AEF has submitted a response to the Government’s consultation on its national plan for tackling nitrogen dioxide. The plan was drawn up in response to a court order that ruled that the previous strategy relied on over-optimistic modelling and failed to demonstrate that nitrogen dioxide limits would be met as quickly as possible – the legal requirement. The Government had tried to delay publication of the new plan until after the election, but the court ruled that this issue was too important to be subject to further delays and it was published on 5th May.
The revised plan drew widespread criticism however. The Mayor of London described it as “toothless and woefully inadequate” and Client Earth, the legal campaigning organisation that brought the successful judicial review, announced on 31st May that it would be returning to court to argue that the updated plan is still deficient.
AEF commented on the day that among the plan’s many weaknesses is the fact it makes no reference to the planned opening of a third runway in the mid-2020s, despite this being predicted to exacerbate NO2 pollution, and despite the plan indicating – on the basis of updated modelling – that London may not be compliant with air quality limits even by 2030. Our consultation response builds on these points. It sets out why Heathrow presents a particular problem in terms of air pollution and why, in this context, the air quality plan presented for consultation fails to address the problem of nitrogen dioxide as quickly as possible.
We highlight four key concerns about the draft plan: