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Bright Blue, the independent think tank for liberal conservatism and home of conservative modernisers, has today published a new report, Emission impossible? Air pollution, national governance and the transport sector,  which proposes new legal limits, legal responsibilities and policies to significantly reduce levels of air pollution in the UK after Brexit.

The report focuses on the sources of, impacts of, and attitudes towards air pollution across the whole of the UK. It then goes on to explore the role national Government does and could play in reducing air pollution, particularly from NO2, since this is the one pollutant where this country does not meet current EU-derived legal hourly and annual limits.

The report contains the results of new polling of UK adults on air pollution, showing:

  • A clear majority (71%) of UK adults reported that they were concerned about the impact of air pollution on the health of themselves and others.
  • A clear majority (69%) of adults agree that the Government should reduce air pollution below current levels.
  • When asked whether the UK should have cleaner air then other EU countries, roughly half (49%) of adults thought the UK should have cleaner air, and only 9% thought the UK should not.

William Nicolle, Researcher at Bright Blue and co-author of Emission impossible?, says:

“Stronger evidence has emerged in recent years about the detrimental impact of air pollution to human health, the economy and the environment. Consequently, there is growing public and political pressure for tougher action to reduce levels of air pollution in the UK. The UK’s departure from the EU means that there is an opportunity to raise air pollution standards in the UK.”

“The UK Government needs new, ambitious legal limits, legal responsibilities and policies on air pollution. This country should aspire to be a global leader on yet another environmental issue, and strive to become the country with the cleanest air in urban areas in the developed world.”

Bright Blue’s main policy recommendations for increasing national accountability on air pollution are:

  • Adopt the World Health Organisation’s (WHO) guideline limits for concentrations for all health-harming air pollutants as soon as possible after a feasibility study by the OEP or a new Committee on Clean Air. The WHO have their own recommended limits for PM2.5, PM10, NO2 and O3. These are more demanding than the current EU-derived limits. Recently, DEFRA stated they believed the WHO’s recommended PM2.5 limit was “technically feasible”, but further analysis was needed as to its economic and practical feasibility. We recommend the Government adopts all the WHO guideline limits for PM2.5, PM10, NO2 and O3 as soon as possible, but only after a feasibility study conducted by the Office for Environmental Protection (OEP) or a new Committee on Clean Air.
  • Provide the Office for Environmental Protection (OEP) or a new Committee on Clean Air with the responsibility to recommend future legal limits for different air pollutants to parliament after conducting appropriate feasibility studies. For the OEP to be able to properly uphold environmental standards, it should be given the power to recommend those standards to parliament. We recommend that the OEP, or a new Committee on Clean Air, be given the power to recommend future legal limits for air pollutants to parliament following appropriate feasibility studies. This will be similar to the role of the Committee on Climate Change’s (CCC) role in advising the UK Government on greenhouse gas emission targets, so that the setting of air pollutant targets will be properly evidenced and scrutinised.
  • Provide the Office for Environmental Protection (OEP), or a new Committee on Clean Air, with the responsibility to recommend future targets for different air pollutants, specifically focussed on additional targets relating to concentrations by population density and deprivation. We recommend the OEP, or a new Committee on Clean Air, should be able to propose new future national targets that take into account two new considerations: first, population density; and, second, deprivation. These targets would be additional to the existing ones the UK has and, therefore, would not detract from any existing targets.
  • Legal duties should be placed on all local authorities to achieve compliance with relevant legal air pollution limits within their geographic area of responsibility. Relevant public bodies should have a legal duty to contribute to achieving compliance with legal air pollution limits within their geographic area of responsibility. Local authorities are obliged to monitor, review and if appropriate take action in relation to the air pollution within their boundaries. But local authorities do not have a clear legal responsibility to reduce air pollution below legal limits. Equally, other public authorities that control some sources of air pollution do not face legal obligations to reduce air pollution levels to below legal limits in areas where they have authority. We recommend that all local authorities have a legal requirement placed on them to achieve compliance with legal air pollutant limits in their geographic area of responsibility. We also recommend that relevant public bodies should have a new legal duty placed on them to contribute to achieving compliance with legal air pollution limits within their geographic area of responsibility. The OEP, or a new Committee on Clean Air, should be tasked with identifying the relevant public bodies and putting these recommendations to parliament.

