The following letter was sent to Wycombe MP Steve Baker, on behalf of Wycombe Labour for a Green New Deal.
Dear Mr. Baker, Re: Environment Bill 2019-20
I am writing to you on behalf of Wycombe Labour for a Green New Deal (‘WLGND’) to voice our strong concerns regarding two elements of the Environment Bill 2019-20 which is currently at the report stage in the House of Commons (the ‘Bill’).
Non-regression on environmental standards
As you may know, the UK’s existing environmental targets are predominantly enshrined in EU law. Following the UK’s exit from the EU on 31 January 2020, these targets have continued to have effect in UK law and will be retained under the EU (Withdrawal) Act 2018 (as amended) once the transition period is concluded.
Moving forward, the Bill allows for the Government specific powers to set new environmental targets. Part 1 of the Bill specifically states that the Government is under an obligation to set targets in the following four areas: air quality; water; biodiversity; and resource efficiency and waste reduction.
The Bill does not contain any targets for these areas but instead provides that the Government must set them through additional legislation by 31 October 2022. As currently drafted, three scenarios are therefore possible. The first is that the UK maintains a level playing field with current EU environmental targets, setting them at the same level. The second is that we set more ambitious targets than currently exist under EU law. As the Government has hailed the Bill as a “landmark” piece of legislation that will allow the UK to “lead the way in tackling global climate change” I would expect it to adopt this position. The final scenario, which is of greatest concern to WLGND, is that the UK sets targets which are weaker than currently exist under EU law.
Given the radical action that is needed to address the climate emergency and ensure that the UK meets its legally binding commitments under the Paris Agreement, we simply cannot allow for the weakening of environmental standards and therefore must eliminate the possibility of such an outcome. We strongly call for a non-regression clause for environmental standards to be added to the Bill before it passes into law and ask for you to publicly voice your concerns on this point.
Air quality target
Clause 2(1) of the Bill requires the Government to set an air quality target, specifically relating to an annual mean concentration level of fine particulate matter (PM2.5) in ambient air. Currently, EU Directive 2008/50/EC (the ‘Directive’) sets out legally binding targets on ambient air quality which the UK must follow. The Directive has set a target of a maximum annual mean concentration of 20μg/m3 for PM2.5 to be achieved by January 2020.
In the context of the Bill, a number of environmental groups and health charities, including The British Heart Foundation and ClientEarth, have called for the Government to adopt the air quality guidelines values for fine particulate matter set out by the World Health Organization (‘WHO’) instead of those set out in the Directive. The WHO guidelines set a more stringent target for PM2.5 than those in the Directive, i.e. an annual mean guideline limit of 10μg/m3.
The severity of the issue at hand is highlighted by an article published by the WHO on its website on 2 May 2018 which states that there is “a close, quantitative relationship between exposure to high concentrations of small particulates (PM10 and PM2.5) and increased mortality or morbidity, both daily and over time”. It goes on to say that if its guideline value targets were to be achieved “significant reductions in risks for acute and chronic health effects from air pollution can be expected”.
When assessing whether the UK could adopt these WHO standards, the Government published a paper on 23 July 2019, concluding that “we believe that, whilst challenging, it would be technically feasible to meet the WHO guideline level for PM2.5 across the UK in the future”.
It should be noted that many areas of the UK have achieved a level of PM2.5 below 10μg/m3 and Scotland has already shown that it is possible by passing into law the Air Quality Standards (Scotland) Regulations 2010 (as amended), which requires Scotland to meet WHO guideline values for PM2.5 of 10μg/m3.
In sum, the WHO say that by following their guidelines we can expect significant reductions in risks for acute and chronic health effects from air pollution. The Government has gone on record in saying that it is feasible for the UK to adopt these guidelines. Scotland have already enshrined these guidelines in law. I find no reason therefore why a provision should not be included in the Bill to ensure that the whole of the UK adopts air quality targets in line with the WHO guideline values.
The reason why I feel so strongly about this matter is that, as a resident of High Wycombe and a father of young children living in the town, I am deeply concerned about the well documented high levels of air pollution that exist in parts of Wycombe. Of particular concern is Marlow Hill and the surrounding areas as they contain a number of schools. We know that there is a clear correlation between air quality and mortality. Buckinghamshire Council reported that there were 234 deaths in 2016 directly attributable to air pollution and Public Health England have released figures showing an estimated 5.6 per cent (1 in 18) of deaths of people aged 30 or over in Buckinghamshire in 2018 were caused by air pollution.
As the Member of Parliament for a town with areas with high air pollution, you must take a leading and progressive stance towards demanding that the UK sets the gold standard when it comes which air quality targets are included in the Bill. I implore you to make your voice heard for your constituents by strongly calling for:
the addition of a robust non-regression clause for environmental standards in the Bill; and
the Bill to adopt an air quality target for fine particulate matter that are in line with those set out by the WHO.
I look forward to hearing from you about this.
Acting Coordinator, Wycombe Labour for a Green New Deal