Cleaner Air for Scotland strategy: independent review

1. Executive Summary

1.1 The air that we breathe is fundamental to human life and the quality of our environment. The quality of life lived is placed at short and longer term risk by pollution. In Scotland today, whilst industrial, domestic, agricultural, natural and transboundary pollution are all parts of the mix, pollution from transport is the single biggest source of concern. Tackling all sources requires concerted and systemic action.

1.2 The Scottish Government engaged an independent chair and a multi-stakeholder steering group to review the progress made since the Cleaner Air for Scotland (CAFS) Strategy was produced in 2015, and to recommend next steps, with a particular focus on the actions necessary and practical in the next three to five years. At the outset it is clear that air pollution, climate change, carbon reduction, and mobility are strongly interconnected. Whilst this was evident to some extent in the original CAFS strategy, just four years on, the inter-woven agendas are even clearer and this review should lead to a highly visible statement regarding this inter-connectivity and the co-benefits associated between mobility choices, carbon emissions and air quality.

1.3 Our conclusion is that Scotland is generally performing quite well by EU and global comparison, with ambient atmospheric pollution concentration levels and regulated pollution emissions generally continuing to fall as a result of actions taken thus far. More remains to be done, not least as we understand better the impacts of pollution in the air we breathe on human health and the natural environment^[1]. Whilst human health has been and remains a strong justification for effort, the initial CAFS was focused on air quality, and particularly transport as the largest source of urban air quality issues.  CAFS must now move on more clearly to include other sources and the wider issues of air pollution (such as agriculture and domestic combustion) if we are to achieve the best air quality in Europe – with a quality of air that aims to protect and enhance health, wellbeing and the environment.

1.4 Emissions of some key pollutants in Scotland are EU compliant and some are already below World Health Organisation (WHO) guideline values, but there are both some general and some localised and periodic poor air quality areas which require urgent attention and action. There are still serious and particular challenges around transport constraints, nitrogen oxides, particulate and ammonia levels (from agriculture), and aspects of public behaviour and our choices, given options available and perceived, which need to be tackled.

1.5 CAFS appears to have had a positive impact but as an action programme has had an overly complex structure, is not yet wholly implemented or widely understood, has had insufficient authority and now needs more focus and energetic and aligned implementation. Effort is required to tackle governance and performance management: who does what, is held responsible for delivery and collaboration, and how to assess and report progress. Existing structures are overly complex and inadequately accountable and effective.

1.6 There is largely constructive engagement between stakeholders but more simplicity and authority are needed in order to ensure effective delivery in areas of overlapping or connected operational and performance management. Integration of policy and implementation is essential, nationally and locally. Local government has a key role to play and its monitoring, transport service provision, transport management, spatial and mobility planning and public health actions all need to fit more effectively with the strategic goals, and with the responsibilities and operational activities of Transport Scotland and SEPA. Visible and politically empowered as well as simpler partnership between the key players is needed to achieve this in policy and operational areas.

1.7 Further effective reduction in pollution will require concerted action across many sectors including national and local government, the private and public sector and by the public itself. All of these stakeholders have critical roles in further reducing preventable air pollution associated with transport, domestic and industrial sources, as well as agricultural activities (a source of both primary and secondary pollutants). Increased awareness and understanding of all the relevant interlinked issues is needed. With respect to transport pollution sources, interventions need to be coupled to encouraging people to change their habitual transport choices. Achieving such public behaviour change will require facilitation by more and better coordinated government action. There needs to be more focus on inter-related interventions including: improved transport infrastructure that encourages higher levels of active travel (walking, cycling); improved access to accessible, affordable and better quality public transport offering more attractive alternatives to private vehicles; and greater encouragement to adopt less polluting private personal transport (e.g. low and zero emission vehicles).

1.8 There needs to be more effective use and enhanced robustness of data and modelling, based on a) the need for and quality of continuous traffic monitoring data, and b) improved air pollution monitoring.

1.9 It is too early to comment on the success of Low Emission Zones (LEZs) but it is clear that they are a necessary and important commitment in delivering cleaner air and they need to be effectively implemented. Early implementation in 2019 in Glasgow is providing learning opportunities for the next three cities.

1.10 There are good and strong legal drivers of change in urban Scotland’s air quality as well as some emerging questions to answer on specific LEZ design and overall effectiveness and the nature of the restrictions applying, and their fit with Air Quality Management Areas (AQMAs), including the nature, sequencing, impact and consequences of interventions. AQMAs can and need to be operated more effectively and overall this, with effective LEZ implementation, will lead to necessary further improvements in air quality in the next three to five years.

1.11 There are clear challenges around the leadership and management of the transportcontext. There is a great deal to do around achieving modal shifts, faster uptake of cleaner engines, counteracting the continued increase in private car use, tackling congestion - reducing it as well as managing effects, greatly enhancing infrastructure and support for goods and active segment options as well as effectively supporting the differing and significant needs of rural, highland and island Scotland.

1.12 There is a clear need for more and better public information on pollution and transport options. We need to know better how to and then proceed promptly to tackle the cultural issues around modal shift and behavioural change. This has to include greatly enhancing understanding of effective, tolerable and affordable incentives and disincentives.

1.13 Further effort and effective delivery are needed on the design and increased coherence, amenity and utility of the public realm. Spatial planning and better place design can guide our way to a cleaner and healthier environment. Steps have to be taken to maximise safety and amenity, urging or requiring less polluting modes and increasing ease of movement and coherence and integration of mobility systems. The steps taken must minimise exposures, especially for sensitive receptors and vulnerable users. Existing and new developments must reflect what we know is necessary to tackle air pollution and enable more sustainable mobility.

1.14 Finally, actions are recommended on pollution and transport data and monitoring, on regulatory and planning activity generally and practical actions for our cities and towns, on the approach taken to public health as a continuing and serious driver for change, on transport provision and its fit with planning, on further controls and guidance on mobility and domestic heating and agricultural activities, on engagement issues, on research needs and on improvements to governance. These are introduced and summarised in each relevant section and in an overview in Section 2.