Environmental Protection Scotland Room 3, Caledonian Suite, 70 West Regent Street, Glasgow, G2 2QZ Tel: 0141 333 6655 Fax: 0141 333 1116 Email: [email protected] www.ep-scotland.org.uk

Environmental Protection Scotland is a Scottish Charitable Incorporated Organisation SCIO Scottish Charity No. SC 043410

“WITH SCOTLAND PERFORMING WELL BY GLOBAL STANDARDS, OUR CURRENT STRATEGY HAS HAD A POSITIVE IMPACT - BUT THERE IS STILL MORE TO BE DONE

THE INDEPENDENT CLEANER AIR FOR SCOTLAND (CAFS) REVIEW

Analysis: John Bynorth

ON August 29th, the independent review of the Cleaner Air For Scotland (CAFS) strategy was published.

Led by Professor Campbell Gemmell, the document reviewed the progress of the Scottish Government initiative and made 10 high level recommendations.

It concluded that, generally Scotland was performing quite well by comparison with the rest of the EU and the world overall. There were falling levels of regulated pollution emissions and ambient air pollutant levels are also down.

However, the report added that more needs to be done particularly in relation to emission sources other than just from transport, such as agriculture and domestic burning.

The report flagged nitrogen oxides, particulates and ammonia from agriculture, issues around transport emissions and the choices people have when it comes to car use and active travel.

Although it said CAFS has had a positive impact, the report found its overall structure was complex, there was a major governance gap for future air quality strategy delivery at ministerial level, and the overall governance group was misnamed – because it had no actual ‘governance’ or decision making power. It called for representation on the group needed to include more senior or authoritative figures and future incarnations of the group needed a clear remit, including how its advice would be conveyed to ministers.

The report praised the fact that it has helped deliver ‘so many of CAFS’ commitments.’’

It raised the need for the work of local government to dovetail more effectively with the work of Transport Scotland and SEPA and for a concerted effort among numerous sectors, from national government to people themselves to reduce air pollution from different sources.

There is clear emphasis on behaviour change and interventions such as the creation of more dedicated cycle and walking routes to encourage active travel; the public transport improvements that many view as essential if people are to give up their cars and further impetus for people to consider electric vehicles.

This included provision of better and more impartial public information about air pollution and the different transport modes that can help improve air quality.

It also called for improvements to be made to ensure there was the most robust data and modelling of traffic and air pollution, but said the report came too early to pass judgement on the impact of Low Emission Zones.

It said there was a need for better place-making to help stimulate a cleaner and healthier environment, which can be achieved by making areas safer and easier to use for pedestrians and having cycle paths and building developments in close proximity to public transport networks.

The recommendations have been opened for stakeholders to comment on. A revised CAFS strategy is expected to be published in 2020.

Roseanna Cunningham, the Cabinet Secretary for Environment, Climate Change and Land Reform 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.”

“Globally, air pollution is now considered the most serious of all environmental health problems”

INTERNATIONAL studies of air pollution impacts on public health, whether that is cardiovascular disease, dementia or the effects on children in the womb, are of only a certain amount of help to experts in Scotland.

Much of the research has been conducted in countries with far poorer levels of air quality than in this country. A relatively small number of published studies have been carried out in this country.

Although analysis showed Scotland’s most important pollutants, including PM2.5, are mostly now below recommended health based limits, excess levels of nitrogen oxides in city centres remain a concern.

The health and environment working group, chaired by Dr Colin Ramsay of Health Protection Scotland, looked at a raft of scientific evidence from across the world and concluded that the minimum demand should be to reduce air pollution levels to meet existing health-based limits.

However, their report said international evidence suggested that further reductions in air pollution levels would bring additional public health and environmental benefits, particularly around the issue of long-term exposure to pollutants.

The group looked at the World Health Organisation (WHO) Review Of Evidence On Health Aspects Of Air Pollution (REVIHAPP) which found significant evidence of the adverse effects of Particulate Matter (PM), Nitrogen Dioxide (NO2) and ozone.

In the WHO review of evidence linking PM with changes in cardiovascular systems, lung functions and premature deaths, there was no evidence of a threshold at which the adverse health effects from the pollutants stop. The WHO report concluded: “Public health benefits will result from any reduction in PM2.5, whether or not the current levels are above or below the limit values.”

