Environment (Air Quality and Soundscapes) (Wales) Bill - consultation response

In April 2023 we responded to the Welsh Government consultation on the Environment (Air Quality and Soundscapes) (Wales) Bill. We welcomed this consultation.

This consultation looked at:

  • providing a framework for setting national air quality targets
  • amending existing legislation relating to the national air quality strategy; local air quality management; smoke control; clean air zones/low emission zones and vehicle idling
  • placing a duty on Welsh Ministers to promote awareness of air pollution
  • placing a duty on Welsh Ministers to publish a national soundscape strategy.

Our response

We very much welcomed the overarching aim of this Bill, which the Explanatory Memorandum (PDF) states as being to “bring forward measures that will contribute to improvements in the quality of the air environment in Wales and reduce the impacts of air pollution on human health, biodiversity, the natural environment and our economy”. 

The health impacts of poor air quality are well known and are described in the Explanatory Memorandum. Our position statement on outdoor air quality in the UK sets out evidence and describes the impact on children and young people, specifically.

Three key points driving our support for legislation to improve air quality are: 

  • The effects of air pollution can start before birth and are shown to have a greater impact on babies, children and young people. These effects are particularly damaging because they can have a lifelong impact and those with existing health conditions are even more vulnerable. 
  • cross the UK, the most deprived communities experience the worst air quality, further driving health inequalities. 
  • Air pollution is a clearly modifiable and avoidable cause of morbidity and mortality and as such, action can and should be taken to reduce or remove this harm. 

Our position statement on child health inequalities further elaborates on the inequalities driving harms associated with poor air quality. It notes that air pollution exposure is highest in the most income deprived areas, and children are disproportionally exposed to the highest levels of pollution. 

Our recommendations

  • We welcome the proposals to create a robust target setting framework, informed by independent expert advice and by the WHO. We strongly agree that this should be underpinned by an equally robust compliance monitoring and reporting mechanism.  
  • In our outdoor air quality position statement, we noted that “more detailed and more widespread monitoring is required to measure each population's exposure to air pollution, particularly in urban areas and near schools… Monitoring needs to advance in line with our understanding of pollutants to provide an accurate picture of risk and inform action.” 
  • In our response to the Welsh Government’s White Paper on a Clean Air (Wales) Bill, we highlighted the need to better inform and support health professionals to take local action and provide advice to patients.
  • Health professionals have a duty of care to inform their patients of the dangers of air pollution and how they can better protect themselves from it. We therefore particularly welcome that the delivery plan could improve “the provision of air pollution resources for health professionals and patients”. This could be strengthened to ensure that it is a specific commitment, rather than a possible outcome.  
  • We support the expansion of clean air zones in towns and cities and expanding the infrastructure to support active travel, travel by public transport and electric vehicles. This includes ensuring populations living in rural and remote communities also have adequate public transport links. We support giving local authorities the power to close or divert roads when air pollution exceeds set limits.

We respond to a wide range of consultations to ensure that the College’s position, and ultimately children’s health, is represented. Members can get involved in current consultations by contacting the Wales team at enquiries.wales@rcpch.ac.uk.