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