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 2

The working group also assessed the findings of the Committee for the Medical Effects of Air Pollutants (COMEAP) in the UK.

In 2010, COMEAP produced a report that suggested exposure to air pollution resulted in an average cut in life expectancy from when people are born of six months across the UK, which worked out as a reduction of three to four months in Scotland.

The CAFS working group said the view had been taken that this was equivalent to 2,000 attributable, or premature, deaths in Scotland.

Since then, the figure had been updated downwards to 1,700 ‘attributable deaths’ in Scotland, with the least annual mean concentration for human source PM2.5 as the basis for this figure.

Importantly, the CAFS working group made clear that “attributable deaths are not actual recorded deaths in a particular year.” They described the figure as a “statistically derived” estimate which aims to convey as honestly as possible “the amount of excess mortality caused by air pollution across the population as a whole.”

It said, and this was backed up by COMEAP’s findings in 2010, that it should not have been interpreted as the number of people who die prematurely, where air pollution has made some contribution to a death, in any single year. The CAFS working group added: “The number is unknown but is almost certainly much larger.”

The group found there were limitations in the applicability of international research to Scotland. This includes many of the studies which have claimed there is a link between air pollution and Alzheimer’s disease, type 2 Diabetes, miscarriage, Autism along with other health outcomes.

Doubts were raised about how the findings were transferrable to Scotland as the main studies took place in countries with notably higher levels of air pollution. “Compared globally, air pollution levels in Scotland are relatively low,” the working group’s report pointed out.

It noted there had so far been a lack of studies in Scotland and called for more research into the long-term effects of ambient air pollution in this country.

Research in Scotland had also failed to definitively so far show the exact effects of air pollution on cardiovascular disease outcomes.

The report said the lack of detailed studies created uncertainty for Scottish health experts when they are asked to predict the size of health gains from future air pollution policies.

It concluded that there is no agreed level of fine particles, PM2.5 ozone and NO2 at which adverse health effects can be said with confidence not to occur.

However, the report said growing evidence from other countries showing links between air pollution and health conditions such as dementia, diabetes and pregnancy-related outcomes collectively represented good evidence that air pollution at ‘low concentrations’ on the level found in Scotland are linked to ‘excess ill health that should be preventable’ by cutting the pollutant levels further.

The working group highlighted a report commissioned in 2016 by the CAFS general governance group on the likely co- benefits between climate change and improvements that could be made to air quality. The report came back with 50 recommendations, of which 38 suggested interaction between tackling climate change and cutting air pollution was possible at the same time.

Turning to indoor air quality, the working group pointed out there were no regulated limits for indoor pollutants in households in the UK.

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 3

It said people living in urban areas spend 90% of their time inside meaning that the air they breathe inside is as important as that outside.

Up to three-quarters of indoor pollutants are concentrations of either NOx, SO2, O3 and PM’s and can be explained by variations in outdoor air quality. Sources depend on the setting; air pollution comes from burning fuels for heating and cooking, cigarette smoke and cleaning chemicals or products that use perfumes.

Meanwhile, America’s environmental protection agency reported that Volatile Organic Compounds given off by building materials, furniture, carpets and wall coverings are up to five times higher than those outside.

There are also pollutants which accumulate in properties, such as radon gas, CO2 and methane.

But again, there is a lack of information on the health effects of indoor air pollution, although the World Health Organisation (WHO) had suggested that it could contribute to up to 117,000 early deaths across Europe

The working group warned that new housing and other properties could increase the risk of indoor air pollution building up because they are being made more ‘air tight’ in order to retain heat and reduce carbon emissions.

It called for a more coordinated approach to indoor air quality and pointed out that the Scottish and UK governments do not have a department with sole responsibility for indoor air quality, although the issue ran across a number of different policy areas.

Household carbon reduction targets could accidentally create a health risk around indoor air quality in a repeat of the damage caused by the UK Government’s push to encourage people to buy diesel cars to cut CO2 emissions from vehicles in the last decade.

It added that the drive to energy efficiency to meet greenhouse gas emission targets ‘could have unexpected adverse health consequences, if these are not anticipated and mitigation measures identified.’ It continued: “Indoor air pollution is therefore a complex issue in its own right with unique determinants… it therefore merits more collective attention to assess its significant in relation to public health.

