As the Local Plan/Green Belt debacle continues to be played out in the local media. The latest instalment being the local Labour group advertisement feature wrapped around the Wirral Globe which has been deconstructed on Defend Wirral’s Green Spaces Facebook page.
However today we bring you ‘The Prof’s learned exploration as to why the issues surrounding the Local Plan and the Green Belt are so important.
Yes, it is lengthy but we think you owe it to you and you family to take some time out this Bank Holiday weekend to become better informed about the potential life threatening consequences of not protecting Wirral’s Green Belt.
COMMENTS ON THE WIRRAl LOCAL PLAN SUSTAINABILTY APPRAISAL AIR QUALITY & HEALTH IMPACTS : DEATH BY PLANNING?
The scoping sustainability appraisal document on air quality and health gives a very limited, misleading and complacent assessment of issues in these areas which should in practice a have a significant impact on consideration of development options under the local plan.
A detailed analysis of the health impact of house building on the Green Belt parcels identified for potential release in the Local Plan adjacent to the M53 is in preparation. Specifically it considers the GB parcels east (downwind) of the M53 from Storeton, south past Junction 4, to Raby Mere and those GB parcels near Junction 5 at Eastham. The serious negative effects of air pollution on any future residents and the current residents downwind of the M53 are examined. This note is to give the council early warning, for the record, of the negative health implications of building in these areas and an outline of the formal objections which will therefore be raised if these parcels are proposed for release.
2. Scoping Report Context
The Scoping Report published by Wirral Council discusses ‘Air Quality’ in a very limited way. It does however note the NPPF imperatives such as
‘New and existing developments should be prevented from contributing to [residents], being put at unacceptable risk from, or being adversely affected by, unacceptable levels of air pollution.’
Contrary to the complacent scoping report we will demonstrate from international and national studies and by analysing Wirral geographical health data, that building in the GB parcels identified will put residents at significant risk and cause real, unacceptable health deficits including reduced life expectancy. As traffic increases in coming years, the health impacts of pollutants such as PMs on Wirral will definitely increase, even if the unrealistic government aspirations for replacing diesel vehicles are met.
The scoping report mentions only one pollutant in detail, NO2, nitrogen dioxide. NO2 is allegedly monitored at 31 passive sites and levels are supposedly falling ‘gradually’. Particulate matter, now recognised as extremely dangerous, is mentioned in passing. It is monitored at only one automatic site on Wirral at Tranmere. International air quality standards, which are continually tightening, and the views, for example of the World Health Organisation on health damage, are not explored. We will do so below. In fact the serious health impacts of air pollution on Wirral are not discussed in the ‘Air Quality’ section nor the ‘Health’ section of the scoping report. Given that air pollution is now considered to be ‘the greatest environmental risk to public health’ in the UK (1, 2) this is concerning. We will look at evidence from the literature causally linking PM and NO2 levels to premature mortality, lower life expectancy, COPD, lung cancer, asthma, diabetes, dementia, stroke, heart attack, development deficits in children’s lungs and low birth weight. We will also present in summary, direct evidence of significant correlations between these diseases and PM levels across Wirral which are fully consistent with that extensive literature.
The 16 Green Belt Parcels Proposed for Release in the Local Plan Adjacent to the M53 at Storeton-Clatterbridge-Poulton Lancelyn
The 11 Green Belt Parcels Adjacent to the M53 between Raby Mere and Eastham
3. National & International Health Impact Evidence
A good starting source for reviewing the evidence is reference 3: the joint report on Air Quality from DEFRA – Public Health England – Local Government Association in 2017. The report concentrates on PMs and NO2. PM10 includes all particles smaller in diameter than 10 microns. PM2.5 includes all particles smaller than 2.5 microns. PM10 therefore includes the PM2.5 and PM0.1 fractions. Nationally the ratio of PM2.5 to PM10 released into the air is 0.75. Concentration ratios vary depending on local conditions. The smaller particles are considered most dangerous since they can be inhaled deep into the lungs and even pass directly into the blood stream. PMs are known to be carriers for carcinogenic materials and are now classed as carcinogenic agents.
