Cleaner Air for Scotland 2 - a consultation on a draft new air quality strategy for Scotland

CIWM Scotland suggests the actions listed can be written for any consultation of this type. The package needs to be bolstered by a clear time frame (for actions rather than the term of the plan) and an indication of where Scotland wishes to position itself by, for example, stating it wishes to see an X% reduction in attributable deaths by Y.

Where indoor pollution is concerned this is liable to become more significant as housing becomes more hermetically sealed for better energy efficiency. Some indication of the direction of policy, with respect to the main indoor pollutants, would have been welcomed.

Indoor pollution in commercial and industrial settings would also benefit from investigation (both epidemiological/health surveillance and measurement of key pollutants in-situ) from the restaurant kitchen to large scale industrial plant.

As noted in the response to Question 1 above. The magnitude of action and timeframe in which they are carried out will determine whether the very general actions listed in this chapter have any lasting/significant effect.

CIWM Scotland believes it is not viewed within local government as a priority (more generally environmental health is largely viewed as irrelevant in local government, by the public and indeed by the Scottish Government). The profession itself must bear some responsibility for this view, given its long-standing attachment to, for example, food safety rather than the more challenging discipline of environment and health.

The difficulty in gaining political buy-in is simple where interventions, which may not reveal benefit either at all or for years carries little political merit given the electoral cycle. And in any event local government in Scotland is dominated by the twin forces of education and social work as revenue spends reveal leaving little room for other services.

Finally, knowledge or a sufficiency of “interest” from the most senior echelon of local government on these matters is difficult to engender and maintain given this strata is now frequently inhabited by policy/administrators rather than individuals with technical or field knowledge/expertise of operational matters.

Given the failure of initiatives such as Single Outcome Agreements and Local Outcome Improvement Plans the only way in which to effect change is to require local government and others to act by legislative means. Although giving Environmental Health, which is itself a difficult term to define in common parlance, a return to its more traditional form of “Public Health” may help raise the profile both of the service and of the impact of air pollution on community health and wellbeing.

As previously stated, the actions are laudable. But what actions will government take where “working with” or where deficiencies in “skill” etc are identified which prevent positive actions from being taken within the required timeframe?

Unfortunately, CIWM Scotland sees one of the greatest barriers to wider community involvement in this issue (and many others) is the use of impermeable jargon to describe matters which most people would otherwise instantly comprehend. The re-invention of “place” and its exposition here and wider adoption throughout central and local government, is a classic example of how important issues, which demand public access, are obscured and as such remain the preserve of the few.

CIWM Scotland sees place-based approaches as important in delivering improvements in air quality but asks whether those involved in this approach would actually have the levers to influence existing air quality issues. Where they do not, then there must be a legislative tool which enables the relevant statutory authority to take action to drive levels of the pollutant(s) of concern to a minimum.

CIWM Scotland seeks clarification on where the expertise within local government planning services lie, to drive this notion through.

Basing decisions on the best data available is absolutely critical. However, the need to make decisions and act on air pollution should not be delayed on the basis that “we need more data”. There are actions that can be taken (based on current knowledge and from experience from around the world) which will improve air quality, and these should be carried out without delay.

No, this is not an area of expertise for CIWM Scotland.

It is to be hoped that the messaging enables everyone to understand the main issues and where air pollution fits in to life in urban and rural Scotland and is not weighted by the managerialism jargon contained in this consultation (particularly evident in Paragraph 85).

Whilst going beyond compliance is to be applauded, it is likely to be those operators that are already pushing the boundaries who wish to do so. As such, SEPA is pushing at an open door. However, SEPA is a regulator and should focus on those operators who either operate out with their regulatory framework (this has been an on-going complaint by the resources and waste sector for many years) or who whilst operating, within it, do so with less than satisfactory outcomes.

One other issue is raised by the idea of “beyond compliance”. If the beyond compliance is a defined standard for a sector and it can be justified on sustainability grounds, then does this not indicate that the existing standard is deficient, and the bar needs to be raised for the entire sector, in keeping with the BATs aspiration?

CIWM Scotland believes that what may or may not be the legal designation of the feedstock, process or plant is irrelevant. It is the emissions and/or impacts which are relevant and which should be the subject of statutory controls.

CIWM Scotland strongly suggests the CCA should be revised - rather than as suggested - consideration being given to its revision.
Any enforcement required on fuels should be carried out (for the sake of consistency) by Environmental Health not Trading Standards; and strategically whilst more efficient stoves etc are being brought on to the market this must surely be a transitional issue given the momentum towards sealed homes with heat pump derived energy and the fact that many are installed for aesthetic reasons rather than need. As such the case and intent to “ban” should be forcefully made.

The impact on the fuel poor is the most important and needs to be addressed by intervention – but not just on any requirements to change stove/fire and or fuel. The opportunity should be taken to improve the entire stock to ensure that an open fire/stove is not required and meets the overall strategic objectives of the government.

CIWM Scotland has no comment to make here.

CIWM Scotland is aware of a code of practice https://www.gov.scot/publications/prevention-environmental-pollution-agricultural-activity-guidance/ and seeks clarification on its awareness or effectiveness given that the consultation suggests developing a voluntary code.

Given the fact that ammonia levels need to be controlled, the government should legislate to do so rather than rely on a voluntary code. A best practice code or approved code of practice could be used to help implement legislation in the most appropriate way.

This is an unnecessary and time-wasting step – see the response to question 14.

Reductions in air pollution from industry has been in part as a result of industry closure or relocation to the developing world. Given the quantity of consumer items and food brought into Scotland, will the inventory include contributions from our exporting of manufacturing and food production? If not, then CIWM Scotland believes it should.

The critical issue of connecting one journey with another is absent from the narrative. A significant blockage to using public transport is the fact that ferries don’t meet buses, trains don’t meet buses and so on. In some cases, this could be remedied by careful timetabling rather than further investment, thereby achieving a quick win.

The narrative quite rightly states that local government cannot control issues beyond its boundary. But then makes the leap to ‘therefore legislation cannot be brought to bear’. This is incorrect. Legislation could be brought to bear on those issues which each local authority can affect. Guidance could then augment the legislation to assist in those areas out with legislative control.

A single Cabinet Secretary (presumably the Chair of the Group) should be explicitly named as the responsible and accountable individual.

CIWM Scotland has no additional comment to make.

No

Don't Know

No reason why it should if supporting actions are taken at the same time. In fact, there is an opportunity to enhance the lifestyle of low-income households that are impacted.

No

Don't know

Don't know

Probably

Satisfactory

It is a high-level document redolent with statements of “working with” various bodies. The effects will therefore be determined, to a large extent, on the success or otherwise of this voluntary approach. As stated throughout this response where the government requires clear action, it should be legislated for.

CIWM Scotland has no comment to make.