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

These "actions" are research that should have started in 2015. The 2015 report called for effective policies to reduce harmful exposure by 2020. The 2019 review stated "it is clear from the evidence presented in the CAFS review that more needs to be done if these co-benefits are to be fully realised." and "finding consistent significant associations of pollution (particulates and nitrogen oxides) with respiratory disease outcomes” which “constitutes good evidence that air pollution, even at the low concentrations found in much of Scotland, is linked to excess ill health that should be preventable by reducing pollution further".
Immediate steps should be taken to improve health: particularly in reducing domestic exposure. I agree that some of these steps are laid out in the Placemaking and Transport sections: but this level of research should have started 5 years ago, now is too late, but better than nothing.

These are not "actions"
The commitment of central government to these perfectly reasonable "50 recommendations for maximising co-benefits" is far too vague. To properly implement these, there needs to be primary legislation to allow councils to fully control development planning, a vast increase (the adjective "significant" occurs frequently, but this means different things to different people) in investment in housing, infrastructure, public transport, and regulation of farming and forestry. The 50 principles contain a lot of "need for careful thought", or "it could be argued": not an encouraging basis for action. This is not enough. Equally, although it may be true that "most significant emissions from industry are controlled by regulatory legislation in Scotland" there is need for greater statutory powers to limit emissions. Finally, some of the recommendations are misleading and have serious consequences: "generation of energy from residual waste by incineration can help Scotland meet its renewable energy and electricity targets without adversely affecting GHG and air pollutant emissions." is misleading: residual waste incineration releases substantial quantities of GHG, and this is set to increase substantially. The four specific environmental principles: precautionary, polluter pays, prevention, and rectification at source should be applied by Scottish government policy.

Inadequate planning control. Local authorities cannot control the use of land and investment adequately to take effective steps to improve air quality. There should be a primary duty of care to improve air quality: any activity that fails to improve quality should be legally indefensible. Any proposed development should be subject to more rigorous inspection of secondary effects: for example a housing development should provide convincing measures to ensure zero impact on air quality. This requires better planning and the absolute right to object to any decisions that degrade environmental standards. SEPA should have sufficient resources to investigate adequately all proposals and assist local authorities. Appeals by developers should not be allowed, unless counter-appeal was guaranteed
The four specific environmental principles in the Treaty on the Functioning of the European Union (TFEU) must have legal force over the development of policy and law in Scotland. (CAFS 2015)

Again, fine words with no teeth. Place standards should be explicit criteria that SPP can enforce. Local authorities need more qualified staff to assess planning proposals to ensure that these meet Place standards. NPF4 should impose the requirements for place planning on local authorities and ensure that local authorities have the resources necessary to meet these standards

Improved statutory regulations to ensure regulation of motor traffic and domestic dwelling standards.
the 2015 CAFS states "Although there has been some progress in this regard, it is clear from the evidence presented in the CAFS review that more needs to be done if these co-benefits are to be fully realised"
We are now in 2020: what is stopping this being done already?

Satnav data should also be used to control traffic to limit pollution.
The data collected should be made available to inspection by the public.
Local authority "guidance" to commission traffic data collection is not enough: this should be a mandatory requirement.

Provide low cost robust personal level household monitoring and modify local legislation to allow such measurements to have legal standing in accommodation standard enforcement. This also applies to noise.

The statement "we will" contains the words "taking into account": this is so weak as to be useless. Para 85 contains a valuable and comprehensive list: it should be accepted, so the wording should be "we shall use these suggestions".

Legislation is required and should include the polluter pays and prevention principles: this particuarly should apply to NEE

Introduce a legal limit for the continued use of existing non-compliant installations.

Some householders may find it difficult to afford heating: grants should be considered if hardship can be shown.

Voluntary codes are ineffective.

Apply the polluter pays principle and require the owners to pay for ammonia release.
Muirburn should be made illegal: it's only used to support grouse shooting. It causes pollution, erosion and flooding. It releases carbo dioxide.

If a voluntary code is to be tried, then clear time limits should be defined: shape up or else. A voluntary approach is only sugaring the pill, and wasting time and allowing more damage to be done.

In favour of all these suggestions, but some are weak. and do not provide adequate material support. It's silly to encompass all these elements of transport in a single question.
One aspect has been completely ignored: housing should be close to the workplace. Allowing local authorities to permit housing to be developed miles away from the workplace in absurd: housing development and workplace provision should be proximate. No mention of the 15 minute to work concept.
Councils should be given greater powers to refuse "distant" housing developments, and far great powers to invest in suitable house developments within towns and cities.
Councils should NEVER permit building developments with car parking spaces for workers!
Out of town retail parks should be discouraged.
Modern car controls, based on GPS, can control traffic speeds and should be introduced to limit emissions and improve road safety.
There is no mention of local authority difficulties in altering road layouts to favour walking and cycling: current legislation means that introducing permanent changes is painfully slow. If roads are congested with cars, make them more favour walking and cycling. The provisions suggested in CAFS 2015 are more than those suggested in 2020. Infrastructure for walking and cycling needs substantial improvement, not just "behavioural change": people righlty are afraid to cycle at the moment: better provision is vital.

Regular targets, legally enforceable, would be an excellent means of ensuring that government meant business. Why should citizens be forced to take government to court over matters of public safety?
Apply the principles of polluter pays, and prevention.

Poorly paid people who travel at inconvenient times are more likely to need car transport. Particularly in the service industries, they may not be able to afford accommodation close to their work. Affordable housing close to work should be encouraged. More effective planning legislation and better financial provision for affordable housing is needed.

Yes. Agricultural workers are poorly paid, poorly housed, and live away from power supplies. This must be taken into accvount perhaps in the rates charged for such housing.

See the comments in (21)

Current legislation for planning development favours the wrong houses in the wrong places. Councils need much more power to refuse inappropriate development.

Complete whitewash relating to the incineration of waste: this is planned to increase substanbtially and does NOT at present produce useful local heating, but does generate a lot of CO2

Provisional improvement only because very little concrete action.