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.