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Environment Improvement Plan 2023: Clean Air


The Environmental Improvement Plan 2023 (EIP23), published on 31 January, is the first revision of the 25YEP, planned on a five-year rolling cycle as set out in the Environment Act 2021

When Defra published the 25 Year Environment Plan (25YEP) in 2018, Clean Air was the first of its 10 goals. Poor air quality has been identified as the greatest environmental threat to human health, in addition to the significant negative impacts air pollution has on ecosystems and biodiversity. The (mostly) downward trend in key pollutant emissions has been maintained since 2018 but the policy content of the goal, the associated target and commitments, was somewhat thinner than for other goals and policy areas. They relied heavily on existing legal targets and policy commitments, as well as promising a future air quality strategy. This is understandable, given that the publication of the 25YEP came part way through the development of the UK National Air Pollution Control Programme, which would form the basis of the Clean Air Strategy. This was duly delivered in 2019 and contained a far more extensive treatment of the issue and the Government’s proposed response.

The Environmental Improvement Plan 2023 (EIP23), published on 31 January, is the first revision of the 25YEP, planned on a five-year rolling cycle as set out in the Environment Act 2021. The EIP23, and the Clean Air Goal within it, are certainly an improvement over the 25YEP. Structurally, the EIP is far clearer, where the targets, commitments and top-level actions are clearly set out and include:

  • A commitment to the existing national emissions reduction targets and air quality concentration targets: with the spectre of the Retained EU Law (Revocation and Reform) Bill (REUL) going through Parliament, this wasn’t a given. The EIP also reaffirms the two new long term targets for PM2.5 set under the Environment Act 2021.

  • Interim targets for PM2.5, something that many of the consultees to the long-term targets called for.

  • A five point delivery plan which draws in actions by other Departments and local authorities

  • Action, or the consideration of action, on key sources, including domestic burning, agriculture, industry and transport, including shipping.

Further detail will be set out in an amended air quality strategy and monitoring and evaluation will be provided through a consistent set of six indicators; Clean Air was one of the few areas under the 25YEP where outcome indicators were fully established and populated with data.

This is all good and progressive and certainly builds on and extends the commitments under the 25YEP. However, closer reading leaves a number of unanswered questions and shows, potentially, an opportunity for greater ambition having been missed. For example, the interim targets for PM2.5 are for the “highest annual mean concentration” not to exceed 12µg/m3 by 2028, and a 22% reduction in population exposure (compared to 2018 levels). To put this into wider context, the European Commission’s proposed revisions to the Ambient Air Quality Directive (AAQD), published in October 2022, set an annual average PM2.5 Limit Value of 10µg/m3 by 2030 and a 25% reduction in population exposure over the same timescales.

Thus, the UK targets appear slightly weaker than those proposed for the EU, despite many EU Member States having much higher levels of PM2.5 than the UK. Of course, the amended Directive has not yet been agreed and adopted and the negotiation process will bring changes. Moreover, the revised Directive provides a long term vision of EU policy aims, tied to the European Green Deal and a net zero pollution ambition. This provides at least a partial view of what the Commission sees as the final objective for the policy area, i.e. “Clean Air”, a definition of which is missing from the EIP (as it was from the 25YEP).

In terms of implementation, the EIP’s description of local authorities as delivery partners is a step forward, and the mention of development planning is welcomed. Planning now plays a central role in air quality management at a local level. While the EIP promises further detail in a revised air quality strategy, due in May[1], local authorities and developers are still in the dark as to the application of the new PM2.5 targets to planning decisions. The lack of clarity on what the targets mean at a local level has led to much, sometimes misguided, speculation and for anyone either proposing or deciding on a major development, the detail cannot come soon enough.

Reducing ammonia emissions from agriculture is one of the five key action points from the EIP23, and rightly so if population exposure to PM2.5 is to meet the levels proposed (ammonia is a key precursor for secondary particulate matter). Extending emissions regulation to dairy and beef farms is being considered and much will rest on the replacement for the Common Agriculture Policy system of subsidies and payments, including the Environmental Land Management schemes (ELMs) still under development. In fact, ELMs are central to achieving several of the goals under the EIP, and their delivery will provide a key test of how joined up Defra can be in its dual roles of protecting the environment and supporting agriculture and rural communities.

On transport, it’s encouraging to see the continued commitment to Clean Air Zones, and to addressing air quality on the railways, especially at train stations. The proposed consultation on a nitrogen and sulphur emission control zone in the Irish Sea is a positive move, given the prevailing winds in the UK and the importance shipping emissions have for background levels of particulate matter.

Finally, domestic burning is singled out as a key source of particulate matter emissions, and one which needs to be further controlled. This presents a significant challenge for air quality policy: a diffuse and highly variable source with a control regime rooted in the 1950s and which is often driven by aesthetic choices rather than market forces. The EIP sets out incremental changes to the current system of regulation, such as the extension of controls to fuels burnt outside (but not including charcoal). This is not likely to make a great difference to the main culprit – log burning stoves and fireplaces – and the tightening of smoke emission standards for new stoves used in smoke control areas will not affect the “Defra approved” stoves already installed.

The EIP23 explains that a ban on domestic solid fuel use is not under consideration, due to the small number of households who rely on it as a sole form of heating, hot water and cooking. Nevertheless, moves to swap out stoves and burners for gas or non-combustion alternatives are likely to require significant financial support, which is an issue that rests with Treasury rather than Defra. In any case, households who have paid to have a stove installed as an additional heating source, potentially for aesthetic reasons, are unlikely to find a scheme to have it removed particularly attractive. Added to this, emerging evidence suggests that the level of domestic burning has increased this year, as households try to offset the impact of the rise in gas and electricity prices. This is a complex picture and significant progress will rely on addressing the drivers for domestic solid fuel use, which will need to go beyond changes to smoke control legislation and engage with some difficult social, and political, issues.

© Air Quality Consultants, Logika Consultants and Noise Consultants 2024