Defra condemned by Clean Air in London for proposals scrapping local air pollution monitoring

Air pollution is a key problem for Heathrow, making the addition of a 3rd runway very hard to justify – or to fit within legal air quality limits. The main pollutant with which Heathrow has problems is NOX – nitrogen oxides, the  majority of which comes from road traffic. The actual proportion from aircraft, airport vehicles and other road vehicles is very difficult to establish. The other key air pollutants are PM10 and PM2.5 – tiny particles which lodge in the lungs and can cause long term health problems. DEFRA has responsibility for air quality monitoring. It put out a consultation on streamlining some air pollution  monitoring, on 19th December (finishes 30th January). The aim is to no longer require local authorities to monitor 4 pollutants, and to combine monitoring of PM10s with PM2.5s. The group, Clean in London says “DEFRA’s plans would result inevitably in the scrapping of thousands of local monitoring sites that have taken a decade to put in place and probably all of them within a few months or years.”  Also that “Alarmingly, local authorities are being told to make use of Defra’s tiny national monitoring network (i.e. 137 monitors, few of which measure two or more of NO2, PM2.5 and PM10).”


Details of the DEFRA consultation below

The main consultation document is


Defra condemned for proposals scrapping local air pollution monitoring

by   (Clean Air For London)

Consultation on proposals to improve local air quality management (LAQM) in England

Defra is proposing modified Option 3 from its 2013 consultation on LAQM (now Option 1), that was rejected by over 18,000 people and organisations, and to scrap ‘Further assessments’ under ‘Business as usual’.  It is unclear whether Defra also intends (catastrophically) to scrap the duty on local authorities to review the need for continued assessment and reporting on objectives that have been met e.g. PM10

Defra’s plans would result inevitably in the scrapping of thousands of local monitoring sites that have taken a decade to put in place and probably all of them within a few months or years

Buried in the fine print, Defra admits that 38 of the UK’s 43 air quality zones will not be compliant with EU limit values for nitrogen dioxide (NO2) by 2015 with three zones (Birmingham, Leeds and London) unlikely to be able to comply with these limits until after 2030.  Meanwhile scientists are highlighting new and much larger mortality risks for NO2  

‘Clean Air in London’ rejects Defra’s proposed Option 1 and condemns the Consultation as the latest example in a string of systemic failures from a Government Department that is doing more to worsen air pollution than reduce it

– See more at:

Would be good if DEFRA can explain quite how councils will know where action is necessary on air pollution, unless there’s monitoring in place to show where quality is poor?


Clean Air in London says:


Alarmingly, local authorities are being told to make use of Defra’s tiny national monitoring network (i.e. 137 monitors, few of which measure two or more of NO2, PM2.5 and PM10) and computer modelling that have been manipulated and used often by Defra to hide smog warnings and breaches of air pollution laws.

Only Defra’s 137 automatic monitoring stations across the UK would remain for NOx/NO2, PM2.5 and PM10 (with not many monitoring two or more pollutants) (together with a few other specialist monitors for other forms of air pollution) together with its computer modelling which is undertaken up to nine months after a calendar year end. Defra says LAs would be ‘encouraged to make use of national monitoring [and modelling]’.
2. Adding guidance on a PM5 role for local authorities (in pursuance of the Public Health Outcomes Framework air quality indicator to reduce fine particulate pollution) to reflect the public health impact of this pollutant

i. Defra says that most anthropogenic sources of PM2.5 derive from road transport (including tyre and break wear) and industrial processes and that up to half of PM2.5 is transboundary.

ii. Defra proposes two options (a) and (b). (a) would be to add a general role into LAQM guidance for LAs to have regard to PM2.5 when carrying out their air quality activities. (b) would be to add a role on PM2.5 to LAQM Regulations, for example the Stage 2 limit value of 20 micrograms per cubic metre annual mean to be achieved by 2020. Defra dismisses (b) in its own consultation. Laughably, Defra says “[Under] this modification LAs would not be tasked with reviewing and assessing PM2.5 at the local level, but implement or strengthen existing measures that can target PM2.5”.

iii. the Consultation states: “There is a degree of uncertainty regarding the extent to which LAs will add additional actions which have not already been prioritised by Directors of Public Health”. CAL is aware of only one local authority (City of London Corporation) that has prioritised PM2.5 in its Health and Wellbeing Strategy. Defra does however, helpfully list measures that LAs can take to reduce mobile and non-mobile sources of PM2.5.

iv. feebly, Defra states “Not only is it uncertain whether incorporating PM2.5 would lead to any additional action by LAs, it is also uncertain what actions they would decide to take”. It seems Defra has done no work on this issue since the previous consultation.

v. CAL’s only comment is that PM2.5 must be put at the heart of LAQM regulations, alongside NO2 and PM10 i.e. the opposite of Defra’s stated intention to reject even its limited inclusion in the Regulations or guidance.