The literature on health impacts of air pollution is now vast and still accelerating in scope. The health implications for the UK are well described in ‘Health Matters: air pollution’ published in 2018, by Public Health England (4). Locally we also have an excellent report by the Wirral Intelligence Service (1). WBC cannot claim that there is a dearth of information on these matters. The PHE report concludes that
‘long term exposure to man-made air pollution in the UK has an annual effect equivalent to 28,000 to 36,000 deaths. Over 18 years a 1 microgram / m cubed reduction in fine PM air pollution could prevent 50,900 cases of CHD; 16,500 strokes; 9,300 cases of chronic asthma; 4,200 lung cancers.’
This gives an indication of the human health value of reducing PM levels since the gains continue to zero levels (3). We will see that Wirral PM levels vary from ~10 to ~16 micrograms / m cubed.
PHE notes that the cumulative disease burden to 2035 associated with PMs includes 348,878 CHD cases; 246,916 COPD cases; 273,767 diabetes cases; 173,886 low birth weight children; 133,356 asthma cases; 106,331 strokes; 44,290 lung cancers. Similar analysis for NO2 exposure yields: 573,363 cases of diabetes; 335,491 asthma cases; 102,545 low birth weight children; 86,617 cases of dementia (4).
The international evidence of harm is overwhelming (8, 9). In many large epidemiological studies air pollution impact has been quantified while taking into account potential co- variables such as lifestyle (smoking, alcohol, exercise), income / education, and measures of socio-demographic deprivation (5). In many studies gradient effects have also been identified. That is, disease prevalence has been shown to fall away as a function of distance from pollution sources such as major roads (6, 7, 23). There have been very large, both cross-sectional and longitudinal health studies (6 provides a 78 page review of the health evidence). Such studies constitute a smoking gun and settle the issue of causation.
PHE notes that the Environment Audit Committee of the HOC found evidence that the cost of these health impacts was likely to exceed £8 – £20 billion.
Since the Clean Air Act in 1956 many sources of PMs have been eliminated but now levels have almost stabilised. The easy sources have been tackled (see Figure A). Traffic sources are resistant to reduction as number of vehicles and traffic miles continue to increase. The government claims that eliminating diesel and / or petrol cars will solve the air pollution problem (10). This is untrue. Their own data shows that ~80% of PMs do not come from car exhausts but from bitumen, rubber, organic and other waste matter released by vehicle tyres from road surfaces. ‘Electric’ cars and trucks will still cause high levels of PMs. Eliminating diesel cars will however reduce NOx by ~40% but published diesel vehicle reduction targets to 2040 in the UK and Europe are widely considered to be wildly optimistic (11). Official data for sales growth in Alternative Fuel Vehicles and conventional petrol / diesel vehicles suggest AFVs will be only ~8.3% of new car sales by 2030 versus the government’s ‘ambition’ and ‘illustrative’, 30% to 70%. Note that Figure A also shows that since ~2005 PM pollution from industrial and commercial activities has sharply increased again.
Recommended maximum allowable levels of the various pollutants continue to fall as health evidence emerges. The World Health Organisation published a review of 2,200 studies in 2013 (6) concluding that
‘Annual PM concentrations are associated with all-cause mortality to a high degree of [statistical] confidence. There is no evidence of a safe level of exposure to PM or to a threshold below which no adverse health effects occur.’
The Air Quality report authors comment that
‘Negative health impacts have been found well below current EU & UK limits.’
Local authorities such as WBC cannot simply say, as they do, we meet the EU or UK legal limits so no further action is needed. The WHO will steadily reduce PM limits in future years
which are currently set at 10 micrograms / metre cubed average levels. In the ‘Clean Growth Strategy 2018’ (12) the government promises to
‘reduce PM levels in order to halve the number of people living in locations where concentrations of PM are above 10 micrograms / meter cubed by 2025.’
Much of the Wirral is above this limit currently and as vehicle numbers and miles travelled increase in the medium term PM levels will increase, not decrease (32). There was a small reduction in vehicle numbers growth during ‘austerity’ for a few years but growth has recovered. Traffic volume flow between J4 and J5 on the M53 is given in Figure B. From 2000 to 2016 traffic increased by 33.5% or 2.1% per annum on average. However before and after the ‘economic shock’ period, during which growth halted, traffic growth rate was ~2.9% per annum. We will show that building in the M53 eastern corridor GB parcels will expose many areas to PM levels well above 10 micrograms / m cubed and this will increase over time.
The government promises new powers for targeted local action.
