Key information
Decision type: Mayor
Reference code: MD2714
Date signed:
Date published:
Decision by: Sadiq Khan, Mayor of London
Executive summary
The Mayor has identified improving air quality as one of his key priorities given its impact on public health and health inequality. A comprehensive plan to achieve (and go beyond) legal air quality standards as quickly and effectively as possible has been set out in the London Environment Strategy (LES), draft London Plan and in the Mayor’s Transport Strategy (MTS). The Mayor also has a number of legal duties, including in relation to the fulfilment by the London boroughs of their local air quality management (LAQM) functions.
Most of the activity and expenditure related to the air quality programme is authorised by project-specific Mayoral decisions. This decision invites the Mayor to approve the funding needed to deliver supporting elements (e.g. supporting schools, research, modelling and evaluation) of the air quality work programme in financial year 2020/21 as well as to undertake preparations for the expansion of the Ultra Low Emission Zone (ULEZ) in October 2021 and support work relating to delivering a Green Recovery in line with the London Recovery Board’s missions. It approves expenditure of £260,000 in 2020/21. This will take total approved expenditure on air quality in the year to £692,000, from a budget of £740,000 with the remaining covering staffing costs.
Decision
That the Mayor approves:
Expenditure of £260,000 to deliver the following supporting activities for the air quality programme:
• additional action to improve air quality at schools, nurseries and other sensitive sites (£70,000);
• evaluation, monitoring and research programme (£150,000); and
• London Atmospheric Emissions Inventory (LAEI) / London Greenhouse Gas Emissions Inventory (LEGGI) Analysis Tool (£40,000).
Part 1: Non-confidential facts and advice
1.1 The air quality team within the Environment Unit is required to undertake a range of activities as part of delivering on statutory functions and manifesto commitments as well as supporting the implementation of the statutory London Environment Strategy, London Plan and Mayor’s Transport Strategy. The team also provide inventories of data that are used to deliver Mayoral priorities and evaluate Mayoral policies.
1.2 Improving air quality is a public health priority. Air pollution is estimated to contribute to thousands of premature deaths and chronic health conditions caused by long-term exposure. There is also strong scientific evidence of the acute health effects of short-term exposure to very high levels of pollution, like those experienced during an air pollution episode. It is essential that coordinated action is taken to reduce exposure, especially by the most vulnerable such as school children and the elderly, as well as to reduce health inequalities. There is also emerging evidence linking air pollution with an increased vulnerability to the most severe impacts of COVID-19.
1.3 The London Environment Strategy sets out the Mayor’s strategy for improving London’s air quality in detail as well as providing more information on the public health impacts of poor air quality.
2.1 This work programme will contribute to the London Environment Strategy objectives:
• Objective 4.1 – Support and empower London and its communities, particularly the most disadvantaged and those in priority locations, to reduce their exposure to poor air quality;
• Objective 4.2 – Achieve legal compliance with UK and EU limits as soon as possible, including by mobilising action from London boroughs, Government and other partners; and
• Objective 4.3 – Establish and achieve new, tighter air quality targets for a cleaner London by transitioning to a zero emission London by 2050, meeting World Health Organization health-based guidelines for air quality.
2.2 The table below sets out the main elements of the work programme, expected outputs, overall costs and expenditure related decisions for 2020/21.
2.3 It should be noted that this is not an exhaustive list of activity being undertaken by the air quality team in FY20/21. Other air quality programme activity, including the continuation of the Breathe London low-cost sensor network, to address emissions from buildings through the planning system, air quality alerts, and action to reduce exposure at schools and nurseries, are addressed through other Mayoral Decisions.
3.1 The GLA and other public authorities must have due regard to the need to eliminate unlawful discrimination, harassment and victimisation as well as to the need to advance equality of opportunity and foster good relations between people who share a protected characteristic and those who do not, under section 149 of the Equality Act 2010. This involves having due regard to the need to remove or minimise any disadvantage suffered by those who share a relevant protected characteristic; taking steps to meet the different needs of such people; and encouraging them to participate in public life or in any other activity where their participation is disproportionately low.
3.2 The protected characteristics and groups are: age, disability, gender reassignment, pregnancy and maternity, race, gender, religion or belief, sexual orientation and marriage/ civil partnership status. Compliance with the Equality Act may involve treating people with a protected characteristic more favourably than those without the characteristic. The duty must be exercised with an open mind and at the time a decision is taken in the exercise of the GLA’s functions. Conscientious regard must be had that is appropriate in all of the circumstances.
3.3 In January 2019 the GLA published analysis on exposure to air pollution which shows not only that there are huge health impacts of pollution but that these fall disproportionately on the most vulnerable, people living in the most deprived areas and Black, Asian and Minority Ethnic communities. This means that improving air quality is fundamentally about tackling social injustice and health inequalities.
