Brake responds to DEFRA air quality consultation

Department for Environment, Food and Rural Affairs consultation on improving air quality and reducing nitrogen dioxide in our towns and cities.

Response from Brake, the road safety charity, June 2017


Question 7. How satisfied are you that the proposed measures set out in this consultation will address the problem of nitrogen dioxide as quickly as possible?

Brake response:

Brake is very dissatisfied with the proposed measures to address the problem of nitrogen dioxide.

It has been predicted that in 2017, 86% of air quality assessment zones in the UK won’t meet the nitrogen dioxide targets set by the EU [1]. Poor air quality causes around 40,000 premature deaths every year in the UK [2], and exposure to nitrogen oxides (NOx), including nitrogen dioxide, has been linked to a range of respiratory diseases and increased morbidity [3].

Brake believes that the most effective way for the government to reduce air pollution caused by traffic is through investment in public transport, walking and cycling routes to enable people to choose more sustainable modes of transport instead of opting to travel by car.

The draft Air Quality Plan lacks detail and devolves responsibility for reducing air pollution to local authorities. The proposal that ‘It will be the responsibility of local authorities to develop innovative proposals for their local area that will bring pollution levels within the legal limits within the shortest time possible’ is weak and insufficient, and does not adequately address the fact that most traffic pollution comes from vehicles travelling on major routes, in big urban conurbations.

Brake is also disappointed that the plan does not include detailed proposals for a national diesel scrappage scheme (see question 14 for further detail).

We are facing a public health emergency and air pollution needs to be tackled at a national level with a consistent, evidence-based policy that has the government’s full backing.


1.  Draft UK Air Quality Plan for tackling nitrogen dioxide: technical report, DEFRA/DfT, 2017

2.  Every breath we take: the lifelong impact of air pollution, Royal College of Physicians, 2016

3.  Ambient air pollution: a global assessment of exposure and burden of disease, WHO, 2016

Question 8. What do you consider to be the most important way for local authorities in England to determine the arrangements for Clean Air Zones, and the measures that should apply with it?

Brake response:

As detailed in question 7, Brake does not support the government’s proposal to push responsibility for lowering air pollution onto local authorities.

We need Clean Air Zones everywhere where there is an illegal level of pollution to protect people from breathing toxic fumes, and this needs to be tackled by government at a national level.

Measures should be implemented based on best practice examples, e.g. London, Germany and the Netherlands [1], and local communities should be informed and engaged – to encourage cooperation and involvement with the sustainability and health agendas [2].


1. Urban access regulations in Europe: Low-emission zones, 2016

2. Transport planning for healthier lifestyles: a best practice guide, Transport for London, 2013

Question 9. How can the government best target any funding to support local communities to cut air pollution? What options should the government consider further, and what criteria should it use to assess them?

Brake response:

As detailed in question 7, Brake does not support the government’s proposal to push responsibility for lowering air pollution onto local authorities and believes that a nationwide approach should be taken to funding reductions in air pollution.

Question 10. How best can government work with local communities to monitor local interventions and evaluate their impact?

Brake response:

Brake recommends that the government take advantage of the relationship between local communities and their councils to monitor and evaluate local initiatives. By engaging with residents and interest groups at a community level, local authorities can specifically target their monitoring systems and information-based interventions.

In the City of London, the council has focused its monitoring on hotspots within the city’s ‘square mile’, engaging with schools and construction companies, and collecting the data required for policy decisions [1].

The information collected is also used to improve public awareness through the ‘London Air’ initiative by Kings College London, providing real-time modelling of pollution in the capital [2].  


1. City of London, Air quality reports.

 2. London Air, London air quality network: local authorities, 2017

Question 11. Which vehicles should be prioritised for government-funded retrofit schemes?

Brake response:

Brake recommends that the government prioritises diesel-fuelled cars and light goods vehicles (LGVs) for retrofitting initiatives.