This should include not allowing building new housing in Green Belt areas and green spaces adjacent to identified PM and NO2 hotspots by major roads and motorways.
There is extensive literature evidence that significant health deficits are found at distances from motorways of 500 ms and more depending on the air pollutant and the diseases considered (6,7). If local authorities ignore the clear health impact evidence in the scientific literature and allow unnecessary house building in high risk areas they will be guilty of a failure in their duty of care to residents. In the case of Wirral, for the sake of certainty, we now present local evidence that air pollution is ubiquitous and that the prevalence of several diseases is strongly correlated with local PM air pollution levels.
4. Wirral Evidence on Pollution Levels
NO2 and PM measurements at many localities around the country have been used to calibrate government air pollution models by locality (13). These models take into account point (e.g. industrial) and line (road) sources of pollutants and topography. In the case of roads the key data are traffic flow volumes and traffic mix. The models also take into account prevailing wind directions and use well established spacial diffusion models to predict average concentration levels in one kilometre squares as defined on standard OS maps. This averaging means that pollution levels close to the source may be even higher because of gradient effects. Nevertheless the models give a reliable guide to pollution spread and general levels.
The Wirral pollution maps are given in Figure 1 for nitrogen dioxide and particulate matter. The patterns are similar in that the highest pollution levels occur east of the M53 (14). This reflects degree of urbanisation and in particular Birkenhead but also major road distribution. The high pollution levels along the length of the A41 near the Mersey are clear as are the high levels adjacent to the M53 from Eastham to Moreton. In relation to the proposed local plan GB release parcels note the very high PM levels near M53 junction 5 (Eastham) and junction 4 (Clatterbridge). (Note: Junction 2 and the Moreton spur road is also a hotspot).
It is therefore puzzling that the Scoping Report tells us (2.6) that :
‘No hotspots are associated with the Boroughs motorway junctions, nor the toll point of the Kingsway Tunnel, suggesting that the presence of significant strategic road network infrastructure does not currently give rise to notable air quality concerns.’
This is simply untrue. In fact the official air quality models show us pollution levels near the mentioned junctions as high as in the worst polluted areas of Birkenhead. An increase in traffic flows on roads feeding the junctions such as J4, resulting from large numbers of new houses on the GB parcels east of the M53 from Storeton south to Poulton Lancelyn would create a high air pollution nightmare. The roads are already congested at peak times twice a day and are generally very busy. J4 is also already a notorious traffic accident hotspot.
5. Preliminary Wirral Evidence for Air Pollution Health Impacts
Detailed analyses are currently underway exploring the links between the prevalence of several important disease classes across the Wirral and the levels of pollutants such as PMs and NOx . Disease data is available from several official sources at the level of political wards and constituencies. Pollutant exposure levels by ward are calculated from the models of Figure 1 by taking all the kilometre squares in a ward and the location of housing and calculating ward exposure averages. This procedure gives a score in the range of 1 to 4 for pollutant level. Disease prevalence is then plotted against pollution level and simple linear models fitted. In all cases significant correlations were found. These include:
Wirral Life Expectancy by ward versus PM10 (Figure 2) Wirral Mortality Rates (DSRs) versus PM10 (Figure 3)
Wirral Prevalence of Constrictive – Obstructive Pulmonary Disease versus PM10 (Figure 4). COPD Prevalence versus Indices of Multiple Deprivation (IMD) for closely similar PM10 level wards (Figure 4A)
Wirral Lung Cancer Mortality Rates versus PM10 (Figure 5). Lung cancer versus IMD for closely similar PM10 level wards (Figure 5 A)
Wirral Low Birth Weight Rates versus PM10 (Figure 6)
Analyses are also underway for dementia, diabetes, asthma, Coronary Heart Disease and stroke prevalence. Preliminary work also shows clear correlations with PMs and NO2.
We report the findings below for a selection of diseases. The ongoing analyses are currently addressing the issue of possible co-variables. Many published studies have already dealt with this issue and showed that even after lifestyle (smoking / alcohol / exercise) and so- called deprivation measures (income / service access) are included air pollution impacts are clearly significant (5, 6, 23). The intention here is to demonstrate this with Wirral health data. On the Wirral we can note immediately that smoking prevalence and intensity has been falling for many years yet diseases commonly associated with smoking in the public mind are rising. What is rising on Wirral are vehicle numbers and total miles travelled. We will also show later that constrictive obstructive lung disease (COPD) prevalence, while strongly correlated with PM level, is only weakly correlated with the Wirral ward level Index of Multiple Deprivation (IMD). The same is true for prevalence of low birth weight children.