“A coordinated approach across government departments and other stakeholders is therefore needed to create a focus for a future cross-government indoor air quality strategy.”

Picture of an office in Manchester, above, that was redesigned by the Hilson Moran Partnership to provide good indoor air quality.

“Behaviour change would be helped by car scrappage incentives such as commuter season tickets and other sustainable travel”

Road transport emissions are the largest source of kerbside air pollution concentrations and poor air quality in urban areas in Scotland and contribute over one-sixth of total PM10 and one-third of NOx emissions.

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 4

The transport working group suggested efforts to encourage a change in public attitudes towards private car use should be high on the next CAFS strategy and electric vehicles cannot be relied on to solve health and congestion problems.

It pointed to a study in Cardiff that showed short-journeys of three miles of less accounted for 50% of all car trips and that these trips have a large impacts on carbon emissions.

Substituting these vehicle trips for walking or cycling in just 41% of cases could lead to savings of almost 5% of CO2 equivalent emissions.

The researchers in the Cardiff study, however, concluded that improving high quality active travel infrastructure was unlikely to achieve a significant reduction in carbon emissions if only these short car trips were cut out.

It said young people are driving less now than their predecessors did 20 years ago with the total number of car trips by those in the 17-29 age group falling by between 24% and 28%.

It called for more research to find out what the attitudes of young people are to driving and owning a car, with cost and the difficulties associated with ownership cited in some studies as a barrier.

It said that cars are less desirable or necessary for some young people in areas where public transport and cycling or walking infrastructure had improved.

The report said, for example, there had been a 20% rise in the number of people cycling in corridors such as the South West City Way in Glasgow, with 240,134 having ridden the dedicated cycle route in 2018.

It added that this surge in interest in cycling had not been reflected across Scotland overall and targets for cycling uptake had not been met.

It said bus services needed to run quickly and more reliably and that this would be helped by the introduction of bus lanes, bus gates – pictured right in Glasgow - and giving them priority at traffic signals. Providing ‘cleaner’ buses was currently more cost effective than the longer-term task of changing the private car fleets in urban transport corridors.

However, the report said current funding levels for active travel remained ‘insufficient to meet the need for transformation change, especially for infrastructure programmes and the associated behaviour change support work given the paucity of funding over many decades.’

It said the funding needed to be doubled again and that short-termism and ‘stop-start’ sustainable transport funding programmes must be replaced with permanent ones. The transport working group also looked at comments by the Standing Advisory Committee on Trunk Road Assessment that new roads bring on extra traffic and ‘locks in’ car driven modes of transport which effectively created a ‘vicious spiral of increasing private motorised travel.’

This has repercussions beyond car use and can lead to a deterioration in public transport provision too.

The transport working group said: “Their logic was that more road space equals more car use equals less public transport use, and so fares go up and frequency goes down, with the result that more people transfer to cars and the new equilibrium point is a lower level of service in both cars and public transport.” Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 5

A majority of the working group’s members agreed that additions to the existing trunk road and motorway network should end by 2024.

The group’s report also made the point that cities, such as Glasgow, which have taken out parking spaces to accommodate initiatives - such as ‘The Avenues’ cycling and walking route in Sauchiehall Street – had lost revenue from payments from car users. This is a potential loss of a source of funding that could have been used for active travel infrastructure improvements.

It described this as one of the ‘perverse incentives’ that can arise from efforts to encourage people to switch from car use to active travel.

The working group highlighted the success of the controversial Workplace Parking Levy (WPL), where local authorities can impose a fee per for each office car-park space in city centres. The charge is then passed by employers to staff who drive to work and the idea is that the money raised is spent on improve the area’s transport infrastructure.

There is currently provision in the Transport Bill to give local authorities the powers to introduce WPL’s.

The working group said a ‘significant’ switch was needed to walking and cycling which would cost far more than the current active travel budget. The reallocation of trunk road building and road widening schemes to cycle paths could provide ‘substantive’ health benefits and to air quality.

A study in Denmark had found that every kilometre travelled there by a person on a bicycle instead of by car was worth 1 Euro per person in terms of health benefits.

