Setting new targets for air quality - consultation response

In June 2022 we responded to a consultation from the Department for Environment, Food and Rural Affairs (DEFRA) on setting environmental targets. We responded to the questions on target proposals for air quality only. This page provides a summary and you can download our full response.

Air pollution poses the biggest environmental risk to public health and is a particular risk to vulnerable groups, including the elderly, the very young, and those with existing health conditions. 

The Environment Act 2021 gave a requirement for Government to set new environmental targets in a number of areas, including for fine particulate matter (PM2.5).

DEFRA’s proposed targets for air quality that this consultation refers to are:

  • Annual Mean Concentration Target (‘concentration target’) for PM2.5 – a target of 10 micrograms per cubic metre (µg m-3) to be met across England by 2040. 
  • Population Exposure Reduction Target (‘exposure reduction target’) – a 35% reduction in population exposure by 2040 (compared to a base year of 2018). 

Below is a summary of our response and recommendations. A copy of our full response is available in the downloads section at the foot of this page. 

Our response 

We disagree with the level of ambition proposed for both the Annual Mean Concentration Target and the Population Exposure Reduction Target. 

Our overarching recommendation is the UK Government must set its legally binding target for fine particulate matter (PM2.5) of 10 micrograms per cubic metre by 2030 – ten years earlier than their current proposal – in order to safeguard the health of current and future generations.

The Pathway to Healthy Air in the UK report clearly demonstrates that a PM2.5 target for of 10 micrograms per cubic metre can be met by 2030 if current and proposed policies are fully implemented. The same research highlighted clear economic and health co-benefits of meeting this target, including children across the UK suffering an average of 388,000 fewer days of asthma symptoms per year.

In our response we have highlighted our five major concerns in detail. These are: 

  1. This consultation does not reference the WHO Air Quality Guidelines, which are based on expert evaluation of current scientific evidence. 
  2. The proposed targets do not take account of the unique impact of air pollution exposure during pregnancy and childhood.
  3. The proposed targets lack ambition. 2040 is 18 years away, meaning that under the proposed target another generation of children are set to grow up breathing polluted air.
  4. The consultation does not clearly recognise the urgent need for strong policies in key areas such as domestic burning and road transport in order to be able to reach the proposed PM2.5 targets.
  5. The consultation does not include targets for reducing the other components of air pollution that also have adverse impacts on health, including ozone, nitrogen dioxide and sulphur dioxide.

In summary: air pollution is a health equity issue. More deprived communities in the UK are typically exposed to higher levels of both indoor and outdoor air pollution. Emergency admissions for asthma are strongly associated with deprivation, and adverse pregnancy outcomes related to air pollution are higher among low socioeconomic and ethnic minority groups. Policy action must be taken to reduce these harms. Solutions in individual sectors are well recognised, and now a commitment must be made to reach WHO limits by 2030. This must be coupled with robust plans to ensure that targets are met, with action and research focusing on the most impacted communities. 

Our recommendations 

On the targets – we are asking DEFRA to:

  • Make the PM2.5 targets more ambitious. The WHO Air Quality Guideline from 2005 (for PM2.5 levels of no more than 10 micrograms m-3) can and should be met by 2030 at the latest, with urgent consideration given to setting stronger targets informed by the updated guidelines published in September 2021.
  • Set targets for the other components of air pollution in line with WHO advice published in September 2021. 

On the other policy areas referenced in the consultation:

Active travel – we are asking DEFRA to: 

  • Support the expansion of clean air zones in towns and cities.
  • Expand 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.
  • Consider additional strategies which limit emissions near schools, including use of 20mph zones and giving local authorities the power to close or divert roads when air pollution exceeds set limits.

Restrictions on domestic wood burning – we are asking DEFRA to:

  • Implement stronger controls on household wood burning, and take action to raise awareness of the contribution of wood burning to the health harms from air pollution.