3.4 The report considered pollution exposure in London and how exposure varies by age, indicators of relative deprivation and ethnic group. It also looks at total exposure (broken down by borough) and exposure at schools. Through this research, City Hall sought to understand inequalities in access to clean air in London and consider how this will be improved by planned air pollution controls.
3.5 The research showed on average that people living in the most deprived 10 per cent of London are exposed to concentrations of NO2 which are 25 per cent higher than the least deprived 10 per cent. However, exposure is not completely uniform and there are also some prosperous areas with very high levels of exposure, e.g. those living in the areas of Westminster City Council or the Royal Borough of Kensington and Chelsea.
3.6 In terms of ethnicity, research has found there are on average higher concentrations of NO2 in areas that have higher percentage of non-white ethnic groups, with a particularly skewed distribution for the Black/African/Caribbean/Black British population.
3.7 The programme of work set out in this MD will benefit all Londoners, but due to the unequal impacts of pollution on the most vulnerable Londoners there is likely to be a positive effect in tackling social and health inequality of this programme of activity. Having a better understanding of air pollution will also create new opportunities to take targeted and effective action.
Key risks and issues
4.1 Delays in undertaking any of the activities listed above (due to not having budgets or contracts in place) are likely to lead to an interruption in service provision that may have a negative reputational impact on the Mayor. Mitigation: The timelines and expected costs for all activities have been reviewed. In addition, risk registers will be drawn up for individual projects (where appropriate) to identify and monitor risks. High value / high risk projects will be monitored through existing corporate reporting and lower value / lower value risks will be monitored through the Environment Unit’s monitoring and review process.
Links to Mayoral strategies and priorities
4.2 In addition to the wider objectives listed at paragraph 2.1 the London Environment Strategy sets out the following commitments relating to schools and the London Atmospheric Emissions Inventory:
• Proposal 4.1.1.b The Mayor will aim to do more to protect London’s young and disadvantaged people by reducing their exposure to poor air quality, including at schools, nurseries, other educational establishments, care homes, and hospitals
Reducing the exposure of young people to pollution is a priority because younger children are among the most vulnerable to its health impacts. Eight and nine year-olds living in cities with high levels of fumes from diesel cars have up to ten per cent less lung capacity than normal. More must be done to reduce exposure at schools – or on the school commute - wherever possible, and also at nurseries, colleges, universities, and other educational establishments.
• Proposal 4.1.2.a The Mayor will produce and maintain the London Atmospheric Emissions Inventory (LAEI) to better understand pollution sources in London
To tackle air pollution effectively, it is necessary to understand its sources. The Mayor will produce and maintain the LAEI. This will help us understand the key emissions sources and how they contribute to poor air quality, both now and projected into the future. It will be used to calculate health impacts, exposure and health inequalities.
Impact assessments and consultations
4.3 A comprehensive Integrated Impact Assessment was undertaken to support the London Environment Strategy (LES) which covered air quality. The Integrated Impact Assessment (IIA) found that the GLA had considered aspects for improving London’s air quality based on four policy options. This was recognised in the LES IIA as the most effective approach for addressing human health impacts. The LES includes targets for some of the pollutants identified in the IIA recommendations.
Conflicts of interest
4.4 No conflicts of interest have been identified for any staff involved in the preparation of this form.
5.1 Mayoral approval is sought for the proposed expenditure of £260,000, supporting the delivery of the activities listed in section 2 of this decision. The cost of this programme of work will be funded from the Environment Programme budget for 2020-21, specifically via the Air Quality Programme budget (£240,000) and the Zero Carbon budget (£20,000), held within the Environment Unit. It should be noted that the consultancy services associated with this programme of activity will be procured under the Health & Safety Services and Environment Framework Agreement.
6.1 The Mayor has a wide range of specific legal functions (duties and powers) in connection with London’s air quality including:
• The achievement of limit values for air pollutants through policies, proposals and other measures contained in the LES, London Plan and MTS under the Greater London Authority (GLA) Act 1999, including achieving limit value compliance as soon as possible by the most effective means;
• Supervision of the London LAQM System under which the boroughs fulfil their local air quality management duties under the Environment Act 1995;
• Undertaking other specific measures and activities for the improvement of air quality which promotes the economic development, environmental and social improvement of Greater London under section 30 of the GLA Act 1999.
6.2 The proposed activities and associated expenditure to deliver the supporting activities for the air quality programme as set out in section 2 of this form are consistent with the Mayor’s functions.
Signed decision document
MD2714 Additional air quality programme activity 2020 21 - SIGNED