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Air Quality Targets: Unambitious, Unscientific And Unable To Solve The Deadly Problem Of Air Pollution

A year ago today (21 April 2021), the Coroner presiding over the inquest concerning the death of Ella Adoo-Kissi-Debrah published his Prevention of Future Deaths Report. In the report he put forward three crucial recommendations that he saw as necessary to prevent the ongoing risk to life posed by air pollution. In summary, they were:

  1. Adopt legally binding targets of Particulate Matter based on the minimum requirements for the protection of health, as set out in the World Health Organization (WHO) guidelines.
  2. Improve public information at a national and local level about air pollution levels so that people are aware of how to reduce their exposure (including increasing air quality monitoring capacity).
  3. Educate and train medical and nursing professionals, and improve guidance for the public about the adverse effects of air pollution on health.

These recommendations were based on what the Coroner learned over the course of the inquest from air pollution specialists who provided expert evidence to the Court.

Ella, who lived near London’s busy south circular road, was exposed to high levels of air pollution, both chronically and during acute episodes, which were in excess of WHO Guidelines. The Coroner found that this made a significant contribution to the induction and exacerbation of her asthma, as well as her death in 2013.

The government’s response so far

A year on from the Coroner’s report and the response from the UK government has been woeful – none of these recommendations have been implemented and the current forecast does not look promising.

There is currently ripe opportunity for the government to act upon the Coroner’s first recommendation – to implement targets for Particulate Matter in line with the WHO’s guidelines. The Environment Act 2021 requires the government to set at least one long-term target for air quality and one specifically for fine particulate matter (PM2.5). This is a once-in-a-generation piece of legislation. The children born today will grow up breathing in the levels of air pollution that this government permits.

Insufficient air pollution targets

On 16 March 2022, the Department for Environment, Food & Rural Affairs (DEFRA) launched a public consultation regarding these targets. In the consultation paper, the government sets out their proposed air quality targets as follows:

  1. Annual Mean Concentration Target (‘concentration target’) – a target of 10 micrograms per cubic metre (µg m3) to be met across England by 2040.
  2. Population Exposure Reduction Target (‘exposure reduction target’) – a 35% reduction in population exposure by 2040 (compared to a base year of 2018).

The annual target proposed is double the current WHO guideline value of 5 μg/m3 and therefore fails to follow the Coroner’s first recommendation. It reflects the now redundant 2005 WHO guideline value of 10 μg/m3. With a 2040 target date, the value will be 35 years out of date by the time it is due to be implemented making it insufficient. In setting their guidelines, the WHO rely on up to date health-based evidence. Their updated guidelines reflect the mounting evidence that air pollution even at low concentrations can have a deadly effect. Markedly, the WHO have asserted that there is no safe limit for PM2.5 and no threshold has been identified below which no damage to health is observed 1, hence the much needed reduction in their guideline value in 2021.

The proposed target from the government does not follow what scientific and medical evidence is showing is necessary to protect human health and lives. The distant target date of 2040 (as opposed to what many had hoped would be at least a 2030 cut off) undermines the government’s assertion that this is an issue they take seriously. It is currently estimated that every year 40,000 deaths in the UK are attributable to exposure to air pollution. Delaying implementation until 2040 will continue to leave the UK public exposed to dangerous levels of air pollution for many years to come. This has left many campaigners and members of the public to comment that the proposals are too weak and too slow.

The human and economic cost of the public health crisis

By implementing the WHO’s air quality guidelines, it is estimated that the number of global premature deaths linked to PM2.5 would be cut by 80% 2. Given that according to the government’s own figures, the health and social care cost of air pollution will be over £5 billion by 2035, it is clear that effecting the WHO guideline value makes sense from an economic as well as a humane and scientific perspective.

The inquest into Ella’s death showed that air pollution is a public health crisis. As such it requires the government to commit to not only cleaning up the air but to also ensuring that the public is aware of the associated dangers and offer effective medical treatment when needed. The Coroner’s recommendations clearly and simply detailed what needed to be done. They were based on evidence presented by leading medical experts and scientists in the field of air pollution yet they have to date been ignored.

The environment secretary, George Eustice, has said that in a post-EU era, the new system of targets will place more emphasis on science as opposed to the legal system. However the government cannot ignore its legal obligations to protect public health. Furthermore, this ’emphasis on science’ is far from evident in the government’s current proposals. DEFRA has yet to provide the background information and evidence relied upon to explain why it is proposing a PM2.5 target that is weaker than the WHO’s guidelines. Given the clear disregard of the WHO and Coroner’s recommendations, both of which were based on scientific evidence, it is clear that there is an ongoing failure by this government to put public health – and science – at the core of its of air quality policy.

The consultation closes on 11 May 2022 and responses can be submitted online here.

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