MD2985 Air quality programme (2022-23 to 2024-25)

1.1.    The Air Quality team, within the Environment and Energy Unit, undertakes a range of activities including: supporting the exercise of the Mayor’s statutory air quality related functions; and supporting the implementation of the LES, the London Plan, the MTS and the London Recovery Board’s Green New Deal mission. The team also develops inventories of data, and undertakes monitoring used to deliver Mayoral priorities and evaluate Mayoral policies.
1.2.    Improving air quality is a public health priority. Analysis from Imperial College London shows that toxic air contributed to the premature deaths of more than 4,000 Londoners in 2019. There is also strong scientific evidence of the acute health effects of short-term exposure to very high levels of pollution, such as 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 schoolchildren and the elderly) and reduce health inequalities. London is currently in breach of legal limits for nitrogen dioxide (NO2), for which the Government’s Air Quality Action Plan (2017) requires measures to bring the city into compliance by or before 2025. Emerging evidence also links 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 Coroner published a Prevention of Future Deaths Report on 20 April 2021 setting out areas of concern to be considered by central government, the Mayor, the London Borough of Lewisham and other organisations. The Mayor has formally replied, setting out his commitment to implementing the recommendations related to the GLA and Transport for London (TfL); and supporting the implementation of other recommendations.  
1.4.    In September 2021, the WHO adopted new recommended guidelines for both PM2.5 and NO2. These targets are based on the best available health evidence, and the Mayor is achieving them as quickly as possible. 
1.5.    In March 2022 the government started consulting on adopting a new legal pollution limit for PM2.5, based on the WHO interim target of 10ug/m3, to be met by 2040. The final target will be adopted in October 2022. The Mayor has already set out his ambition of meeting the WHO interim target for PM2.5 by 2030.
1.6.    Tackling toxic air pollution is an integral component of the Mayor’s plans to meet net-zero by 2030 and to help tackle the climate emergency. The Mayor’s work to promote active travel and cleaner technologies is a crucial part of addressing both air quality and climate. There are also strong links with episodes of climate change and high pollution, as demonstrated by the high ozone-pollution incident coinciding with the heat wave on 18 and 19 July 2022.
1.7.    Further information on air quality, including why it is a public health priority and the Mayor’s strategy for addressing it, is provided in the LES.
 
 

2.1.    The GLA’s work to improve air quality supports the delivery of the London Recovery Board’s 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 LES 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 WHO health-based 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. 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
•    wider engagement with the medical and public health sectors.
2.4.    In October 2021, the Mayor expanded the ULEZ to inner London. To build on the success of the ULEZ in reducing air pollution, carbon emissions and traffic, the Mayor has asked TfL to consult on proposals for expanding the ULEZ London-wide in 2023; that consultation has concluded and TfL is in the process of preparing a report for the Mayor on public and stakeholder responses before a decision about whether proposed expansion should proceed. In addition, the Mayor has asked TfL to explore how future smart RUC policy could be developed in a way that supports air quality objectives. The programme outlined in this MD will provide resources to develop this policy area further.  
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 (2022-23, 2023-24 and 2024-25). 

3.1.    The GLA and other public authorities must have due regard to the need to eliminate unlawful discrimination, harassment and victimisation; and 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, sex, 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 showing not only that there are huge health impacts of pollution, but also 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 to consider how this will be improved by planned air pollution controls. 
3.5.    The research showed that, on average, the most deprived 10 per cent of the population in London are exposed to concentrations of NO2 which are 25 per cent higher than the least deprived 10 per cent 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.    However, new research published  in October 2021 showed that, thanks to the Mayor’s policies, the gap between the most and least deprived areas for exposure to NO2 has narrowed by up to 50 per cent. 
3.8.    The programme of work set out in this MD will benefit all Londoners; however, 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. Having a better understanding of air pollution will also create new opportunities to take targeted and effective action.
3.9.    While London’s poorest households are more likely to be affected by the negative air pollution impacts resulting from traffic and congestion, they are also much less likely to own a car than wealthier households. For instance, 13.8 per cent of London households are in the lowest household income band (household income less than £10,000 a year) but this income band only accounts for 5.5 per cent of car owning households. By targeting air pollution and congestion, the Mayor’s proposed RUC programme therefore stands to benefit those who suffer the most from these problems while contributing to them the least. 
 

