsible for air pollution HM Government devolved a range of powers to the local authorities and charged them to deliver legal air. The Review of interventions  sets out the various devolved powers and concludes that a coherent and holistic range of interventions are required. For instance, to reduce pollution requires less vehicles on the road . For this to be successful appropriately routed, regular and inexpensive public transport is required together with safe cycle and pedestrian pathways.

HM Government also expect local authorities to work together. For instance Ipswich Suffolk County Council are responsible for Highways and Transport which will be required to put in place clean air zones or forbidding the dirtiest vehicles whilst Ipswich Borough Council are responsible for planning and development management and are responsible for an effective Air Quality Action Plan.

HM Government also makes it clear that ‘Improving air quality can go hand in hand with economic growth’ debunking arguments that we can’t afford actions to protect our health.

HM Government expects that ‘everyone has a role to play’. This includes all of us who live, work, visit or travel through Ipswich, businesses and local authorities. 

Devolved powers include;

·       forbidding the dirtiest vehicles or favouring clean vehicle fuels like petrol, LPG or CNG over diesel and bio-diesel

·       public and school transport policies

·       low or zero emission last mile services

·       traffic and parking management

·       street design and road layouts

National Institute for health and care excellence (NICE) NICE guideline [NG70] 2017 recommends taking a number of actions in combination, because multiple interventions, each producing a small benefit, are likely to act cumulatively to produce significant change. It includes recommendations on:

·        planning

·       development management

·       clean air zones

·       reducing emissions from public sector transport services and vehicle fleets

·       smooth driving and speed reduction

·       walking and cycling

·       awareness raising

Ipswich Borough Council and Suffolk County Council obligations

 Technical Guidance (TG16) February 2018 Section 3.2: There are obligations on both district and county councils within Part IV of the Environment Act. In summary, although district councils prepare the annual reports and Action Plans under LAQM, the Secretary of State expects lower and upper tier councils to work together to develop their content and, with respect to Action Plans, ensure that all necessary measures to address air pollution in their local area are included.

District Authorities - [Ipswich Borough Council, IBC]

Technical Guidance (TG16) February 2018 Section 3.4:  Under section 83 [IBC] is required to designate an Air Quality Management Area (AQMA) when …any of the air quality objectives are not being achieved.

Technical Guidance (TG16) February 2018 Section 3.5:  Under section 84, as amended by the Deregulation Act 2015 - Part 4 of Schedule 13, once an AQMA has been designated [IBC] should prepare an Air Quality Action Plan (AQAP) that sets out how it will achieve the air quality standards or objectives for the area that it covers. [IBC] should provide information on the timescales for the achievement of measures.

Technical Guidance (TG16) February 2018 Section 2.69:  As a minimum, AQAPs should include the following:

o   Quantification of source contributions…knowing the source of the problem will allow the AQAP measures to be effectively targeted;

o   Quantification of impacts of proposed measures. It should ensure that compliance is not just ‘possible’ but ‘likely’. It is important that the local authority shows how it intends to monitor and evaluate the effectiveness of the plan;

o   Clear timescales, including milestones and expected outcomes, which the authority and other delivery partners propose to implement the measures within the AQAP; and

o   Defined roles and responsibilities that detail how the local authority and other delivery partners, including transport, planning and health departments, will take ownership of the problem and in what capacity they will work together to implement the AQAP.

County Councils – [Suffolk County Council, SCC]

Technical Guidance (TG16) February 2018 Section 3.8:   …[SCC] have to proactively engage with [IBC] as soon as an air quality issue is identified.

Technical Guidance (TG16) February 2018 Section 3.9:  Where [IBC]is preparing an Action Plan, [SCC] are obliged under section 86(3) to submit measures related to their functions (i.e. local transport, highways and public health) to help meet air quality objectives in their local area. Under section 3.1 of the Air Quality (England) Regulations 2000, submission of these proposals should take place within at the latest nine months of first being consulted on the Action Plan by [IBC]. Earlier responses from [SCC] are encouraged in order not to delay the completion of the Action Planning process.

Technical Guidance (TG16) February 2018 Section 3.12:  As a result of the obligations set out above, the Secretary of State would expect [SCC] to actively engage at all stages of review, assessment and action planning in relation to LAQM in its area. Early engagement will not only ensure a more effective Action Plan but should ensure that no unnecessary costs or resources are spent on collecting and sharing the necessary information or securing agreements too late in the process.

The legal Framework

Tackling air pollution is a priority for this government and that is why they have agreed legally binding UK targets to reduce emissions of the five key primary air pollutants by 2020 (through the UNECE Gothenburg protocol) and 2030 (as part of the National Emission Ceilings Directive).

The five key primary air pollutants; sulphur dioxide, nitrogen oxides, non-methane volatile organic compounds, ammonia and fine particulate matter.

Under Part IV of the Environment Act 1995 local authorities have a statutory duty to monitor air quality levels and when they find them over the limit declare an Air Quality Management Area and produce an Air Quality Action Plan to reduce pollution to legal levels.

Our European-wide National legal levels will be passed into Environment Bill 2020 which also builds on Clean Air Strategy 2019  

Ipswich has 5 AQMAs covering much of central Ipswich, specifically;

Norwich Road double mini-roundabouts, along Chevallier Street to Waterloo Road

The Bramford Road/Yarmouth Road/Chevallier Street crossroads

From Electric House on Crown Street, along St Margaret's Street, Woodbridge Road and St Helen's Street as far as Palmerston Road

The Star Lane/College Street gyratory to the north of the waterfront

St Matthew's Street and Norwich Road, between the Civic Drive roundabout and Bramford Road

Department for Environment, Food and Rural Affairs (Defra) Technical Guidance (TG16) February 2018 describes what tiered authorities need to do and how they need to work together to deliver an AQAP with;

·      Quantified impacts of proposed measures. It should ensure that compliance is not just ‘possible’ but ‘likely’. It is important that the local authority shows how it intends to monitor and evaluate the effectiveness of the plan;

·      Clear timescales, including milestones and expected outcomes, which the authority and other delivery partners propose to implement the measures within the AQAP.

