IAQM Forum: Should the UK adopt WHO air quality targets?

1. Tim Williamson
18 October 2022
WHO Guidelines 2021: fit for policy?

2. Logika Group
18 October 2022 2
IAQM
Forum
Three sister companies – Air Quality Consultants, Noise Consultants and Logika
Consultants – together form the Logika Group, comprising around 50
environmental experts based in the UK and continental Europe.
• Largest independent AQ consultancy in
the UK, > 25 years old
• We provide expert advice and support
to developers, industry, local authorities
and policy makers
• Experts in environmental noise and vibration
management and assessment
• Our specialists work in the aviation,
transport, residential and industrial sectors
as well with governments
• Embedding environmental design into the
built and rural environments
• We work with public and private sector
clients to enhance the multi-functionality of
natural capital and green infrastructure
Environmental Policy & Economics Practice
Established in 2020 to work horizontally across the group

3. 18 October 2022
IAQM
Forum
3
My background
• Most of my professional career has been linked to
environmental policy targets in some way, mainly
air quality but also climate, waste and water
• Worked in air quality in local authority,
government, NGO and consultancy
• Was actively involved in discussions about exposure
reduction targets for particulate matter as part of
the EU AQ Directive, as an NGO and as a UK
Government representative
• All views expressed are my own, and do not
necessarily reflect the position of AQC or Logika

4. Should the WHO
guidelines be adopted as
UK air quality targets?

5. 18 October 2022
IAQM
Forum
5
What is the purpose of policy targets?
Targets serve multiple purposes:
• An indication of the “end point” of policy
• A benchmark against which to assess developments or activities
• A measure of progress, or a waypoint towards an end goal
• A way of holding authorities or organisations to account
• A trigger for action (or a way of deflecting or postponing action)
• A way of focusing attention or effort
• A demonstration of ambition
• A surrogate for an outcome or effect
These are often contradictory, and no one target can fulfill them all

6. 18 October 2022
IAQM
Forum
6
Two common features of policy targets
• As soon as a target is set, the policy aim is to meet the target, not address
the issue the target represents
• NHS waiting list targets are supposed to represent the responsiveness of the service,
but, in reality, can mean that patients are not referred
• AQ concentration targets are meant to represent health effects, but the focus is often
on areas of marginal compliance and some EU Member States (or cities therein)
routinely move monitoring stations
• The stricter the enforcement, the greater the incentive to “game the
system”
• This is especially true where compliance is not fully in the control of the authority
concerned

7. 18 October 2022
IAQM
Forum
7
What is the purpose of AQ targets?
• AQ targets are intended to be a surrogate for effects, and a threshold for
action. However…
• WHO review shows that health effects occur at levels below the targets (especially for
long term impacts)
• A simple concentration figure cannot reflect the complexity of the health evidence
• Linking actions to outcomes (concentrations or health impacts) is extremely difficult in
reality
• Emission targets are more closely linked to action, but emission estimates are just that
• Ecosystem targets (e.g. critical loads) more closely represent effects but are generally
perceived as being unobtainable, and are thus more indicators than targets

8. 18 October 2022
IAQM
Forum
8
WHO Guidelines as policy targets?
• WHO are clear that the guidelines are not legally binding…
• …but are intended to inform the setting of policy and legislative targets (i.e. not a cut and paste)
• A policy/legislative target is never just a number
• It needs an assessment approach and timescale to be defined
• The tighter the target, the longer the compliance date, and the more it can be ignored
• Achieving the guidelines won’t necessarily bring the greatest health benefit
• They are currently achievable in many/most geographical locations, which would thus not
benefit from action,
• but would require virtually zero emissions in South East England. All of the policy investment
would thus be in the wealthiest and already best served part of the country
• A lack of achievability would undermine the case for action on AQ in
Government

9. 18 October 2022
IAQM
Forum
9
So, what is the roles of the WHO
Guidelines?
• They provide a clear, evidence-based message that we are not “done”
with air quality
• They provide a long-term aim but we need achievable, interim targets to drive policy
• They offer a start point for policy but are not the complete package
• We need targets that provide the greatest health benefit in the most efficient way
• AQ targets need to be linked to broader outcomes: net-zero, public health, biodiversity
protection. Simple concentration values cannot provide that
• We need to beware perverse outcomes and unintended consequences
• Targets tend to skew policy towards their achievement, no matter the real-world
outcome

10. www.logikaconsultants.co.uk
www.noiseconsultants.co.uk
www.aqconsultants.co.uk