Consultation outcome

Summary of responses

Updated 14 June 2019

Introduction

The Secretary of State for Environment, Food and Rural Affairs published a UK National Air Pollution Control Programme (NAPCP), on 1 April 2019. Prior to publication the draft NAPCP was subject to a four week consultation which ran from 14 February 2019 to 14 March 2019. This document provides a summary of the consultation responses received.

The NAPCP is a UK wide document and sets out the proposed measures and technical analysis which demonstrate how the legally binding 2020 and 2030 emission reduction commitments (ERCs) for 5 damaging pollutants (nitrogen oxides, ammonia, non-methane volatile organic compounds, particulate matter and sulphur dioxide) can be met across the UK.

The NAPCP is a largely technical document which assesses the emission reduction (abatement) potential of a range of measures to be deployed across the UK, based broadly on the commitments published in the Clean Air Strategy. Estimates of the impacts of these measures are made for each pollutant in terms of emission reductions. Each UK administration has its own current and planned emission reduction commitments and this has been factored in when preparing the document and conducting the analysis.

Consultation content

The consultation sought views on the draft NAPCP and the use of the estimates of abatement associated with the policy measures. It also provided the opportunity to submit additional or alternative analysis or evidence that could be used.

The consultation posed 8 key questions, the first of which asked about the estimates of abatement associated with the policy measures. The next 6 questions linked specifically to the package of measures associated with specific industries (road transport, shipping, other transport, domestic, agriculture and industry). The final question related to the development of further measures the UK government or the devolved administrations could incorporate in the future to help to achieve the UK ERCs most effectively.

Consultation responses

The consultation received a total of twenty-eight responses. The responses came from a range of different stakeholders including individuals, businesses, trade associations, NGOs and local authorities. We received responses from all areas of the UK.

Question 1: Do you agree with the estimates of abatement associated with the policy measures in the NAPCP?

This question had a set of closed answers: Agree, Neutral, Disagree and Don’t Know. Of the twenty-seven respondents that answered this question, eleven picked Don’t Know, nine picked Disagree, four picked agree and three picked neutral. One of the respondents did not answer this question.

Question 2: Within the package of measures on road transport do you have any concerns about the estimates provided on any of the pollutants below?

We received eleven responses specifically relating to Nitrogen Oxides (NOx), one response about Non-methane Volatile Organic Compounds (NMVOC) and four responses on Fine Particular Matter (PM2.5). A number of respondents commented that there was too little focus on modal shift within the data.

Of the responses which focused mainly on NOx emissions, one response questioned whether the NAPCP analysis included existing NO2 plans and others requested the inclusion of anticipated emission reductions arising from individual Policies and Measures (PaMs) and a more detailed explanation of the methods and assumptions applied in calculating anticipated emission reductions.

The response relating specifically to NMVOCs suggested that the government should focus on technologies to recycle NMVOCs into vehicle engines.

Two responses on PM2.5 questioned the government projections of PM2.5 and whether the emissions could meet targets. A single response detailed that the estimations placed too much emphasis on burning reductions and should instead focus on PM produced from vehicles. Two responses suggested that modal shift could reduce vehicle PM2.5 by encouraging cycling and walking. Another response suggested shifting goods transport to less polluting methods such as rail transport.

Question 3: Within the package of measures on shipping do you have any concerns about the estimates provided on any of the pollutants below?

We received five responses specifically relating to Nitrogen Oxides (NOx), four responses about Sulphur Dioxide (SO2) and two responses about Fine Particular Matter (PM2.5).

A single response from industry explained that NOx and SO2 reductions in shipping emissions would be dependent on the way in which this sector responds to the implementation of the IMO MARPOL VI regulations in 2020. However, the same respondent also stated that they believed that the SO2 reductions would be higher than stated in the NAPCP due to the implementation of shipping emission control areas (ECAs).

Another industry response, linked to both NOx and SO2, highlighted the importance of modal shift in relation to industry. The response focused particularly on the emissions reductions which could be achieved in shifting from road to freight train when delivering aggregates.