It appears that the official habit of simply blaming disease on bad ‘lifestyle choices’ among the poor underclass may be overstated, or indeed a case of ‘blaming the victim’. High air pollution levels for example generally correlate with poor urban housing locations. As more major international multi-factor studies emerge, blaming the victims is becoming harder. To a first approximation, in a country like Britain, we are all air pollution victims now. Similar analyses examining other variables are being prepared for the other disease classes and will be published as soon as possible.
The intention of the detailed analyses will be to quantify the actual disease loading due to current variations of air pollution across the Wirral and to predict future loadings as traffic increases in general and in proposed areas of green belt development. Such increases impact both new residents in areas adjacent to the M53 but also current downwind residents. There is extensive evidence, accepted by government, and local authorities, that open fields, hedgerows and trees near motorways and major roads significantly reduce the levels of some air pollutants (15, 16). It is notable that WBC itself is promoting the growing of hedges for this purpose to protect schools (17) and that the Scoping Report talks of pollution mitigation ‘through green infrastructure provision’ (2.10).
On this ‘official’ logic it is surely wise to preserve not destroy, Wirral green spaces and existing green belt buffers near major roads and motorways.
Removing these green ‘shelterbelts’ by building on them reduces the protection of nearby, current residents and exposes new housing residents to high pollution levels (as is the case in all the GB parcels being considered for release east of the M53).
For now we will simply note some basic disease / air pollution correlations. Figure 2 shows Wirral life expectancy versus ward average PM10 levels. There is a clear correlation here with life expectancy at PM level 1 being around 87 years and PM level 4 around 75 years. This should not be surprising since Reference 1 tells us that : ‘reducing PM by 10 micrograms / m cubed would extend lifespan by three times more than eliminating passive smoking’.
The Air Quality Strategy for the UK in 2007 noted : ‘PM in the UK would be expected to reduce life expectancy averaged over the whole population by 7 – 8 months’. DEFRA tells us NO2 exposure alone ‘reduces UK life expectancy on average by ~5 months’. But of course excess deaths are concentrated in urban area sub-populations. People here are losing years of life.
In the worst cases the WHO note an average life deficit of ~ 20 months related to PMs.
Figure 3 shows Mortality, age standardised death rates, for the Wirral versus PMs and a linear best fit model (h1). The correlation coefficient is quite high at 0.69. We can say that 48%, roughly half the variability in Wirral mortality rate, is accounted for by PM level differences (while noting there may be several interacting variables in play here. See below).
Now we examine briefly, particular diseases. Figure 4 shows a best fit linear relationship between constrictive –obstructive pulmonary disease prevalence and PM10 level by Wirral ward (h3). The correlation coefficient is moderately high at 0.73. Taken literally this would imply that 53% of the variation in COPD prevalence is explained by PM variation.
With this data we can make a rough check of the scale of impact on COPD of other possible ‘causative’ variables as we can identify several wards where PM levels are very similar (~3.2 to 3.3). The main official measure which purports to capture the level of deprivation in a population is the Index of Multiple Deprivation. This is a weighted sum of several inputs such as income, access to housing & services, education, health and crime exposure. Health includes ‘lifestyle’ items such as smoking and alcohol prevalence. We might therefore expect IMD to correlate with disease measures such as COPD. IMD is usually adduced to explain various diseases under the short hand terms, ‘poverty’ and ‘lifestyle choices’.
In Figure 4 A we plot COPD versus IMD for wards with very similar PM levels. A linear fit gives a small positive relationship between COPD and IMD. The correlation coefficient is 0.11 so the slope is uncertain and IMD ‘explains’ very little COPD variation.
This is notable since other data suggests a strong relationship between smoking prevalence and IMD on Wirral. The intercept implies that even at zero IMD, COPD would be ~2% for this
set of wards. All we can say at this stage is that COPD is strongly related to PM levels but that other variables may also be in play.
