Cleaner Air for Scotland 2: consultation

Overview

CAFS 2 is shaped around 10 general themes, which largely reflect the high level recommendations arising from the CAFS review.

1.  Health - A Precautionary Approach.  The current weight of evidence justifies adopting a precautionary public health approach to air pollution reduction.  As a minimum, compliance is required with domestic and international air quality standards but, where practicable and feasible, there should be continued efforts to reduce preventable air pollution still further beyond these limits.

2.  Integrated Policy.  Strategies, policies and plans being developed and implemented by central government for placemaking, climate change mitigation and adaptation, and related polices such as noise reduction, should be closely co-ordinated and aligned with those for air quality in order to maximise co-benefits.  Local government, which is largely responsible for implementing the LAQM system, besides its planning, transport delivery, public health and regulatory roles, also has a key role to play.

3.  Placemaking.  National Planning Framework 4 (NPF4) will transform how Scotland’s planning system shapes our places and society over the years and decades to come.  It will provide an important context within which further air quality improvements will be delivered, supported by the Place Standard tool and the Place Principle, besides having regard to any national strategy for the improvement of air quality prepared by Scottish Ministers.

4.  Data.  There are gaps in both quality and coverage of air quality, transport and human health data in Scotland.  Addressing these gaps will help to improve public awareness and engagement, modelling, reporting and ultimately, policy implementation.  A greater focus on collecting traffic data in a way that supports air pollutant emission understanding will have similar benefits.  Health data also require careful consideration so that Scotland-specific interpretations, plans and interventions are strengthened.  Wider utilisation of low cost sensor technology, including citizen science initiatives, has a role to play too.

5.  Public Engagement and Behaviour Change.  More research is needed to provide clear evidence on levels of knowledge, attitudes, and concern related to air pollution, as well as on willingness to change behaviours which contribute toward air pollution.  Many of the key drivers and incentives/disincentives will be closely related to those associated with climate change, but at the same time there will be differences in focus and approach.  Development of complementary and co-ordinated public engagement strategies is therefore essential to deliver the required behavioural change outcomes and to avoid confusing or conflicting messages.  

6.  Industrial Emissions Regulation.  Following the UK exit from the European Union (EU), the Scottish Government is committed to ensuring that EU environmental principles continue to sit at the heart of environmental policy and law in Scotland.  In relation to current regulation, retained EU law will continue to apply, as will domestic regulations made to transpose EU Directives.  Four specific environmental principles – precautionary principle, polluter pays principle, prevention principle and rectification at source principle – are enshrined in the Treaty on the Functioning of the European Union (TFEU).  The Scottish Government intends to ensure that these principles continue to have legal force over the development of policy and law in Scotland. The contribution of non-road mobile machinery (NRMM) including transportation refrigeration units and construction plant to air pollution in Scotland also requires attention.

7.  Tackling Non Transport Emissions Sources.  Domestic (household) burning and agriculture are two sectors not addressed in detail in the original CAFS, but which make an important contribution to air pollution in Scotland.  Consideration is needed of performance and standards for domestic fires, stoves and fuels, and local authority powers to permit and control these, and a refreshed approach to good agricultural practice and aiming for increased nitrogen use efficiency of farming. Together, these have the potential to deliver significant improvements in air quality beyond current regulatory and management approaches. 

8.  Transport.  Increasing modal shift to active travel and public transport is key to further reductions in transport emissions.  This will mean, amongst other objectives, providing a transport system that facilitates active travel choices, better public transport provision, embracing new technologies, and constraints upon private vehicle use, especially in urban centres where pollution and congestion are most acute.  The new National Transport Strategy (NTS2), published in February 2020, sets out an ambitious and compelling vision for Scotland’s transport system for the next 20 years.  The four NTS2 priorities – reducing inequalities, taking climate action, helping deliver inclusive economic growth and improving our health and wellbeing – will underpin our efforts to deliver additional air quality improvements in CAFS 2.

9.  Governance, Accountability and Delivery.  Simple and effective governance arrangements and a focus on practical joined up delivery are imperative for CAFS 2.  We need to be clear on who is doing what, who is leading, who is supporting and who is ultimately responsible if CAFS 2 is to be delivered as a coherent, integrated and successful strategy.

10.  Further Progress Review.  As with CAFS, the intention is that CAFS 2 will have a five year lifespan.  A further review of progress on air quality improvements will commence during 2024 in order to track progress on delivering the actions in the new strategy, besides allowing Scotland to keep abreast of developments in the evidence base, technological advances and societal attitudes, so that remaining challenges and actions can be identified.