– See more at:
Selective statements in Defra’s Impact Assessment include:
6. “As was proposed in the 2013 consultation, we would not expect local authorities to conduct their own monitoring/modelling of PM2.5 (which would represent a disproportionate cost for many) but instead make use of the data available via the Automatic Urban and Rural Network (AURN), which is freely available via the UK-Air website.” AND “Currently there are approx. 75 AURN stations monitoring PM2.5 across the UK” (page 9, IA).

7. PM2.5 | “With the introduction of the Public Health Outcomes Framework (PHOF) and the move of public health responsibilities onto local authorities, those authorities responsible for Public Health will have need to investigate what measures are available to reduce this pollutant so as to reduce local health burdens where this has been identified as a priority.” (Page 11, IA).

– See more at:

Information on PM2.5 from Heathrow Airport

Heathrow Air Quality Strategy

Air quality management is a key priority for HAL [Heathrow Airport Ltd] and local air quality is one of the issues of concern to local residents and national stakeholders. The main pollutants of concern in the Heathrow area are nitrogen dioxide (NO2) and particles (measured as PM10 and PM2.5). The EU has specified concentration limits for these pollutants due to their impact on human health. Only NO2 exceeds the EU limit value in some local areas which requires HAL and other stakeholders to reduce emissions of
its precursor – oxides of nitrogen (NOX).

Particles (PM10 and PM2.5) are categorised in terms of their size. PM10 refers to particles with an aerodynamic diameter of less than 10 microns (µm) and PM2.5 is a sub-set of this, referring to particles of less than 2.5µm. PM10 and PM2.5 are produced from a wide range of materials and from many sources including vehicles, aircraft and boilers, brake and tyre wear, fires and construction.

As well as PM10, HAL also monitors the finer fraction PM2.5 at all four of its monitoring sites. Fig. 6 shows annual mean concentrations of PM2.5 measured at Green Gates, Oaks Road, Harlington and LHR2 in 2010 were less than half of the EU target of 25 µg/m3.

Review PM2.5 monitoring – We completed the review in 2009 and all HAL financed monitoring sites now measure PM2.5 as well as PM10.

Heathrow air pollution monitoring sites from Air Quality Strategy 2011 - 2020

More at


Information from DEFRA on PM2.5

What is Particulate Matter? What is PM2.5?

Particulate matter (PM) is a term used to describe the mixture of solid particles and liquid droplets in the air.  It can be either human-made or naturally occurring. Some examples include dust, ash and sea-spray. Particulate matter (including soot) is emitted during the combustion of solid and liquid fuels, such as for power generation, domestic heating and in vehicle engines. Particulate matter varies in size (i.e. the diameter or width of the particle). PM2.5means the mass per cubic metre of air of particles with a size (diameter) generally less than 2.5 micrometres (µm). PM2.5 is also known as fine particulate matter  (2.5 micrometres is one 400th of a millimetre).

Health Effects of PM:

Inhalation of particulate pollution can have adverse health impacts, and there is understood to be no safe threshold below which no adverse effects would be anticipated [1].  The biggest impact of particulate air pollution on public health is understood to be from long-term exposure to PM2.5, which increases the age-specific mortality risk, particularly from cardiovascular causes. Several plausible mechanisms for this effect on mortality have been proposed, although it is not yet clear which is the most important.  Exposure to high concentrations of PM (e.g. during short-term pollution episodes) can also exacerbate lung and heart conditions, significantly affecting quality of life, and increase deaths and hospital admissions. Children, the elderly and those with predisposed respiratory and cardiovascular disease, are known to be more susceptible to the health impacts from air pollution [2].  Potential mechanisms by which air pollution could cause cardiovascular effects are described in the Committee on the Medical Effects of Air Pollution (COMEAP) report“Cardiovascular Disease and Air Pollution” (2006) (PDF, 1.75MB, 215 pages).

Sources of PM2.5:

Human-made sources of PM2.5 are more important than natural sources, which make only a small contribution to the total concentration. Within UK towns and cities, emissions of PM2.5 from road vehicles are an important source. Consequently, levels of PM2.5 (and population exposure) close to roadsides are often much higher than those in background locations. In some places, industrial emissions can also be important, as can the use of non-smokeless fuels for heating and other domestic sources of smoke such as bonfires. Under some meteorological conditions, air polluted with PM2.5 from the continent may circulate over the UK – a condition known as the long range transportation of air pollution. Long range transport, together with pollution from local sources, can result in short term episodes of high pollution which might have an impact on the health on those sensitive to high pollution.

