An independent approach to air?

Traffic in Edinburgh: The review said reducing personal private vehicle use was “a priority”

Late August saw the publication of an independent review of Scotland’s 2015 clean air strategy, and current progress in achieving its aims, which concluded that the country “is generally performing quite well by EU and global comparison”, with pollution levels continuing to fall in-line with EU norms.

It was prepared by Professor Campbell Gemmell, Professor of Environment Policy, Regulation and Governance at the University of Glasgow.

More remains to be done, it said, and our growing understanding of the effects of air pollution on human health should inform further progress.

Scotland’s first clean air strategy “Cleaner Air for Scotland – The Road to a Healthier Future (CAFS)”, which was published in 2015, marked the country’s point of departure from simply following a UK-wide policy. Its initial focus was on air quality, and particularly transport (as the biggest threat to urban air quality). The review suggested there now needs to be more inclusion of other pollution sources, such as agriculture and domestic combustion. This is necessary, it said, “if we are to achieve the best air quality in Europe – with a quality of air that aims to protect and enhance health, wellbeing and the environment.”

The review recommended the development of Scotland-specific plans to better regulate and manage domestic and agriculture sector emissions.

Emissions of some key pollutants are EU compliant, and some are already below WHO guideline levels, said the review, but “there are both some general and some localised and periodic poor quality areas, which require urgent attention and action.” The review identified “serious and particular challenges” in relation to transport constraints, nitrogen oxides, particulate and ammonia levels (from agriculture), and aspects of public behaviour and our choices.

The 2015 strategy “appears to have had a positive impact”, said the review, but it also criticised the former as having “an overly complex structure”. Also it is “not yet wholly implemented or widely understood, has had insufficient authority, and now needs more focus and energetic and aligned implementation.” On governance and performance management it said: “Existing structures are overly complex and inadequately accountable and effective.”

The review called for more effective and robust data and modelling efforts, in relation to air pollution. There was also a need and quality requirement in relation to continuous traffic monitoring. As for Low Emission Zones (LEZ), it is “too early to comment” on their success, but “it is clear they are a necessary and important commitment in delivering cleaner air”.

There are some questions to answer on LEZ design and effectiveness, and the nature of the restrictions that should apply. And also about how they should fit with Air Quality Management Areas (AQMAs), which “can and need to be operated more effectively”.

A shift to more sustainable transport modes was deemed key to advancing progress in relation to these emissions, and “reducing personal private vehicle use” was deemed “a priority” that would require “strong leadership and clear understanding of demand management and behaviour change issues and the most effective interventions.

Amongst the recommendations it said that the requirements of EU legislation on industrial and other emissions control which have been transposed into domestic legislation “should be retained and new EU requirements should continue to be implemented” to provide as high a level of protection as possible.” Some observers speculated that this might presage a more obvious divergence between Scotland and the rest of the UK on air policy following Brexit.

Commenting on the report’s recommendations, Environment Secretary Roseanna Cunningham said:

“With Scotland performing well by global standards, it is clear that our current strategy has had a positive impact by raising the profile of air pollution and helping to facilitate constructive stakeholder engagement. So while I welcome this report, I am under no illusions that there is still more to be done as we progress towards our 2020 targets.

“We will now take the time to consider the review’s recommendations in detail before formally responding following a public consultation to gather wider views. In the meantime, I would like to thank Professor Gemmell and his team for their hard work and look forward to discussing this with him in due course.”