Lord de Mauley

Parliamentary Under Secretary of State for Resource Management, the Local Environment and Environmental Science

Department for Environment, Food & Rural Affairs

Nobel House

17 Smith Square

London SW1P 3JR

Date: July 30^th, 2013 

Dear Rupert,

I am writing to you about DEFRA’s consultation on the best way to address shortcomings identified in Local Air Quality Management (LAQM) delivery in England. While I support the Government’s stated aim of improving air quality, I am concerned that the proposed method for achieving this will be counter-productive and fail to achieve the desired results.

As I am sure you are aware, air pollution reduces average life expectancy in the UK by up to eight months,[1] and London has the worst air quality of any European capital.[2] The Environmental Audit Committee’s report on air quality noted that the “£8-20 billion total cost of poor air quality is likely to be an under-estimate”.[3] In Brighton and Hove, despite a notable lack of practical support from central Government, the local authority is working hard to improve air quality – with considerable success. Whilst I agree that they should not be forced to spend money monitoring air quality more often than is necessary to gather relevant information, there is no evidence to suggest that weakening requirements to monitor air quality will free up sufficient resources to mitigate the various effects of air pollution.

I also fail to see how such a significant problem can be addressed without sufficient data. Simply refusing to measure the problem will not improve air quality or help meet EU limits, as the UK will still be obliged to do.

I am concerned that this is nothing more than a cost-saving exercise on the part of the Government that will ultimately lead to greater expense rather than cleaner air; either through increased EU fines and legal costs for infractions or because DEFRA will have to take more action centrally to improve air quality - as DEFRA’s impact assessment acknowledges.

The review[4] commissioned by the Government notes that the assessment part of the LAQM is working “very well” (although the process is “prescriptive”), while the action planning components are “not working well”. The proposed measures are “often not quantified or effectively implemented”, or fall “considerably short of what is required to attain the objectives”. Why is the Government considering changing something which is already working “very well”, while not providing any assistance or extra funding for those aspects which need improvement?

The review went on to state that there is evidence that “some major schemes have been withdrawn due to funding cuts or delays in Major Scheme Bids”, and that key barriers to implementation include “lack of funding for large infrastructure projects, and inadequate resources”. DEFRA’s justification for scrapping local authority duties is framed as cutting so called ‘red tape’, and yet nowhere in the review is excessive bureaucracy mentioned as the cause of problems with implementation. Lack of funding, on the other hand, is clearly identified as the principal obstacle.

If Option 3, the Government’s preferred choice, were to be implemented, it is estimated to bring savings for LAs across the country of £48.4m over 10 years. While this is not an insignificant sum, particularly at a time of massive cuts to local authority budgets, it is still less than £5m per year. How will weakening diagnostic abilities in order to free up a relatively small amount of funding help to improve implementation measures and provide better outcomes? What evidence is there that this will be the case?

DEFRA’s impact assessment states that freeing up resources used for reporting on air quality could lead to “cost savings and/or increased capacity for action to improve air quality”. Will the Government insist that local authorities ring fence any savings so they are invested directly back into improving air quality? If this money is not ring-fenced, it is likely that stretched local authorities will spend it on their many other pressing financial commitments. Does the Government plan to provide any extra funding to local authorities to help them improve implementation, or simply insist that they reallocate existing funding away from assessment?

In conclusion, it is vital that policy in this area be based on evidence, rather than short-term cost cutting. The Government’s approach is extremely short-sighted and I request that my comments be included as part of the formal consultation.

I look forward to receiving your reply.

Yours sincerely,