What is the DfT doing to ensure the UK meets EU air quality limit values?

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The Rt. Hon. Ruth Kelly MP,
Secretary of State for Transport,
Department for Transport,
Great Minster House,
76 Marsham Street
London SW1P 4DR

By email to:      [email protected][email protected]               24 October 2007

Dear Secretary of State

What is the DfT doing to ensure the UK meets EU air quality limit values?

The primary purpose of this letter is to request please an urgent and comprehensive answer as to what the Department for Transport (DfT) is doing now and planning to introduce as specific measures to ensure that the United Kingdom (UK) achieves the European Union’s (EU) Limit Values for air quality throughout London given that road transport, particularly in so-called “hotspot areas”, is the biggest single cause of exceedances? Crucially, by what date does the DfT consider that these binding legal obligations for air quality will be met?

With the  greatest respect, the  Campaign for  Clean Air  in  London (CCAL) has  seen  no evidence demonstrating that the DfT has yet engaged seriously with air quality as an urgent problem.   To put the seriousness of this matter into perspective, one form of air pollution alone, called particulate matter caused over 1,000 premature deaths in London in 2005 which compares with around 230 people who died in London from road traffic accidents in each of 2005 and 2006 and 617 such deaths per annum nationally from passive workplace related smoking before the recent legislation came into force.

Given the seriousness, urgency and scope of the issues raised in this letter, we have copied this letter to the Prime Minister.

The Campaign for Clean Air in London

The Campaign for Clean Air in London has only one aim which is to achieve urgently at least World  Health  Organisation  (WHO)  recommended  standards  of  air  quality  throughout London.  Given that most of these have been required to be met since 1999 legislation by January 2005 (in respect of coarse particulate matter i.e. PM10) and January 2010 (for nitrogen dioxide i.e. NO2), CCAL is campaigning to achieve sustainably at least WHO recommended standards of air quality throughout London by no later than the London 2012 Summer Olympics.

CCAL has received support from the Mayor of London, leading politicians from the four main political parties in London as well as leading business and community groups including the Central London Partnership, London First and The Knightsbridge Business Group. It has also received a Pledge of support from Environment Protection UK (formerly the National Society for Clean Air and Environmental Protection).  Our campaign website address is shown in the letterhead above.

15 Crucial questions for the Department for Transport to answer

CCAL asks respectfully that you reply personally, in your capacity as Secretary of State for Transport, to the two primary questions above and to the other specific questions listed below. Relevant background information appears in the attached letter submitted recently to Mayor Livingstone in response to his consultation on Emissions Related Congestion Charging (e.g. on EU legislation and the dangers of diesel emissions) that was copied to you.

