Draft Government plans to cut NO2 pollution are woefully inadequate, having limited impact

The government was forced to publish its draft Air Quality Plan consultation (closes 15th June) on 5th May, having tried to delay it till after the election. It has not impressed campaigners for lower NO2 in our air. The plan has been criticised for being “woefully inadequate” and containing measures that would make only slight improvements. There is a planned scrappage scheme for a year, but this would only be for 15,000 vehicles (9,000 diesel and 6,000 petrol). The plan would replace these vehicles with electric Ultra Low Emissions Vehicles (ULEVs). It would cost the government money. There are plans to get more vehicles retrofitted, with selective catalytic reduction (SCR) technology for buses and heavy goods vehicles (HGVs) and LPG technology for black cabs. But it would only be for around 6,000 buses, 4,400 black cabs, and 2,000 HGVs by 2020. There could be more incentives to buy both battery operated and plug-in hybrid electric ULEVS.  And also hopes to change driver behaviour to drive more smoothly, remove speed humps, or cut speed limits.  All sound sensible ideas, but would have minimal impacts on the vast numbers of UK road vehicles. There are around 160,000 vehicles per day on the M4 near Heathrow, and around 263,000 on the M25 near Heathrow. It will take more than the government’s current proposals to make more than a tiny dent in all that NO2 air pollution.  There is no mention of airports in the Defra document.  

There are about 12 million diesel cars on the UK’s roads. 9,000 is a minute proportion. 360,000 diesel cars were sold between January and March in 2017, almost 90,000 more than the same period in 2012


Government Plans To Tackle Air Pollution ‘Woefully Inadequate’, Say Campaigners

Just 9,000 diesel cars out of two million could be eligible for scrappage under new scheme.

By Kate Forrester (Political Reporter, Huff Post UK)

Government plans to tackle air pollution across the country have been branded ‘woefully inadequate’ by leading campaigners.

Defra was forced to publish its draft air quality strategy this week by the High Court, despite attempts to delay it until after the general election.

It includes plans for a ‘targeted’ diesel scrappage scheme – but campaigners say it would only translate to about 9,000 out of two million diesel car owners being paid to swap their heavily polluting vehicles for electric ones.

The strategy was also lambasted for being short on detail and an attempt to push responsibility to deliver clean air to local councils, who will be expected to ‘develop new and creative solutions to reduce emissions as quickly as possible, while avoiding undue impact on the motorist’.

Oliver Hayes, of Friends of the Earth, said: “The government has produced a plan that is woefully inadequate, with a breath-taking lack of detail.

“If reports are true and these plans have been watered down because of the general election, ministers will have shown a shocking disregard for protecting people’s health.

“Every day of inaction on air pollution costs lives. This is an exceptionally poor plan. The government must not put politics above people.”

He said the best way to protect people from toxic fumes is to ensure Clean Air Zones are put in place in every location where high levels of pollution are recorded and implement a proper diesel scrappage scheme.

The Green Party has put air quality front and centre in its election campaign and accused the Tories of ‘standing by while Britain chokes’.

Co-leader Caroline Lucas said: “This feeble plan won’t go anywhere near far enough in tackling this public health emergency. We needed a huge investment in public transport, serious taxation changes and a new Clean Air Act – but none of these solutions are in the plan.”

Poor air is linked to 40,000 deaths every year and ministers are coming under increasing pressure to take drastic action – including from London Mayor Sadiq Khan, who has made improving air quality one of his key priorities.

Other proposals in the draft strategy, which is now out for consultation, include:

– Additional funding and regulatory changes to improve uptake of electric vehicles, and increasing the number of charge points for them.

– New tests on vehicles to make sure manufacturers are sticking to regulations on emissions.

– Addressing problems on the roads which contribute to traffic congestion, including road humps and ‘poorly managed traffic lights’.


Secretary of State for Environment, Food and Rural Affairs, Andrea Leadsom, said improving air quality was a key priority for the government.

“Our modern Industrial Strategy will ensure Global Britain is at the forefront of developing new, innovative and cleaner technologies,” she added.