A little more detail on the guidance follows;

 Technical Guidance (TG16) February 2018 Section 3.2: There are obligations on both district and county councils within Part IV of the Environment Act. In summary, although district councils prepare the annual reports and Action Plans under LAQM, the Secretary of State expects lower and upper tier councils to work together to develop their content and, with respect to Action Plans, ensure that all necessary measures to address air pollution in their local area are included.

District Authorities - [Ipswich Borough Council, IBC]

Technical Guidance (TG16) February 2018 Section 3.4:  Under section 83 [IBC] is required to designate an Air Quality Management Area (AQMA) when …any of the air quality objectives are not being achieved.

Technical Guidance (TG16) February 2018 Section 3.5:  Under section 84, as amended by the Deregulation Act 2015 - Part 4 of Schedule 13, once an AQMA has been designated [IBC] should prepare an Air Quality Action Plan (AQAP) that sets out how it will achieve the air quality standards or objectives for the area that it covers. [IBC] should provide information on the timescales for the achievement of measures.

Technical Guidance (TG16) February 2018 Section 2.69:  As a minimum, AQAPs should include the following:

o   Quantification of source contributions…knowing the source of the problem will allow the AQAP measures to be effectively targeted;

o   Quantification of impacts of proposed measures. It should ensure that compliance is not just ‘possible’ but ‘likely’. It is important that the local authority shows how it intends to monitor and evaluate the effectiveness of the plan;

o   Clear timescales, including milestones and expected outcomes, which the authority and other delivery partners propose to implement the measures within the AQAP; and

o   Defined roles and responsibilities that detail how the local authority and other delivery partners, including transport, planning and health departments, will take ownership of the problem and in what capacity they will work together to implement the AQAP.

County Councils – [Suffolk County Council, SCC]

Technical Guidance (TG16) February 2018 Section 3.8:   …[SCC] have to proactively engage with [IBC] as soon as an air quality issue is identified.

Technical Guidance (TG16) February 2018 Section 3.9:  Where [IBC]is preparing an Action Plan, [SCC] are obliged under section 86(3) to submit measures related to their functions (i.e. local transport, highways and public health) to help meet air quality objectives in their local area. Under section 3.1 of the Air Quality (England) Regulations 2000, submission of these proposals should take place within at the latest nine months of first being consulted on the Action Plan by [IBC]. Earlier responses from [SCC] are encouraged in order not to delay the completion of the Action Planning process.

Technical Guidance (TG16) February 2018 Section 3.12:  As a result of the obligations set out above, the Secretary of State would expect [SCC] to actively engage at all stages of review, assessment and action planning in relation to LAQM in its area. Early engagement will not only ensure a more effective Action Plan but should ensure that no unnecessary costs or resources are spent on collecting and sharing the necessary information or securing agreements too late in the process

UK Defra’s table of legal limits and targets and World Health Organisation guidelines for all pollutants includes;

·       NO2

·       EU/UK (Defra) 40 μg/m3 annual mean

·       WHO 40 μg/m3 annual mean, 200 μg/m3 1-hour mean

·       Particles (PM10) 

·       EU/GB (Defra) 50 μg/m3 not to be exceeded more than 35 times a year

·       WHO 20 μg/m3 annual mean, 50 μg/m3 24-hour mean

·       Particles (PM2.5)

·       EU/UK (Defra) 25 μg/m3 annual mean

·       WHO 10 μg/m3 annual mean, 25 μg/m3 24-hour mean

 The 2019 Clean Air Strategy (UK)…. we will reduce PM2.5 concentrations across the UK, so that the number of people living in locations above the WHO guideline level of 10 μg/m3 is reduced by 50% by 2025.

The UK Clean Growth Strategy, 2017, sets out measures which will reduce both CO2 emissions and air pollutant emissions from the transport sector. Delivering the significant air pollutant emission reduction we require demands transformational change for our transport network and how we use it. The tools and technologies that will help achieve this are becoming available. Many deliver broader benefits as well as improving air quality, such as greater energy security and reduced congestion. The Industrial Strategy, published in 2017, set the ‘Future of Mobility’ Grand Challenge for the UK to become a world leader in the way people, goods and services move. The Challenge is supported by the £2.4 billion Transforming Cities Fund which aims to invest in new local transport infrastructure to boost productivity by improving public and sustainable transport connectivity. 

The role of the Director of Public Health

Local authorities have, since 1 April 2013, been responsible for improving the health of their local population. Health and Social Care Act 2012. Section 12 of the 2012 Act introduced a new duty for all upper-tier and unitary local authorities in England to take appropriate steps to improve the health of the people who live in their areas

A Briefing for Directors of Public Health 2017 describes the DPH role and provides information to support them.

The DPH should be a key local champion of air quality improvement, by informing and influencing their peers in local transport, planning, sustainability and other departments, and by getting the message out to the general public to ensure acceptance of air quality related measures and promote behaviour change where necessary.

The DPH is expected to play a key role in generating a deeper cultural shift in the approaches taken by Local Authorities to air quality reduction: from a passive regulatory stance to one of active stakeholder engagement.

The DPH is expected to;

1. Assess and prioritise

2. Engage senior decision makers

3. Lead and champion action

4. Scrutinise impact of actions

5. Inform and communicate