Question 4: Within the package of measures on other transport do you have any concerns about the estimates provided on any of the pollutants below?

Four responses were received, all of which linked specifically to NO2 reductions.

One respondent believed that the expected reductions in this area were highly ambitious, due to the investment needed in order to deliver the emissions reductions identified in the rail industry. For example, significant investment in the electrification of the rail network and the use of hydrogen fuel cell powered trains. The same respondent also highlighted the investment needed in non-road mobile machinery (NRMM) used for agriculture and construction, which is a significant contributor to NOx emissions.

Another respondent noted that the additional measures needed to abate emissions from NRMM must not jeopardise the momentum behind the existing regulatory changes, and must allow appropriate time for these changes to come into effect. For example, Stage IV NRMM emissions regulations were introduced in 2014, and reflect significant improvements in NRMM emission reductions once they have taken effect.

Question 5: Within the package of domestic measures do you have any concerns about the estimates provided on any of the pollutants below?

We received thirteen responses about domestic measures. Of these, six raised concerns about policies that control domestic burning. Their primary concern related to the difficulty in converting domestic consumers from wood heating to electrification when electrification can be more expensive and consumers view wood as a renewable source.

Respondents also raised concerns about proposed reductions to domestic gas and oil burning as many off-grid households are dependent on these heating sources and the proposed NOx reductions are overly dependent on electrification.

We received five responses relating to Particular Matter (PM2.5). Specifically, one respondent questioned whether the measures selected had been prioritised by their health impacts and if black carbon emissions had been factored into the health assessment which underpins the selection of measures. Again, another respondent highlighted that the emissions reductions were highly dependent on the electrification of domestic heating.

Finally, one response called for further segmentation of SO2 from domestic burning and energy generation.

Question 6: Within the package of measures on agriculture do you have any concerns about the estimates provided on any of the pollutants below?

We received six responses relating to Ammonia (NH3). Some responses raised the high degree of uncertainty inherent in emission reduction projections and encouraged the introduction of robust regulation as soon as possible. They also suggested supplementing the regulation with penalties for non-compliance, in order to ensure compliance with the 2020 emission reduction commitments (ERCs). The responses were also concerned that the lower range of emission reductions for ammonia in the government’s current proposals would not be sufficient to meet the UK’s 2030 ERC. One respondent suggested the introduction of agricultural codes as a means of complying with the legally required NH3 emission reductions.

One response focused on concerns about digestate and suggested that the treatment of digestate would be a more lasting solution than the covering of digestate lagoons.

We received one response in relation to Nitrogen oxides (NOX), highlighting recent research findings that nitrogen fertilisation will increase NOX emissions from soils in the drier parts of the UK, increasing in the future in response to climate change. The concern is that fertiliser-induced NOX emissions can be the main source of atmospheric NOX in rural areas, and may ultimately reduce crop yield.

One response raised points specifically in relation to Wales. For example, concerns over the assessment being based on the Defra Clean Air Strategy and therefore potentially not including the full suite of measures for the devolved administrations, and a respondent who did not support a regulatory approach to ammonia emission reductions from agriculture in Wales, instead preferring an advice-led and incentivised approach. Concern was raised regarding the Welsh Government’s draft supplement to the Code of Good Agricultural Practice which was felt not to provide sufficient guidance to the agricultural industry. Officials have since met with key stakeholders, and there has been mutual agreement about their future involvement in the development of the Clean Air Programme and Plan for Wales.

Question 7: Within the package of measures on industry do you have any concerns about the estimates provided on any of the pollutants below?

Most responses to this question focused primarily on NOx emissions. Some respondents raised concerns around how proposed measures would allow the UK to meet the 2030 NOx targets and requested further detail and more granular data around the assumptions that underpin existing estimations. Two also suggested that energy projections and the potential for additional reductions in stack emission concentrations should influence underlying assumptions in the NAPCP.