“EU vehicle emissions regulations have failed to deliver anticipated reductions in air pollution – because some irresponsible diesel car makers avoided or cheated the emissions reductions they had agreed.

“As a result, the UK is currently one of 17 EU countries breaching annual nitrogen dioxide targets. In fact, the UK would have met pollution limits agreed in EU law had the measures intended to achieve them actually been effective.”




Government set to be taken back to court over air pollution plans

Ministers’ latest proposals, published on Friday after high court intervention, criticised by climate groups calling for stronger action on illegal pollution levels
Government plans to cut levels of diesel fumes, nitrogen oxides and particulates may flout its duty to protect public health.

Environment lawyers are expected to take the government back to court over its controversial plans to tackle the UK’s air pollution crisis. They say the proposals are so weak they flout ministers’ obligation to protect public health.

The government published its plans to cut levels of diesel fumes, nitrogen oxides and particulates in the atmosphere on Friday – after being forced by judges to acton the crisis. Medical experts say toxic air is responsible for tens of thousands of premature deaths every year.

The plans by the government contained little concrete detail and left most anti-pollution measures to be dealt with by local authorities. “These belated proposals are toothless and woefully inadequate,” said the mayor of London, Sadiq Khan.

James Thornton, founder and chief executive of ClientEarth, was equally caustic. “The more we study this appalling plan, the more unsatisfactory it gets,” he said.

His organisation took the government to the supreme court to force it to comply with its legal obligation to reduce air pollution. Ministers had claimed they were not obliged to act on the issue as a matter of urgency. The court disagreed and told them to produce an air pollution plan as a priority. When this plan was published in 2015, it was deemed to be so poor it was illegal and the government was told – by the high court – to submit a new plan by April.

A few days ago the government used the excuse of the general election to postpone publication of this latest plan. Once again, it was taken to court by ClientEarth, where ministers were told they could not postpone publication. On Friday, they produced their report, to general derision and a growing conviction that environmental lawyers will demand far more robust action to deal with air pollution.

“This latest plan is even worse than the previous effort, which has already been ruled illegal by the high court,” said Thornton. “The government should be ashamed of itself. It has dragged its heels for seven years while we choke on illegal and poisonous air; it’s been hauled through the supreme and high courts and had to be forced by a judge to publish this delayed plan.

“We need to ask ourselves at what point will the government take this public health emergency seriously enough to start protecting our health and our children’s futures, instead of the car companies?

“The government must, and will be forced to, obey its own laws to protect our health and give us safe and cleaner air to breathe.”




The Defra main consultation document is at 



Draft UK Air Quality Plan for tackling nitrogen dioxide

Technical Report

May 2017



One section is copied below: 

National actions to support CAZs

It is recognised that the type of changes required to deliver compliance could disproportionately impact a number of individuals. In order to mitigate these impacts and support the transition to CAZs three national supporting options have been considered: retrofit, scrappage and the support for Ultra Low Emission Vehicles (ULEVs).

The retrofit option would entail the installation of selective catalytic reduction (SCR) technology for buses and heavy goods vehicles (HGVs) and liquefied petroleum gas (LPG) technology for black cabs. This policy considers retrofit for around 6,000 buses, 4,400 black cabs, and 2,000 HGVs by 2020. This is considered feasible given current market capacity.

Retrofitting for buses is well established; however, there may be challenges in successfully extending retrofitting to other types of vehicles in terms of both technological capability and market capacity to meet required demand. Based on previous schemes, which have proved to be successful in promoting retrofit, it is envisaged that a retrofit grant scheme would need to be established where organisations could bid for funding to retrofit vehicles with accredited technology.

The scrappage option assumes a national level scheme is introduced targeting drivers of older diesel and petrol cars, which emit substantially more pollution per kilometre than newer vehicles. It is assumed that around 15,000 vehicles (9,000 diesel and 6,000 petrol vehicles) are scrapped and replaced with new Battery Electric Vehicles (BEVs) during a one-year scheme. A targeted scrappage scheme of this type would improve air quality by amplifying fleet turnover so that highly polluting vehicles are scrapped sooner than they would have been if no intervention took place.