Figure 5 plots lung cancer mortality rates (SMRs) versus PM10 levels across Wirral (h4). The scatter band is wide but a significant relationship emerges from a linear best fit. The correlation coefficient is moderate at 0.63. Taken at face value PM level accounts for ~40% of the variation in lung cancer. This is interesting since lung cancer is the canonical disease linked with smoking and high smoking prevalence these days correlates with low income. IMD should capture the low income effect and the direct ‘health’ deprivation / lifestyle effect. We noted earlier a sub-set of wards with very similar PM levels but a scatter of COPD levels. In Figure 5 A we plot lung cancer mortality versus IMD for these wards. There is a positive correlation and the correlation coefficient is again modest at 0.6.
This implies that IMD ‘explains’ ~ 36% of the variation in lung cancer mortality in this data. We can tentatively conclude that PM air pollution and smoking variation contribute about the same amount to lung cancer mortality locally. Given the strenuous legal and social efforts to reduce smoking dependence over recent decades it seems air pollution deserves the same state attention. We noted that smoking prevalence and intensity is falling on Wirral and across the UK. However fossil fuel vehicle numbers and vehicle miles travelled are increasing and will continue to do so for decades. The proportion of disease like lung cancer due to air pollutants such as PMs will increase over time. Combating this will be very difficult for future governments in existing built up areas. However two actions would be both easy to implement and totally effective :
1. Do not allow building of new housing, whether luxury or social homes, next to motorways and do not destroy green spaces and green belt protective zones.
2. If a council chooses to allow such building it should be required by law to WARN prospective buyers and existing residents downwind of the health dangers involved.
The government tells us they ‘aspire’ to build 300,000 new homes each year with many on green belt land. By following the above rules hundreds of thousands of families per annum can be protected from dangerous exposure to air pollutants. The real ‘need’ numbers are probably less than 160,000 houses per annum but there is still a huge accessible, potential saving in human distress, national disease burden and cost to the NHS.
The diseases examined so far express themselves mainly in adults. In fact the coronary heart disease, strokes and dementia impacts of PMs largely strike older people. Living in a polluted area can increase dementia risk by up to 40% (23). But we should be equally concerned about the health impacts of air pollution on children and the developing foetus.
There is very worrying evidence that living in high PM areas not only causes acute and chronic asthma but stunts lung development in children permanently (21). ‘Pronounced deficits’ in lung function has been found in 18 year olds who grew up within 500 ms of a motorway. Reference 21 notes
‘the new study found reduced lung growth in [young] people who lived by motorways in otherwise open spaces with relatively clean air.’
It should be noted that this major pioneering study took place in Southern California and only 3.9% of traffic there is diesel powered. In the UK the proportion is 45.9%. Even if the UK government clean air strategy succeeded it would not remove the problem (10, 11).
California state law now prohibits new schools being sited within 500 ft of a highway.
These lung stunting results have recently been confirmed in the UK (22). Of even greater concern is the recent work showing directly that fine PMs can penetrate the placenta of pregnant women (19). Fine PMs are carriers for a range of carcinogenic compounds. What is certain is that the literature proves a strong correlation between low birth weight in babies and PM levels in the air (18). Low birth weight correlates significantly with later childhood problems including cognitive deficits (20). These results should be viewed with alarm by all current and prospective parents and cause UK politicians to put immediate, severe constraints on house or school building near motorways and major roads.
It is of some interest then to see if LBW is connected to air pollution on Wirral. Figure 6 plots low birth weight prevalence for Wirral wards versus PM levels (h5). The correlation is strong at 0.71. This implies that ~50% of LBW variation on Wirral is explained by PM levels. There is also a suggestion in the data that the negative effect of PM accelerates at higher PM levels. We may safely infer that the associated physical and cognitive deficits in children living near major roads and motorways, demonstrated conclusively in national and international pollution-health studies, also apply to Wirral.
6. Wirral Local Plan : Planning Implications of the Health Deficit Evidence
We have examined a summary of the national and international evidence for the many negative impacts on new and existing residents of building housing estates in the vicinity of motorways and major roads and the positive health value of preserving green buffer zones and green spaces in general. The problem is recognised by government to the extent that Highways England is experimenting with giant poly-tunnels to cover motorways (24).
We also demonstrated by statistical analysis of Wirral health and pollution data, very similar and significant negative health impacts for several disease classes. The evidence for impacts on vulnerable groups such as pregnant women, children and older people is particularly concerning.