Other responses speculated that whilst the 2020 NOx commitments looked likely to be met, the 2030 targets seemed highly dependent upon industry. They highlighted that, as industry emissions reduce, so too does that potential for further significant reductions and that Defra should look for other parts of the economy which currently have less regulation in order to achieve reductions.

Question 8: After the publication of this initial NAPCP, UK government and devolved administrations will continue to develop our policy measures and approach. This will be reflected in future iterations of the NAPCP which will be published in due course. Please inform us of any further measures you think the UK government and devolved administrations should take into account to help to achieve the UK ERCs most effectively. Proposals should be evidence based, indicating likely costs and benefits. Please select a country from the list below and use the text box and file upload button to leave your feedback.

England

We received six responses specifically linked to England. One response focused on the use of bio fuels for heating and suggested adopting the best practice from other EU states. This includes supporting consumers who wish to upgrade their old boilers to new condensing boilers, and rolling out smart metering systems and controls so that both consumers and suppliers can more effectively monitor energy use.

Five other responses related to future transport measures. One response expressed the importance of designing a compensation scheme across all modes of transport, thereby implementing meaningful penalties for breaches of air quality standards and directing the proceeds to the communities most affected by the initial impacts. Another suggested the introduction of non-charging measures for local authorities to reduce NO2 emissions, including car-sharing schemes, good quality public transport, air-filtering buses and other behavioural change measures. One response raised a concern regarding HGVs and the consequential effects of high clean air charges for HGVs, as retrofitting of HGVs is not a viable option. A further response that focused predominately on transport at a local level suggested a number of additional measures including: enabling local authorities to make profit from Clean Air Zones (CAZ), subsidising retrofits for diesel taxis, increasing stringency of licensing for taxis based on emissions standards and the introduction of CAZs for non-road mobile machinery.

One respondent raised concerns over emissions of NO2 and the compatibility of the NAPCP with the EU Ambient Air Quality (AAQ) Directive. Furthermore, they stated the need to include an estimate of the year that non-compliant zones are expected to come into compliance under already adopted policies and measures, and to estimate the maximum concentrations of concerned pollutants in these zones. The same respondent requested further clarity on the timescales of measure implementation.

One response raised concerns over section 2.7.2 of the NAPCP and its coherence with European Commission guidance which indicates that an assessment in this section should normally cover at least PM10, PM2.5, NO2 and O3 pollutants.

Northern Ireland

The response focusing on Northern Ireland placed concern on the air pollution caused by traffic. It emphasised the need for modal shift to increase the use of public transport and active travel. The respondent stated they hoped to see progress on e-bikes projects in Northern Ireland as well as the development of Active Travel Hubs. They also welcomed the investment in research linked to air quality around schools.

Scotland

The single response we received for Scotland focused on the publication of the Cleaner Air for Scotland Strategy. The respondent called for an ambitious strategy which saw Scotland strive for the best air quality in Europe and exceed World Health Organization targets for NOx and PM.

Wales

The response we received relating to Wales commended Planning Policy Wales and Welsh Government’s commitment to placing air quality higher on the agenda but commented that there was a need for Wales to ensure the strategy on clean air is implemented and supported modal shift. They called for Welsh Government to demonstrate the correlation between policies on clean air, health, planning and transport.

Alternative points raised in the consultation

Several responses did not relate to any of the above questions. One response questioned the non-linear trajectory assumed for NMVOCs emission projections. There was also a request to clarify the government agency responsible for fulfilling the coordinating role in implementing the PaMs, and the role anticipated for the new Office for Environmental Protection once the UK leaves the EU.

Regarding the projected emission reductions from the PaMs, one respondent raised the uncertainty inherent in emission projections. The respondent urged the commitment of further measures to reduce emissions of NOx, NMVOCs, ammonia and PM2.5. Finally, one respondent requested the publication of a qualitative description of the projected improvements in air quality.

Government response

All the consultation responses were carefully considered and the NAPCP was amended prior to submission to the European Commission on 1 April 2019. We hope to capture further amendments and suggestions received during this consultation in a future iteration of the NAPCP.