Key risks and issues

Links to Mayoral strategies and priorities

4.1.    The actions proposed above will contribute to delivering the LES, and as part of the London Recovery Board’s Green New Deal mission, enabling 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.
4.2.    In addition to the wider objectives listed at paragraph 2.1 and 2.2, the LES sets out the following commitments relating to the projects outlined above:
•    Proposal 4.3.2.c: The Mayor, working with government, TfL, the London boroughs and industry, will aim for London’s entire transport system to be zero-emission by 2050, with work towards this including using regulatory and pricing incentives to support the transition to the usage of Ultra Low Emission Vehicles.
•    Proposal 4.2.4.a: The Mayor will use the 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.
•    Proposal 4.2.3.a: The Mayor will work with government, TfL, the London boroughs, the construction industry and other users of 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.
•    Proposal 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. 
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 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.
4.3.    The actions set out above will also contribute to delivering the objectives of the MTS. The following MTS policies are especially relevant:
•    Policy 6: The Mayor, through TfL and the boroughs, and working with stakeholders, will take action to reduce emissions – in particular diesel emissions – from vehicles on London’s streets, to improve air quality and support London reaching compliance with UK and EU legal limits as soon as possible.
•    Proposal 20: The Mayor, through TfL, will keep existing and planned RUC schemes (including the Congestion Charge, LEZ, ULEZ and Silvertown Tunnel schemes) under review to ensure they prove effective in furthering or delivering the policies and proposals of this strategy.
•    Proposal 21: The Mayor, through TfL, will investigate proposals for the next generation of RUC systems.
•    Proposal 26: The Mayor, through TfL and boroughs, will create a comprehensive alert system to inform Londoners about air-pollution episodes; and, where appropriate, will implement additional emergency measures to reduce or restrict vehicle use when forecast or actual periods of very high air pollution risk have the potential to cause immediate adverse health effects.
•    Proposal 27: The Mayor, through TfL and the boroughs, will tackle pollution from transport in local air quality hotspots and at sensitive locations (such as around schools), including through the MAQF and other funding.
•    Policy 7: The Mayor, through TfL and the boroughs, and working with stakeholders, will seek to make London’s transport network zero-emission by 2050, contributing towards the creation of a zero-carbon city, and also to deliver further improvements in air quality to help meet tighter air quality standards, including achieving a health-based target of 10µg/m 3 for PM2.5 by 2030.
•    Proposal 33: The Mayor, through TfL and the boroughs, will introduce regulatory and pricing incentives to support the transition to the usage of ultra-low emission vehicles in London.
•    Proposal 41: The Mayor, through TfL, will meet or exceed the emissions standards set out by the NRMM LEZ for TfL Road Network construction and maintenance activities; and urges Government to introduce new legislation to ensure that all emissions from NRMM can be effectively reduced.
4.4.    To ensure the MTS and the proposal to expand the ULEZ to cover all of Greater London are in alignment, it is necessary to revise the MTS, which currently only proposes an expansion of the ULEZ to inner London, to make reference to the further expansion now considered necessary to address the triple challenges of toxic air pollution, the climate emergency and traffic congestion. If this revision is confirmed after public consultation, then the programme of work set out in this MD will also support this updated MTS objective.

Impact assessments and consultations
4.5.    A comprehensive Integrated Impact Assessment (IIA) was undertaken to support the LES, which covered air quality. The 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. 
4.6.    A consultation on proposals to expand the ULEZ London-wide was launched on 20 May 2022 and closed on 29 July 2022. TfL is in the process of preparing a report for the Mayor on public and stakeholder responses before a decision about whether proposed expansion should proceed. Outputs from the consultation will be considered during the design of the scheme. A comprehensive impact assessment for the proposed expanded ULEZ will be undertaken.
4.7.    Evaluation of the impact of the air quality programme is delivered through the London Atmospheric Emissions Inventory, which estimates key pollutants across London and is updated every three years. Additionally, larger projects within the air quality programme, such as the ULEZ and Schools Air Quality Audit Programme, have their own evaluation, as outlined in section 2.5.   

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

5.1.    The Environment and Energy Unit seek permission for the expenditure of up to £3.717m over three FYs to deliver the air quality programme. 
5.2.    The breakdown of this expenditure across the various air quality projects and FYs can be seen below (the table summarises section 2.5, above).

5.3.    It is important to note that these projects contain a mixture of revenue and capital expenditure and as such will be recorded appropriately.
5.4.    £300,000 of the proposed total expenditure will be funded by 2021-22 underspends: £200,000 will be spent in 2022-23, and £100,000 in 2023-24. The remaining balance of £3,417,000 will be funded from the air quality budgets that reside within the Environment and Energy Unit.
5.5.    £1.440m relates to future years and is in line with the indicative budget allocations for 2023-24 and 2024-25. However, as these years’ budgets have not yet been approved, these allocations will be subject to change. If approved, this decision would constitute a pre-existing commitment against these budgets when the formal budget-setting process is undertaken. As such, all contracts will include break clauses to mitigate against the risk should these funds become unavailable.
 

6.1.    The proposed activities and associated expenditure to support the air quality programme set out in this decision fall within the powers in section 30 of the GLA Act 1999, on the basis that they further the promotion of the improvement of London’s environment and/or they facilitate, or are conducive or incidental to the exercise of those powers under section 34 of that Act. They also support the provisions of the Mayor’s LES and in particular those policies, proposals and other provisions dealing with air quality pursuant to the Mayor’s duties under section 362 of the Act in relation to the LES. 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 the GLA processes; and appropriate legal advice and subject should be sought at the appropriate time to confirm they are within legal powers and grant or procurement obligations.