It said routine active travel should be encouraged by prioritising the construction of cycling infrastructure for some activities as commuting over leisure travel.

It called for a scrappage scheme that allowed people to trade in their petrol or diesel vehicles for contributions towards public transport season tickets and to encourage eBike ownership or other incentives to cut car ownership.

It said behaviour change programmes ‘would be helped by significant scrappage incentives’ and said eBikes had an important role to play in encouraging modal shift especially as take-up of the products became increasingly popular.

It called for Scottish Government funding to help local authorities follow the example of Edinburgh, which in May launched ‘Open Streets,’ pictured left, which has seen road closures for vehicles on the first Sunday of each month in some of its city centre streets.

It added: “Overall, there is a need to directly engage with the public on car ownership, but leadership from national government is needed.”

It said supplementary guidance on air quality did not go far enough and should be made mandatory. The working group’s report said this would help the Scottish Government impose changes where local authorities lacked ambition in relation to improving air quality. Powers are available to SEPA to direct councils to fulfil their duties, but the agency has to approach and seek approval from Scottish Ministers on a ‘case by case’ basis each time it needed to do so.

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 6

“To date these (powers) have not been exercised, in part because of the collaborative approach taken and also as there are now legal penalties available for not complying with SEPA Direction,” the report said. SEPA has an enforcement procedure in place for the use of these reserve powers, but it added that this has only consisted of warning letters sent by SEPA to local authorities and have mainly only been used in relation to late submission of annual air quality progress reports.

It said there should be ‘stronger action’ from the Scottish Government in terms of funding and actions in support of all local authorities to take stronger actions to improve air quality. It added that this could be an important way of tackling climate change.

In a section on how to drive public support for reduced car use, the report called for a long-term social marketing campaign around the issue.

It said there had been a lack of such programmes in relations to transport and air quality which risked building up feelings of mistrust and that the Government’s actions could be misinterpreted.

It said a revised CAFS strategy should be committed to a nationally funded and coordinated ‘citizen science’ and community engagement programme to help gain an understanding of air pollution and how people can make informed decisions to reduce their own impact on the environment.

It called for a major increase in bus-based Park and Ride schemes alongside Low Emission Zones and charges for cars which park at the facilities. This would help people who cannot afford to upgrade their older vehicles to an electric model – but who still need their cars for some of their journeys and do not want to be fined for entering an LEZ.

The report said ‘Park and Ride’ would be more effective if it was complemented by a ‘relentless attention’ to minimising the impact of congestion on bus routes connected to the schemes by not allowing bus lanes to be blocked by cars and vans.

The working group said it was important that new measures to discourage car use did not heighten social inequalities. It added: “It remains the poorest income groups, often with no or limited access to cars, are over-represented such as through residential location or occupational exposure (e.g. taxi drivers) to air pollution.”

“There are no quick fixes and collaborative working is required between all communities of interest”

THE Placemaking working group said there was a ‘real concensus’ among its members on the actions that were needed to be taken to improve the policy and deliver improvements in air quality.

The report said many of the challenges faced in delivering air pollution improvements, especially in towns and cities, result from ‘inertia and frictions’ caused by inherited road pavement layouts, past economical geography and other historical factors.

They said these inheritances can be adapted to a certain extent, but attention has to be made to our heritage, the cost of improvements and the impact that disruption can cause. It said that only with new-build properties and new street layouts can air quality and health solutions be more comprehensively addressed by ‘designing in’ these factors from the earliest planning stage.

But their report argued that unless these developments were ‘future- proofed’ to incorporate further changes in society they could be short- lived success stories.

Picture of the Urban Eden project in Edinburgh, above, courtesy of EMA Architecture + Design Ltd Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 7

The CAFS strategy had identified the importance of greenspaces in and around new developments as effective buffers and where recreation and active travel can be encouraged along with space for nature to be preserved or grow.

It working group viewed it as imperative for new developments to be linked to bus, walking and cycling routes and prioritise, where possible, these transport modes over vehicles.

