MD2813 Air quality programme – 2021/22 to 2022/23

1.1. The air quality team within the GLA’s Environment Unit is required to undertake a range of activities as part of delivering on statutory functions as well as supporting the implementation of the statutory London Environment Strategy, the London Plan, the Mayor’s Transport Strategy and the London Recovery Green New Deal mission. The team also develop 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 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. London is currently in breach of legal limits for NO2, for which the Government’s Air Quality Action Plan (2017) requires measures to bring the city into compliance by or before 2025. There is also emerging evidence linking air pollution with an increased vulnerability to the most severe impacts of COVID-19.

1.3. On 16 December 2020 the Assistant Coroner for Inner South London (“the Coroner”) concluded that exposure to excessive air pollution contributed to the death of nine-year-old Ella Adoo-Kissi-Debrah in 2013. The medical cause of her death was given as acute respiratory failure, severe asthma and air pollution exposure. The landmark ruling means that for the first time ever in the UK, air pollution exposure has been listed as a cause of death in an inquest. Key themes explored during the inquest included:

• health effects of different air pollutants and their sources;
• effectiveness of EU and national standards in addressing air pollution from vehicle emissions, including issues such as Dieselgate;
• details and effectiveness of local and national policies in addressing air pollution; and
• ensuring public and health professional awareness of the health effects of air pollution and individual ways to mitigate them.

1.4. The Coroner’s conclusion and recent analysis from Imperial College London show that toxic air contributed to the premature deaths of more than 4,000 Londoners in 2019. This suggests that all levels of government (central, regional and borough) must extend and accelerate action to ensure all Londoners can breathe clean air. The Coroner also published a Prevention of Future Deaths Report on 20 April 2021 setting out areas of concern for central Government, the Mayor, the London Borough of Lewisham and other organisations to consider. The GLA is required to provide a response to the relevant areas of concern outlined in the report by 17 June 2021.

1.5. Further information on air quality, why it is a public health priority and the Mayor’s strategy for addressing it are set out in detail in the London Environment Strategy.

1.6. The expansion of the Ultra Low Emission Zone will also play a critical role in achieving the Mayor’s air quality objectives and is covered in a separate Mayoral Decision (MD2305).

2.1. The GLA’s work to improve air quality supports the delivery of the London Recovery Green New Deal mission, which will help London to recover by sustaining economic growth, supporting jobs and creating new ones. The Green New Deal Mission will support London to become a zero-carbon, zero pollution city by 2030 and a zero-waste city by 2050. It will help make London better adapted to climate change and healthier for its citizens.

2.2. The air quality work programme will also 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.
• 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-cased guidelines for air quality.

2.3. In addition, the programme will address the main themes explored during the Ella Adoo-Kissi-Debrah inquest. These actions will be supported by the overall air quality budget. All of the main elements of the work programme described below will play an important role in addressing air pollution and preventing future deaths of this nature. An outline of the key work areas raised during the inquest were:

• the importance of continued efforts to reduce air pollution in London;
• the provision of effective training, resources and support to local authorities charged with addressing local air pollution levels;
• a need to address traffic and pollution on busy trunk roads;
• improved provision of public information about the dangers of air pollution; and
• wider engagement with the medical and public health sectors.

2.4. A summary of themes raised during the inquest and proposed actions is included in Appendix A.

2.5. The table below sets out the main elements of the work programme, expected outputs, overall costs and expenditure related decisions broken down by year (2021/22 and 2022/23).

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 that not only are there huge health impacts of pollution but that these fall disproportionately on the most vulnerable, more deprived people 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, the GLA 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 the most deprived 10th of the population are exposed to concentrations of NO2 which are 25 per cent higher than the least deprived 10th of the population. It is important to note that hidden within this are pockets of extreme wealth with very high levels of exposure, e.g. those living in parts of Westminster 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 percentages of non-white ethnic groups, with a particularly skewed distribution for the Black/African/Caribbean/Black British population. A greater proportion of mixed, black and other ethnic groups are exposed to levels of pollution that exceed the NO2 limit value than their proportion of the total 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.

a) 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. 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 team’s monitoring and review process.

4.2. Staff resources have been identified within the air quality team to manage and take forward the projects set out above. These will be monitored and reviewed by the Environment Team’s management team.

b) Links to Mayoral strategies and priorities

4.3. The actions proposed above will contribute to delivering the London Environment Strategy goal for London to have the best air quality of any major world city by 2050, going beyond the legal requirements to protect human health and minimise inequalities, and will form part of the London Recovery Board’s Green New Deal mission.

4.4. In addition to the wider objectives listed at paragraph 2.1 and 2.2 the London Environment Strategy sets out the following commitments relating to the projects outlined above:

• 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.
• Proposal 4.2.4.a The Mayor will use the London Local Air Quality Management(LLAQM) framework to assist boroughs and require them to exercise their statutory duties to improve air quality in accordance with that framework, and will exercise statutory powers as required: The Mayor will help boroughs in carrying out the exercise of their statutory duties to improve air quality. Through the reformed LLAQM framework there are clearer requirements for the boroughs. The Mayor will continue to provide coordination, tools, templates, support and funding. The Mayor will also improve information sharing and promote best practice by publishing an annual report on borough achievements, and provide advice, information and workshops.
• Proposal 4.2.3.a The Mayor will work with government, TfL, the London boroughs, the construction industry and other users of Non-Road Mobile Machinery (NRMM), such as event organisers, to prevent or reduce NRMM emissions
• 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.
• 4.1.1a The Mayor will provide better information about air quality, especially during high and very high pollution episodes, and use emergency measures where appropriate: Timely air pollution information gives disadvantaged people a chance to act to protect themselves, for example by reducing their exposure, or simply by carrying their medication.

4.5. The Mayor is committed to ensuring that London’s recovery from the pandemic is a green and fair recovery and his air quality programme is a key part of that vision. The Green New Deal recovery mission, agreed by the London Recovery Board, aims to tackle the climate and ecological emergencies and improve air quality by doubling the size of London’s green economy by 2030 to accelerate job creation for all.

Impact assessments and consultations

4.6. 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

4.7. There are no known conflicts of interest to note for any of those involved in the drafting or clearance of this decision.

5.1. Mayoral approval is sought for the proposed activities detailed above and the associated expenditure of £631,500 to deliver the supporting activities for the air quality programme as set out in section 2 of this report. The spend is to be funded from the Environment Programme budget with £316,500 to be funded from the 2021-22 budget and £315,000 from the 2022-23 budget. Funding in future years will be subject to the GLA’s annual budget setting process.

6.1. The proposed activities and associated expenditure to support the air quality programme set out in this Form fall within the power in section 30 of the GLA Act 1999 on the basis that they further the promotion of the improvement of London’s environment and facilitate or are conducive or incidental to the exercise of that statutory function under section 34 of the GLA Act. They also support the provisions of the Mayor’s London Environment Strategy and in particular those policies, proposals and other provisions dealing with air quality and the Mayor’s duties under section 362 of the Act relating to the London Environment Strategy.

6.2. The awarding of grants and/or expenditure in the procurement of services and supplies in implementing the air quality programme should be carried out in accordance with applicable GLA policy and processes and appropriate legal advice should be sought at the appropriate time to confirm they are within legal powers and consistent with grant or procurement obligations.

Appendix A: Inquest issues raised