Bright Blue’s main policy recommendations for reducing air pollution from the transport sector are:

  • Lift the freeze on the value of Fuel Duty and apply a surcharge on Fuel Duty for diesel fuel (a ‘Diesel Duty’). The current Government committed to freezing the value of fuel duty yet again last year, meaning it has been frozen since 2010. We recommend ending the freeze on the value of fuel duty from the next tax year. In addition, diesel fuel should attract a surcharge of fuel duty in its sale. This could be badged as a ‘Diesel Duty’.
  • Introduce an ongoing surcharge for Vehicle Excise Duty (VED) on new diesel cars in the UK (‘Diesel Excise Duty’ (DED)). At present, there is a higher charge faced by drivers of diesel vehicles only on their first VED payment. After the first year of VED payment, petrol and diesel cars are subject to the same ongoing VED payments, and electric cars are fully exempt. We recommend that a diesel surcharge on ongoing VED payments be introduced in the next tax year. Together with the tiered initial payment, this would create a separate ‘Diesel Excise Duty (DED), for all new diesel vehicles registered.
  • Exempt the purchase of ultra-low emission vehicles (ULEVs) from VAT. Ultra-low emission vehicles (ULEVs) are defined as vehicles that emit less than 75 grams of carbon dioxide (CO2) per kilometre travelled (g/km). Recently, it was forecast that EVs will only be 75% of new vehicle sales by 2040 based on current incentives – falling short of the Government’s target of phasing out fossil fuel car purchases by 2040. We recommend that VAT should be scrapped on the purchase of all categories of ULEVs in the UK.
  • Enable local and combined authorities to strive for ‘reasonable profits’ from their charging Clean Air Zones (CAZs) to fund further local air pollution abatement policies. Local authorities cannot set charges in CAZs to raise revenue. Any additional revenue raised from CAZs must be reinvested to “facilitate the achievement of local transport policies”. We recommend the Government allows local and combined authorities to pursue ‘reasonable profits’ from their CAZs, as long as they are reinvested to pursue policies that will tackle roadside air pollution. We suggest the following criteria areas for these reasonable profits to be spent on: charging infrastructure for EVs; local scrappage schemes for diesel and petrol cars; and, local transport objectives, as currently defined. We propose that the reasonable profits raised need be first allocated to investment in EV infrastructure and local scrappage schemes for both diesel and petrol cars, prior to being used for the pursuit of local transport objectives.
  • Mandate introducing charging or banning Clean Air Zones (CAZs) for non-road mobile machinery (NRMM) alongside the establishment of all charging CAZs in England. There are CAZs for vehicles being introduced over in different cities across the UK in the years ahead. Local authorities are expected to follow DEFRA’s statutory guidance on establishing CAZs, which suggests they should, if appropriate, seek to implement minimum emissions standards for NRMM to be used within their Clean Air Zones. Nonetheless, there are no CAZs for NRMM in the UK at present, only London’s ULEZ for NRMMs. We recommend, alongside future charging CAZs for vehicles, it should be mandatory for any new charging or banning CAZ to be established. As with the London ULEZ, exemptions should apply to NRMM in a banning CAZ that is not otherwise available, or where comprehensive retrofitting is not feasible.
  • Make it a requirement for local authorities with a charging CAZ to introduce a citizen-based reporting system to increase the enforceability of anti-idling measures. In the City of New York in the US, there is a system in place to allow citizens to report commercial trucks and buses that are idling for longer than the legal three minutes – or for longer than one minute if outside schools – through taking photographs and videos and filling out an online form run by the City of New York government. Citizens who report polluters get a 25% share of the income from the fine imposed. Alongside proposed new powers to enable local authority traffic officers to instantly apply fines for stationary idling, we recommend local authorities with a charging CAZ should be required to introduce such citizen-based reporting of stationary idling. If a fine is imposed, citizens could receive a portion of the fine, with the remainder going to the local authority to be spent on other local air pollution abatement policies. We further recommend the government consult on expanding this citizen-based reporting system from the City of New York to passenger vehicles.
  • Replace the current 30mph default speed limit on all ‘restricted roads’ in England and Wales with a 20mph default speed limit. In urban areas, speed limits are automatically set on ‘restricted roads’ at 30mph, unless specified as not. Local authorities do have the power to lower speed limits below the national speed limit. Evidence shows that 20mph speed limits are beneficial in terms of lowered amounts of pollutants being emitted by vehicles, particularly for NOx and PM. Generally, arguments for the lowering of speed limits to 20mph are framed in terms of public safety, but there is now also a solid evidence base to be made for it lowering air pollution from vehicles. We recommend that the default national speed limit on all ‘restricted roads’ in England and Wales be lowered from 30mph to 20mph.
  • Require the installation, checking and cleaning of particulate matter filters on all petrol cars through the annual Ministry of Transport (MOT) test. Some petrol cars, specifically those that use direct injection engines, can emit more PM than conventional diesel cars. This is because modern diesel cars are normally fitted with diesel particulate filters (DPFs), meaning the PM they generate is filtered out of the exhaust fumes. Petrol cars, however, largely lack these filters. Recent regulation means it is likely that most new petrol cars sold will have gasoline particulate filters (GPFs) fitted. But the existing stock of petrol cars in the UK continue to emit PM into the air unabated. We recommend that, as part of the annual MOT tests, any petrol car without a GPF be required to have one installed. GPF filters are relatively cheap, on average costing £25. As part of the annual MOT test, the checking and, if appropriate, cleaning of the GPF should also be a requirement, as is currently required for Diesel Particulate Filters (DPFs).