Describing how large scale challenges remain in the adaptation of existing spaces, the report said the right kind of Placemaking could tackle air pollution and create, better, more sustainable environments and lives for residents and make them more attractive for businesses too. The report highlighted some of the influences on Placemaking, including EU research in 2015 that stated the way to achieve sustainable development and make the economy greener was to embraced natural based solutions. The ‘Cities of Tomorrow’ report by the European Commission, which set out how cities can mitigate the impact of climate change, was also highlighted.

The Scottish and UK governments support for the UN Sustainable Development Goals and National Planning Framework 3 (NPF 3) won praise as did the ‘Good Places Better Health’ report for the Scottish Government in 2008 and the 2013 ‘Creating Places’ Scottish Government policy statement. It contained a commitment to develop the Place Standard assessment tool as the hallmark of well-designed places.

The working group’s final report also singled out the work of the Connectivity Commission report, led by Professor David Begg in 2019 – a piece of work commissioned by Glasgow City Council to drive changes in the city’s transport infrastructure.

Prof Begg’s report described Glasgow is an example of a city ‘of contradictions.’ It had the largest suburban rail network outside of London, but it still struggled to accommodate rising passenger numbers. Despite below average car ownership levels among its population, major road projects such as the M74 extension had still been given the go ahead.

One of the proposals in Prof Begg’s report included a canopy over a section of the M8 that runs through the Charing Cross area of Glasgow with the neighbouring slip road and street furniture to be replaced by trees and walking and relaxation areas. (See the artists’ impression compared and current view of Charing Cross below)

The working group said some of the recommendations coming from Prof Begg’s commission and the EU H20220 Connecting Nature project, which aims to introduce more nature based solutions to some climate change and adaptation policies in Glasgow, could be built into future improvements to Placemaking.

The working group recommended further research and development to make planners more aware of the pressures and impacts of air pollution and how they can be mitigated and ‘reframed.’

It also said an over-arching Placemaking theme was required in the CAFS strategy with a greater understanding of how the PlaceStandard philosophy can help guide awareness of air quality.

There needed to be analysis of how legislation around air quality is embedded in policy national, regionally and locally and how The National Planning Policy Framework, National Transport Strategy and Place Principles are all linked into embedded policy nationally.

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 8

It also said assessments were needed as to how the pilot air quality training has been received by planners and whether it should be rolled out elsewhere, and whether planning officers across the board have the required skills to place the latest air quality polices properly within plans and strategies.

It also called for investigations into how many local authorities included air quality policies within their development plans or other statutory documents and look at how many ‘City Deals’ have air quality initiatives and what these are for and whether they affect regional policy decisions.

The working group’s report also said there needed to be analysis of how existing air quality spatial polices have been implemented and what can be learnt from failed policies.

It said there should be a database of possible nature based solutions covering social, environmental and economic areas and what is currently influencing behaviour change and how are we using data and whether public health priorities are understood.

It also said there was a need to know what impact the Scottish Government is currently making on behaviour change with our existing polices and to identify what behaviour it is trying to influence.

It highlighted the need for a good communications strategy to make the public better informed about what is required to make Placemaking work and the benefits it brings them in terms of their health and well-being.

“The measures outlined in DEFRA’S Clean Air Strategy will result in emissions reductions”

The working group on agriculture, industrial and domestic emissions (AIDE) agreed that Scotland should aim to follow the strategy adopted by DEFRA on domestic combustion emissions.

This recognises that wood burning emissions depend on whether a new or older type of appliance is used and the condition of the wood, with how the stove is used by owners, maintenance of the appliance and chimney, and the dryness of the wood other factors.

Emissions from wood burning in cities across the UK, including Glasgow, Edinburgh and Dundee fell in the six years leading up to 2015, according to DEFRA’s own research with the main reason for this being the replacement of traditional open fires and older stoves with more modern equipment which produce less PM10 and PM2.5.

AIDE said DEFRA had predicted further reductions in emissions based on the research and called on the Scottish Government to see if it can emulate and build on the UK Government department’s methodology.

It said the DEFRA research concluded it to say that it believed the measures in the overall UK clean air strategy will result in emissions reductions.

Questions marks remained about how customers can be encouraged to replace open fires and upgrade to the latest industry standard Ecodesign new stoves, which can achieve emission reductions of up to 90%

The Department for Business, Energy and Industrial strategy estimated 44% of wood in Scotland was burned on open fires and 51% in stoves.