In addition to these direct (i.e. primary) emissions of particles, PM2.5 can also be formed from the chemical reactions of gases such as sulphur dioxide (SO2) and nitrogen oxides (NOx: nitric oxide, NO plus nitrogen dioxide, NO2); these are called secondary particles. Measures to reduce the emissions of these precursor gases are therefore often beneficial in reducing overall levels of PM2.5.

Primary emissions of PM, the formation of secondary PM within the UK and long range transport of pollution from outside the UK all contribute to regional PM levels across the UK. Local primary emissions are also important in urban areas.

…. and there is more on PM2.5 from DEFRA at



Toxic air monitors may be scrapped

Jonathan Leake, Environment Editor

28 December 2014 (Sunday Times)

Environmental groups accused the government of seeking to hide details of poor air quality.  Environmental groups accused the government of seeking to hide details of poor air quality

BRITAIN’S air pollution monitoring network could be dismantled under government plans to remove the obligation on councils to produce detailed reports on local air quality.

The proposal is contained in a consultation paper slipped out by Defra, the environment ministry, before Christmas.  [See below].  The main consultation document is

Its stated intention is to reduce the regulatory burden but environmental groups and Labour accused the government of seeking to hide details of poor air quality in many cities.

“Sadly, the government’s response is that it doesn’t like the evidence so it wants to stop collecting data,” said Barry Gardiner, Labour’s environment spokesman.

Under the proposal, councils will no longer have to produce detailed assessments, especially those showing pollution hotspots, using a network of 10,500 monitors.

These monitors have helped to find more than 470 “air quality management areas” where nitrogen dioxide (NO2) or particulate pollution threaten people’s health.

If the use of council monitoring drops, as the paper predicts, more emphasis will be placed on Defra’s much smaller network of just 100 machines measuring NO2.

Defra said: “We are consulting on changes to reduce the administrative burden and allow councils to focus on taking action to improve air quality.”




The DEFRA consultation


Review of Local Air Quality Management (England) – regulatory and guidance changes


The purpose of this consultation is to invite views on our proposals to improve Local Air Quality Management (LAQM) delivery in England.  This is a follow-up consultation to one issued in July 2013.

This latest consultation contains a number of proposals to reduce regulatory and administrative burdens in line with commitments made under the Red Tape Challenge, and to improve the overall effectiveness of LAQM in dealing with current air quality  challenges.

The Consultation Document  is split into two parts:

(1) regulatory consultation on a statutory instrument to enable the removal of four redundant pollutants (Benzene; 1,3 Butadiene; Carbon Monoxide; and Lead) for local authority reporting purposes;

and (2) part two which provides an overview of non-regulatory changes such as streamlining of reporting processes and providing local authorities with a role to tackle PM2.5 (fine particulates) to be set out in statutory guidance.

Part two will be subject to a further, more detailed consultation in late 2015
A summary of  responses will be compiled based on comments submitted during the 6 week consultation period.   The consultation is aimed principally at air quality practitioners in England, but we want to hear views from as wide a range of interested parties as possible.

For more information, please scroll down to the ‘Related Documents’ section [below] for the latest consultation, impact assessment and statutory instrument.

More at

Consultation is Open

Runs from 19 Dec 2014 to 30 Jan 2015


“Preferred Option: The following objectives will be removed, for local authority reporting purposes, from the 2000 (2002 as amended) Air Quality (England) Regulations:

  • 1,3 Butadiene
  • Benzene
  • Carbon Monoxide
  • Lead “

….”The aim being to reduce reporting burdens on local authorities to help focus  on those areas that required action without reducing levels of protection to human health or the environment. Monitoring at the national level would remain, enabling Government to take action if necessary…..”

and DEFRA say:

“…Many of the measures to tackle PM2.5 are measures that are already available to tackle PM10 or NOx – therefore the introduction of PM2.5 to LAQM [Local Air Quality Management]  may not result in different action being taken just to address that particulate, but from a strategic perspective, can support and strengthen the local authority business case for taking action overall and in making decisions on what specific measures to use.”


and DEFRA say:

….” Following the consultation in 2013 and further workshop in September 2014, Defra’s preferred approach to including PM2.5 in LAQM is through adding a requirement in statutory guidance to have regard to PM2.5 in carrying out their air quality functions. In doing so they will not be required, though they may choose, to carry out local monitoring and modelling but will be able to use national modelling and monitoring. ….”

Related Information



Related Documents


  • Environmental campaigners ,
  • Government Departments,
  • Government Agencies,
  • Devolved Administrations,
  • Energy sector,
  • Ports and Harbour Authorities and Estuaries,
  • Environmental professional services ,
  • Local Authorities,
  • Walkers,
  • Environmental Health Officers



Sean O’Byrne(Policy Advisor – Local Air Quality Management)Atmosphere & Noise0207 238