University for the West of England's Dr Ben Williams presents on Defra's air quality plans at the IAQM's annual general

1. UWE response to the Defra Air
Quality Plan consultation
Dr Ben Williams
Air Quality Management Resource Centre, UWE
Ben3.williams@uwe.ac.uk
12th November 2015

2. Outline
• General Comments
• Model Assumptions
• Clean Air Zones
• National Responsibilities
• Points of Clarification

3. General Comments
• Disappointed that despite a public health crisis we still haven’t achieved
compliance within legally defined timeframes.
• This plan represents the national government’s interpretation of the Supreme
Court’s judgement of “…the need for immediate action”.
• Disappointed with the lack of clarity and lack of national government action
within the plan.

4. Model Assumptions
• Data used in COPERT 4 (v11) are not thought to be representative of real-world
emissions but are the basis for the modelling undertaken in the proposed Plan.
• Literature suggests real-world emissions are somewhere between 4 and 7 times
type-approval limits1.
• Alternative scenario seems more realistic, but needs to be properly assessed
when data and assumptions are made available.
• On the basis of the alternative scenario 30 zones and agglomerations would be
non-compliant by 2020.
1 http://europa.eu/rapid/press-release_IP-15-5945_en.htm

5. Clean Air Zones
• Unclear how many of the six local authorities have stated their desire to
implement CAZs.
• How will local authorities fund the scoping, development, implementation and
management of CAZs?
• If local authorities decide not to implement CAZ then the modelled outputs
won’t be appropriate for that area. Is there a plan B?
• If local authorities don’t take up CAZs will they be held accountable for national
government’s failure to comply with the Ambient Air Quality Directive?
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/311449/Annex_A_Letter_to_LAs_o
n_NO2_infraction.pdf

6. National Responsibilities
• National government bears responsibility for complying with the Ambient Air Quality
Directive.
• The national government needs to develop an air quality plan that actually addresses the
problem instead of masking it with model outputs.
• The national government needs to make clear that it will support stronger planning
decisions by local authorities that seek to reduce or limit air pollution emissions.
• The national government has to support the implementation of more stringent testing
regimes and ongoing testing of in-service vehicles to ensure standards are met during the
lifetime of the vehicle.
• Do proposed amendments to type-approval testing cycles go far enough?

7. Points of Clarification
• Which aspects of SL-PCM have been streamlined and how does this differ from the standard
PCM model?
• Clarification as to the basis of any conformity factors used.
• The data and assumptions used in calculating the “alternative scenario”.
• Have Defra undertaken a survey of local authorities to determine the likelihood of CAZ
uptake? If so, we would expect these data to be made publicly available.
• Under what circumstances, if any, will local authorities bear the cost of any fines imposed as
a result of non-compliance?