The working group said that in line with the previously mentioned emissions benefits of owning an Ecodesign stove, replacing this percentage of wood burnt in open fires would cut emissions by around 40%.

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 9

It said chimney sweeps had a part to play in giving advice to householders about good burning practice, but that their level of training needed to be improvement and they needed proper accreditation.

The working group’s report said the educating stove owners about how to operate and burn wood properly in the home is important and mentioned the ‘Burnright’ initiative that is led by Lawson Wight. Click to read a previous Newsletter interview with Mr Wight here.

The working group said analysis of the different approaches to reduce ammonia emissions in England, Denmark, the Netherlands and Germany could inform the Scottish policy approach.

Scotland emits around 34 kilotonnes of ammonia, which made up 12% of UK emission and levels have fallen slow than other pollutants (by 12% ) since 1990.

There has been a decline in animal numbers and fertiliser use since then, but this has been offset by a rise in urea- based fertilisers leading to higher emissions and they have plateaued since 2008.

Although most agriculture emission sources have fallen in the last 29 years, the sector still produces large amounts of PM10, PM2.5 and Volatile Organic Compounds and emissions linked to laying hens have risen since 2008.

The working group highlighted the importance of the agriculture sector being aware of any differences between ammonia mitigation policies in Scotland to those that exist or are introduced in England.

Stories sections of the media have tended to concentrate on the DEFRA Clean Air Strategy and not any Scottish specific policies.

With the UK Government required to report to the National Emissions Ceilings Directive (NECD) on the impact of air pollution on ecosystems, a report on the UK Network to Monitor the Impacts of Air Pollution on Ecosystems said the UK will meet this obligation.

However, the working group said the report found that for terrestrial ecosystems, the representativeness of habitats in Scotland and the suite of parameters measure were inadequate. The working group said that there was good coverage for freshwaters and atmospheric chemistry, but that it was likely Scotland would need more monitoring of more parameters across a broader range of terrestrial habitats because the ecological effects of air pollution abatement could be detected with any confidence.

The working group suggested another reason for a national, as opposed to a localised approach to emissions, was that 50% of these were transboundary.

Ammonia is a risk to public health because it binds with acids to form fine particles which can be carried tens of hundreds of kilometres from the source. It can also lead to the complete breakdown of some forms of plant life, such as certain types of moss and lichens. With little coverage in the specialist farming press about the impacts of ammonia, the working group called for engagement with famers to make them aware of the importance of including high nutrient levels in manures and fertilisers.

It added that changing farm management to cut emissions could require upfront funds which may not be possible for many struggling farmers and cost benefit analysis was required. Picture credit, above: Akeg/Flickr Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 10

The working group’s agriculture sub-group also suggested the Scottish Government develop a voluntary code of practice on ammonia emissions with the industry.

On the issue of industrial emissions, the working group recognised that a comprehensive framework already existed, but said there were a few areas where improvements could be looked at by the CAFS strategy.

These included whether there was an environmental benefit to bringing currently unregulated sectors that have not been prescribed by EU legislation under the remit of existing legal frameworks for air emissions. It could affect non- waste anaerobic digestion and short term operating (STOR) generators; whether amendments to the existing legal framework were required to remove loopholes, ambiguities and gaps and whether additional reductions in industrial emission sources can be achieved where certain pollutants are not showing a downward trend.

In its conclusions, it said that due to the prescriptive nature of the legal regimes surrounding industrial emissions, further reductions may be difficult unless measures which go beyond compliance are implemented.

It highlighted SEPA’s on-going work with its ‘sector plans’ which cover 15 areas of industrial and commercial emissions.

The CAFS report said it was difficult to assess the implications of Brexit on emissions control legislation.

However, the report said Scotland should aim to continue with the transfer of current EU requirements into domestic legislation as a ‘minimum standard.’ The report said it had been demonstrated that the requirements that came out of Brussels were ‘proportionate and effective in reducing emissions.’

But it also added that further reductions should be targeted to provide additional environmental benefits.

FURTHER LINKS:

To read the CAFS Review report click here https://www.gov.scot/publications/cleaner-air-scotland-strategy-independent- review/

Environmental Protection Scotland working for a cleaner, quieter, healthier and sustainable Scotland 11