Anthony Rae for FOE 3rd December 2015 Our previous article – Take action against air pollution now – here and nationally! 1st November – dealt with the consultation about the government’s proposed air quality strategy. And now there’s a second consultation, this time produced by the West Yorkshire authorities, and with a closing date of Friday 11th December. You can download the consultation document – it’s called the West Yorkshire Low Emissions Strategy or WYLES – and respond online here.

Calderdale Friends of the Earth thought there were fundamental weaknesses with the government strategy produced by DEFRA, and unfortunately that’s the same now with this West Yorkshire strategy. Our principal criticisms are:

– Whilst the seriousness of the transport-driven air pollution problem in West Yorkshire is properly identified, the West Yorkshire document (WYLES) does not comment about the fact that its analysis of the extent of air pollution in West Yorkshire and that of the national government are substantially different. The government seems to be confident of almost complete compliance with EU air quality directives by 2020, whereas WYLES says that ‘concentrations of nitrogen dioxide will not fall below the limit values in some parts of West Yorkshire until after 2030. ‘

– the most important weakness of WYLES is that it is not focused on the question of whether it will secure EU compliance or not? Since the strategy does not examine, model or discuss whether its proposals will secure EU compliance, it is not ‘fit for purpose’.

– Its objectives are too weak. There should be a specific objective relating to ‘securing compliance with EU directives’, and another related to fixing the problems within West Yorkshire is 28 declared Air Quality Management Areas (AQMAs).

– WYLES is missing an entire end section focused on the probability of its being implemented, covering: an action programme and timetable; a modelled reducing emissions trajectory; an assessment of obstacles to implementation; and of the resources required. With a legally enforceable compliance deadline no more than five years away, after which the West Yorkshire authorities could be found to be in contravention of the EU directives and facing major financial penalties, such a focus on implementation is simply essential, but also to prevent at least 5000 premature deaths that will otherwise occur before the 2020 deadline.

– WYLES does not contain proper analysis of the levels of air in the 28 West Yorkshire AQMAs, and what will need to be undertaken in those specific locations in order to secure compliance. This is a second fundamental shortfall which will need to be made good in a revised strategy.

– The DEFRA strategy proposes that ‘clean air zones’ may well need to be established in ‘the seven zones in England that are projected to exceed the limit values in 2020’ which may require ‘access restrictions for certain types of vehicle’ to be introduced. This includes Leeds. But WYLES is unclear as to whether it supports the ‘clean air zone’ approach suggested by DEFRA and their own research.

Conclusions: The WYLES strategy at present has major failings which will require it to be comprehensively revised. The test for this revision will be: does it demonstrate, with evidence and modelling, that all areas in West Yorkshire, and particularly its 28 AQMAs, will be compliant with EU air quality directives by no later than 2020, with annual delivery milestones, key implementation measures and the necessary resources budget?