  1. What is the DfT doing now and planning to introduce as specific measures to ensure that the UK achieves the EU Limit Values for air quality throughout London given that road transport, particularly in so-called “hotspot areas”, is the biggest cause of exceedances?;
  2. By what date does the DfT consider currently that each of these binding EU legal obligations for air quality will be met for each of the regulated air pollutants?;
  3. Is my understanding correct that the DfT is jointly responsible with the Department of Environment, Food and Rural Affairs (Defra) for the UK meeting its legal obligations in respect of the EU Limit Values for air quality?  Assuming this belief is correct, will the DfT please make this responsibility explicit on its website e.g. in its aims and objectives, its organisation chart and elsewhere?;
  4. Will the DfT confirm please that it is treating air quality in its highest category of Ministerial level issues given that the UK is in breach of EU Legal Limits for air quality and now faces the possibility of enforcement action by the European Court of Justice?;
  5. Will the DfT please commit to consider air pollution holistically (i.e. air quality and climate change together) whenever it considers any air pollution related matters?;
  6. Will the DfT please reposition urgently “Act on CO2” such that it advises citizens much more appropriately about vehicle choice?  For example, the US Environment Protection Agency’s “Green Vehicle Guide” gives much more relevant, sophisticated and useful advice by highlighting an “Air Pollution Score” ahead of a “Greenhouse Gas Score”;
  7. What action specifically is the DfT taking to actively and substantially discourage the driving of diesel engined vehicles in London?   Please confirm that the emissions information given by Minister of State, Dr Stephen Ladyman, in a written answer to Mr Arbuthnot about “Motor Vehicles: Exhaust Emissions” on or about 25 June 2007 was correct (it was for different vehicle types in g/km) (please refer to Column 522W of Hansard);
  8. What is the DfT doing to introduce technology and testing standards for the abatement of emissions of nitrogen oxides from vehicles of all sizes with particular reference to Selective Catalytic Reduction and its use in the UK’s current vehicle fleet (i.e. not just new vehicles)?  When will these measures be implemented and with what estimated impact?;
  9. Why did the DfT “scrap” recently the only DfT programme that seemed to incentivise actively the adoption of alternatively fuelled, low emission, vehicles?;
  10. Will the DfT commit to rebalancing and modifying fuel tax so that it treats air pollution emissions holistically rather than favouring diesel fuel as currently (with its slightly lower CO2 emissions but its much higher emissions of the hazardous air pollutants)?;
  11. Will the DfT commit to rebalancing and modifying Vehicle Excise Duty (VED) banding so that it treats air pollution emissions holistically instead of unbalancing the incentives in favour of diesel engines?;
  12. What information does the DfT hold about air pollution emissions per kilometre for different types of motorcycles?;
  13. What action is the DfT taking to ensure that the use of biofuels in the UK is sustainable and takes full account of the need to meet air quality legal obligations?;
  14. What incentives is the DfT proposing to encourage the early adoption of the much cleaner Euro 4/IV and Euro 5/V engines in London and to scrap the oldest, most polluting, vehicles when Defra’s new National Air Quality Strategy made clear that transport related measures offer exceptionally favourable benefit to cost ratios?; and last but not least
  15. What specific action is the DfT taking to assist London to introduce urgently dynamic road pricing (“tag and beacon” or the equivalent) to replace in full the current “blunt instrument” of congestion charging?   What more needs to be done to implement this mechanism quickly across London?

We appreciate that some of these may be tough questions but how can the UK expect to satisfy the European Commission that it is making reasonable efforts to meet its legal obligations in respect of air quality, which it may be required to do shortly, when much more significant measures are clearly needed for it to do so.


CCAL considers that the DfT could, with a change in its culture and a fresh approach that treats the improvement of air quality as an absolute and urgent Ministerial priority, make substantial contributions immediately to improve London’s air quality.  In many cases, the DfT could do this simply by amending modestly existing mechanisms and in others by positively and urgently prioritising the most meaningful new measures (such as those outlined above).  CCAL respectfully urges you, as Secretary of State, to initiate this fresh approach at the DfT. We would welcome your considered response please to these questions by electronic reply to the email address provided separately.

With best wishes.

Yours sincerely



Simon Birkett
Principal Contact
Campaign for Clean Air in London

By hand:

Winston Fletcher, Chair, The Knightsbridge Association
Carol Seymour-Newton, Honorary Secretary, The Knightsbridge Association


The Rt. Hon. Gordon Brown, The Prime Minister
Commissioner Dimas
The Rt. Hon. Hilary Benn MP, Secretary of State for Defra
Mayor Livingstone
Sian Berry, Principal Speaker and Green Party candidate for Mayor of London
Boris Johnston MP, Conservative Party candidate for Mayor of London


Amenity Societies
Helen Ainsworth, EU and International Air Quality, Defra
Jenny Bates, London Regional Campaigns Co-ordinator, Friends of the Earth
James Bidwell, Chief Executive, Visit London
John  Brewster  OBE,  Chairman,  Port  Health  and  Environmental  Services  Committee, Corporation of London
Patricia Brown, Chief Executive, Central London Partnership
Robert Buxton, Deputy Chairman, West London Residents Association
Sarah Dudgeon, National and Local Air Quality, Defra
Nick Fairholm, Transport for London
David Higgins, Chief Executive, Olympic Delivery Authority
Tim Hockney, Executive Director, London First
Professor Frank Kelly, Kings College London
Dr Michal Krzyzanowksi, Regional Adviser, Air Quality and Health, WHO
Sarah Legge, GLA Principal Policy Adviser – Air Quality
Blake Ludwig, Campaign Director, Alliance Against Urban 4x4s
Professor Bob Maynard, Health Protection Agency
Paul McLoughlin, UK General Manager, Zipcar
Philip Mulligan, Chief Executive, Environment Protection UK
Derek Picot, Chairman, The Knightsbridge Business Group
Dr Gordon Taylor, Chairman, West London Residents Association
Dr Martin Williams, Head of Air and Environment Quality Division, Defra