The promotion of Ultra Low Emission Vehicles (ULEVs) option would seek to extend the existing plug-in car grant set up by Government which incentivises the adoption of ULEVs, comprising both battery operated vehicles and plug-in hybrid electric vehicles. By securing additional funding, it is envisaged that around 160,000 ULEVs would be purchased over a three-year period. As ULEVs have low NOx emissions, air quality improvements stem from the assumption that each additional ULEV is replacing a conventional car.

Promotion of ULEVs is expected to support economic growth in the short term by encouraging the ULEV market and there is expected to be a substantial reduction in greenhouse gas emissions. Despite this, the additional cost of the grant to Government significantly overshadows the estimated benefits to society. However, it should be noted that there are a range of non-monetised benefits (e.g. increased 8 public understanding, acceptance of electric vehicles) associated with the early uptake of ULEVs that have not been considered as part of this assessment.

Supplementary national options

In addition to the improvements that can be delivered through adapting the UK Air Quality Plan for tackling nitrogen dioxide (published in 2015) a range of supplementary additional measures have been assessed. This is especially important as not all areas in exceedance of NO2 concentration limit levels can be readily addressed through Clean Air Zones. In these cases, options applied on a national scale are required to help reduce NO2 concentrations or to reduce the period of non-compliance.

The options identified in this category are: introducing speed limits on the strategic road network; improving the standard of Government vehicle purchases; and encouraging changes in driving behaviour.

Speed related emission curves suggest that vehicles travelling at high speeds emit greater levels of NOx the faster they travel. Therefore, there may be potential to improve air quality by lowering speed limits. The speed limits option would seek to tackle lengths of motorway experiencing poor levels of air quality. For this option, the effect of reducing the motorway speed limit from 70 to 60mph has been simulated by modelling a reduction in the average speed (by 10mph) of affected vehicles. This change is assumed to have no impact on congestion, which is also a notable determinant of air pollution. There is uncertainty in this area and the evidence would benefit from further monitoring in real world conditions: for example, at sites where variable speed limits are used already for traffic smoothing purposes, to understand better the extent of the impact any change to speed limits might have on air quality.

The option to improve the standard of Government vehicles would involve updating the Government Buying Standards for transport (GBS-T) to account for NOx and PM impacts, in order to guide the procurement process. It is anticipated that this option will gradually replace the Government fleet with cleaner vehicles with diesel vehicles only being bought as a last resort. The policy is limited by the fact that low NOx alternatives do not exist for certain specialist vehicles (e.g. fire engines) and because it has only been applied to central Government.

Behavioural change has been considered through two indicative options: vehicle labelling, which attempts to change consumer behaviour at the point of purchase; and influencing driving styles, which could use education and technology to encourage more environmentally friendly driving techniques.

Vehicle labelling would improve air quality by encouraging a shift of purchasing behaviour away from new diesel vehicles to alternative vehicle types. This would involve an expanded labelling system, which would include information on air pollutants, in addition to already existing information on fuel consumption and carbon 9 dioxide emissions. The modelled scenario assumes a 0.5% shift in purchasing decisions away from new diesel cars to new petrol cars annually. The cost to Government of this option is assumed to be negligible as a labelling review is already taking place.

Influencing driving styles would seek to tackle excessive speeds and harsh acceleration, which are known to increase NOx emissions. It would teach and reinforce economical driving practices through driving style training. The option assumes that 100,000 drivers would be trained by 2019 with a percentage reduction in distance travelled used as a proxy to estimate the impacts of the option. With both options outlined to achieve behavioural change, it is important to recognise that there are notable non-quantifiable benefits, but that these come with unpredictability in the ability for Government to achieve the desired impact, as behavioural responses are uncertain.



The Defra page with information on the consultation (closes 15th June) is at:


The online consultation form to fill in is at 


Closes 15 Jun 2017

Opened 5 May 2017

Results expected 31 Jul 2017

Feedback expected 31 Jul 2017