Diesel road vehicles, particularly passenger cars, are major NOx producers and the proportion of the licensed car fleet that is made up of diesel-fuelled cars continues to grow. In 2016, there were 12.1 million diesel cars, accounting for 39% of the total licensed car fleet, up from only 10% in 1996 [1].

LGVs are the fastest growing mode of transport on UK roads, owing to the growth in online shopping and home deliveries [2]. Van traffic grew by 4.7% between 2015 and 2016, to reach a record high of 49.1 billion vehicle miles in 2016 [3]. In 2016 there were 3.8 million licensed LGVs in the UK, the majority of which (3.6 million or 96% in 2016) are fuelled by diesel [4].


1.   Vehicle licensing statistics: 2016 report, DfT, 2017, VEH0105

2. Braithwaite, Prof. A., The implications of internet shopping growth on the van fleet and traffic activity, RAC Foundation, 2017

3. Road traffic estimates: Great Britain 2016, DfT, 2017, TRA0101

4. Vehicle licensing statistics: 2016 report, DfT, 2017, DfT, 2017, VEH0403,

Question 12. What type of environmental and other information should be made available to help consumers choose which car to buy?

Brake response:

In recent years, many diesel cars have been revealed as having NOx emissions that exceed, or massively exceed, their current exhaust emission standard. Brake believes manufacturers should be required to disclose real-world driving emissions (RDE) data to their customers.

Studies suggest that real-world NOx emissions for new vehicles are six to seven times the limit (80mg/km) mandated by the Euro 6 standard [1]. Test conditions for these standards are laboratory-based and strictly regulated, lacking crucial elements of real-world driving that can influence vehicle emissions (e.g. speeding, road environment and idling) [2].


1. Fact sheet Europe: Impact of improved regulation of real-world NOx emissions from diesel passenger cars in the EU, 2015-2030, ICCT, 2016

2. Fact sheet Europe: Impact of improved regulation of real-world NOx emissions from diesel passenger cars in the EU, 2015-2030, ICCT, 2016

Question 13. How could the government further support innovative technological solutions and localised methods to improve air quality?

Brake response:

It is harder to limit the release of NOx from a diesel engine compared with a petrol engine, because the higher temperatures in diesel engines cause NOx to be released in higher amounts. However, it is possible to make engine modifications to reduce engine temperature and there are after-market NOx ‘control technologies’ available (e.g. lean NOx traps and selective catalytic reduction) that can reduce the level of NOx produced by diesel vehicles [1]. Brake believes the government should incentivise vehicle manufacturers and owners to install these technologies in all diesel vehicles.

Additional measures should be taken to dissuade people from owning diesel vehicles. These could include higher parking charges for diesel vehicles, charges to enter a ‘low emission zone’, higher taxation of diesel for cars, and a financial incentive to scrap older diesel cars.

Installation of additional electric vehicle rapid-charging points is another opportunity to improve air quality. Government support for ultra-low emission vehicles (ULEVs), with more than £2 billion in funding [2], has resulted in almost 42,000 new ULEVs registered on UK roads in 2016, a 40% increase on the previous year [3]. Installing infrastructure designed to support ULEVs will encourage more people to buy these vehicles.


1. Fact sheet Europe: Impact of improved regulation of real-world NOx emissions from diesel passenger cars in the EU, 2015-2030, ICCT, 2016

2. Draft UK Air Quality Plan for tackling nitrogen dioxide, DEFRA/DfT, 2017

3. Vehicle licensing statistics: 2016 report, DfT, 2017, VEH0130

Question 14. Do you have any other comments on the Draft UK Air Quality Plan for tackling nitrogen dioxide?

Brake response:

Brake is disappointed that the draft Air Quality Plan does not include proposals for a diesel-scrappage scheme. As stated elsewhere in this response, diesel vehicles, particularly passenger cars and light goods vehicles, are major NOx producers and their numbers are growing (see question 11).

Brake recommends the introduction of a national diesel-scrappage scheme to give a financial incentive for owners of diesel vehicles to switch to more environmentally-friendly means of transportation.