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EFTAG responds to Air Quality Action Plan

Epping Forest District Council recently ran a consultation on their proposed Air Quality Action Plan. We were disappointed; here’s the response we sent.

Overall, EFTAG is concerned that the plan lacks ambition, it shies away from setting a strong narrative around the dangers of air pollution (the phrase “no safe level of exposure” does appear, but only once – page 3 – and not in the text which sets the tone of the document). The Table 5.1 in the document is also useful, but we are concerned it will fail to lead to any successes as the performance indicators given are generally extremely poor, focusing on the publication of strategy documents (or even increased signposting to strategy documents in the case of measure A06). The KPIs need to be Specific, Measurable, Achievable, Relevant and Time Bound and I don’t think any of the KPIs at present meet that standard. Our fear is that with such weak performance indicators, success will be able to be demonstrated while actions which could have a significant positive impact on the district are left unattempted, especially as UK government messaging acknowledges that mere compliance with threshold limit values is not enough. All levels of NO2, PM10 and PM2.5 are a risk to health. 

We feel too that the measures proposed generally fall too far on the side of new tech and don’t make enough of the enormous opportunities for active travel in Epping Forest District. If, instead of being signposted to on websites, the now 9 year old Epping Forest Cycling Action Plan had some of its routes actually built there would likely be a measurable impact on air pollution, and importantly there would also be co-benefits to the health of the districts residents and workers from the additional exercise. Similar benefits could be found by improving pavements in the district, again the Air Quality Action Plan does not raise this as a possibility. Signposting the cycling action plan will achieve absolutely nothing. I single it out as a KPI because its inclusion is embarrassing. 

The language used in the document is generally sloppy, with “objective” used extensively to describe threshold limit values. The document needs to be clear that national targets are upper limits, not desired outcomes. annual mean concentrations of 30µg/m3 are always preferably to the legal limit value of 40µg/m3, and to call the limit values “objectives” fails to make that clear. Furthermore, the description of the legal landscape that the document gives reveals that it is already significantly out of date. It does not mention the Environment Act 2021, nor does it mention the air quality targets which have been made in secondary legislation this year off the back of the Environment Act. It is important that where there is compliance with current threshold limit values in the district at present, that does not mean that there will be compliance in 2028 when interim targets start to come into force, even if the rate of pollution doesn’t increase. This is a very important point that the document needs to reflect. 

The geographical points in the document are often strange. There is a table on page 6 which professes to compare Epping Forest to “neighbouring authorities” and yet while it includes authorities with completely different demographics and geography on the other side of the county, it makes no reference to Waltham Forest, Havering, Redbridge and Broxbourne, neighbouring authorities which are much more like the most densely populated parts of Epping Forest District than anywhere on the east coast. Air pollution does not respect county boundaries and immediately adjacent areas need to be included if this document is to be actually useful and not merely a box ticking exercise for Defra. 

The data given in the document is often unclear too. A lot is made of modelling completed by consultants and the conclusions drawn for Epping Forest, but there is no critical assessment of this. It is unclear whether the modelling actually used data from the district, or just made assumptions based on demographics and national data. I suspect it is often the latter, but if so the implications of that modelling go on to be overstated, with conclusions said to be “demonstrated” where they would in fact be merely “suggested”. Where the Action Plan is using data with limitations, those limitations need to be set out really clearly.

It would be great to have more of an assessment of the air quality monitoring that goes on in Epping Forest District too, a map could be a useful way to display this, and would highlight the gaps in the monitoring. Where data is mentioned in the current draft, it’s invariably 2020 data with reasonable caveats on its representativeness, but it isn’t then followed up with 2019 (or another year’s) data which might be more useful. We also wonder why there isn’t more recent data than 2020 available, given that was 3 years ago now. It again suggests that this is a document which is already several years out of date. 

EFTAG are always happy to have a conversation about the Air Quality Action Plan, we care deeply about making it a document which is useful and part of a meaningful step towards cleaning up the air in Epping Forest District. We feel it needs some significant improvements before it will fulfil that aim. 


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