We also noted possibly two dozen Green Belt Parcels listed in the initial Local Plan for consideration for release from the green belt for major housing developments, lying adjacent to the M53 motorway. The parcels east of the M53 from Storeton, through Brakenwood (junction 4) and Poulton to Raby Mere and the parcels adjacent to junction 5 at Eastham, are downwind from the motorway and particularly vulnerable to additional pollution impacts. The official government air quality models show levels implying serious health effects.
All this evidence bears no relation to the Wirral Council Sustainability Assessment, Scoping Report in which all is apparently well on the Wirral. To be fair this simply reflects recent WBC documents on air quality (25). WBC sleeps on, apparently unperturbed by wider responses to this health crisis. Curiously this includes the new Air Quality Task Force, just set up for the Liverpool City Region Combined Authority of which Wirral is a part (26). Mayor Rotherham seems clear enough :
‘Poor air quality is a national public health crisis which is shortening the lives of people across our city region…’
WBC should also note the European Court of Justice action which threatens to impose huge fines on six nations including the UK. The northwest is one danger area identified (27). We can also draw WBC attention to the latest NICE Guidance recommendations on local housing and facilities planning (28) in relation to the M53 green belt parcels:
‘When Plan Making consider
- Minimising the exposure of vulnerable groups to air pollution by not siting buildings (such as schools, nurseries and care homes) in areas where pollution levels will be high
- Siting living accommodations away from roadsides
- Avoiding the creation of street and building configurations that encourage pollution tobuild up where people spend time
- Including landscape features such as trees and vegetation in open spaces or as‘green’ walls…
- Siting and designing new facilities and new estates to reduce the need for motorisedtravel.WBC should also consult ‘Housing & Economic Land Availability Assessment’ (29) on the issue of the ‘suitability of sites and broad locations for development’ and consider :
- Physical limitations or problems such as access, ground conditions, flood risk, hazardous risks and pollution or contamination.
- Environmental / amenity impacts experienced by would be occupiers and neighbouring areas.
- Potential impacts including the effects upon landscape features, nature and heritage conservation.
The extensive evidence presented above indicates the need for an independent, formal evaluation of the air quality health impact of the proposed developments on Wirral. The Institute of Air Quality Management & Environmental Protection’ provides detailed instructions for LAs (30) on what should be taken into account including
- The background and future baseline air quality
- The presence of a heavily trafficked road, with emissions that could give rise tosufficiently high concentrations of pollutants that would cause unacceptably high exposure for users of the new development.The author is working on these issues. It is also clear that it is necessary to investigate the exposure of new residents of a development to existing pollution sources but also to assess the impact of the new development on existing residents. We have shown that housing east of the M53 would both expose new residents to unacceptable air pollution but also remove the green buffer zone currently giving some protection to existing residents downwind.The new NPPF / guidance (31) is also very clear:
‘The planning system should contribute to and enhance the natural and local environment.’ This is to be achieved by:
‘preventing both new and existing development from contributing to, or being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability.’
‘Opportunities to improve air quality or mitigate impacts should be identified such as…green infrastructure provision and enhancement. So far as is possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. ’
The Wirral Local Plan must consider properly the health and environment impacts of building on the 50 sites earmarked for release from the Green Belt in the draft Local Plan.
Specifically, on the evidence, building on the GB parcels we have identified east of the M53 will not provide opportunities to ‘improve air quality’ for new or existing residents nor ‘mitigate impacts’ nor ‘enhance green infrastructure’.
It will definitely kill people.
We note from WBC Air Quality documents (25) that
‘By being involved in conceptual stages of local planning policy and proposed development before formal planning applications are made, Environmental Health can help scrutinise initial plans…’
‘We want all of our residents to have a good quality of life in clean and safe environments.’
‘To use the planning system, in accordance with guidance, to effectively promote air quality.’
The latter statement is a ‘key priority’ for the coming year. The current creation of the Local Plan provides a wonderful opportunity for WBC to deliver on all this positive rhetoric and protect current and future Wirral residents. Let us hope that these statements are true. Alas, the report concludes with
‘The principle challenges and barriers to achieving the above mentioned air quality priorities will be maximising the opportunities of the resources we have to maximise influence on air quality in the Borough.’
The author would welcome a coherent interpretation of this.
Professor D P Gregg (retired) Poulton Lancelyn April 2019