Peter Ainsworth MP, Shadow Secretary of State, Defra, Conservative
Greg Barker MP, Shadow Minister for the Environment, Conservative
Mrs Gwyneth Dunwoody MP, Chair of the Transport Committee, Labour
Mark Field MP, Conservative
Jim Fitzpatrick MP, Parliamentary Under Secretary of State, DfT
Tom Harris MP, Parliamentary Under Secretary of State for Transport, DfT
Chris Huhne MP, Shadow Environment Secretary, Liberal Democrat
The Rt. Hon. Michael Jack MP, Chairman of the Environment and Rural Affairs Select Committee
Susan Kramer MP, Shadow Secretary of State for Transport, Liberal Democrat
The Rt. Hon. Sir Malcolm Rifkind QC MP, Conservative
The Rt. Hon. the Lord Rooker, Minister of State, Defra
Joan Ruddock MP, Parliamentary Under Secretary of State
Jonathan Shaw MP, Parliamentary Under Secretary of State and Minister for the South East
Theresa Villiers MP, Shadow Secretary of State for Transport, Conservative
The Rt. Hon. Rosie Winterton MP, Minister of State for Transport
Phil Woolas MP, Minister of State, Defra
Tim Yeo MP, Chairman Environmental Audit Committee, Conservative
Gerard Batten MEP, London, Independence
John Bowis MEP, London, Conservative
Chris Davies MEP, Liberal Democrat
Robert Evans MEP, London, Labour
Mary Honeyball MEP, London, Labour
Syed Kamall MEP, London, Conservative
Ms Jean Lambert MEP, London, Green Party
Baroness Ludford MEP, London, Liberal Democrat
Linda McAvan MEP, Labour
Claude Moraes MEP, London, Labour
Charles Tannock MEP, London, Conservative
Angie Bray AM, Leader of the Conservative Group, GLA
Tony Arbour AM, Conservative
Richard Barnes AM, Conservative
Robert Blackman AM, Conservative
Brian Coleman AM, Conservative
Roger Evans AM, Conservative
Elizabeth Howlett AM, Conservative
Bob Neill AM, Conservative
Andrew Pelling AM, Conservative
Jenny Jones AM, Leader of the Green Group, GLA
Darren Johnson AM, Chair of the Environment Committee, GLA, Green
Len Duvall AM, Leader of the Labour Group, GLA
Jeanette Arnold AM, Labour
John Biggs AM, Labour
Nicky Gavron AM, Labour
Joanne McCartney AM, Labour
Valerie Shawcross AM, Labour
Murad Qureshi AM, Labour
Mike Tuffrey AM, Leader of the Liberal Democrat Group, GLA
Dee Doocey AM, Liberal Democrat
Sally Hamwee AM, Liberal Democrat
Geoff Pope AM, Liberal Democrat
The Lord Tope, AM, Liberal Democrat
Peter Hulme Cross AM, One London Group, GLA
Damian Hockney AM, One London Group, GLA
Councillor Sir Simon Milton, Leader of the Council, WCC, Conservative
Councillor Alan Bradley, Chair, Go Green Board, WCC, Conservative
Councillor Merrick Cockell, Leader of the Council, RBKC, Conservative
Councillor Daniel Moylan, Deputy Leader, RBKC, Conservative
Councillor Frances Blois, WCC, Conservative
Councillor Tony Devenish, WCC, Conservative
Councillor Philippa Roe, WCC, Conservative
Councillor Dr Iain Hanham, RBKC, Conservative
Councillor Margot James, RBKC, Conservative
Councillor Mrs Shireen Ritchie, RBKC, Conservative


Rebecca Brown, Environment Quality Unit, RBKC
Guy Denington, Team Manager, Environment Quality Unit, RBKC
Martin Low, Director of Transportation, WCC
Mike LeRoy, WCC
Mahmood Siddiqi, Chief Traffic Engineer, RBKC