Long-outdated Air Pollution assessment still used in Wales

The official Welsh (WG) classification of Air Pollution levels (link) is inherited from the old Department of Health (DoH), based on COMEAP 'experts' who've changed their minds below). It’s still posted up for use, despite new Welsh policy issued in 2017. This included statutory guidance to Local Authorities on giving special consideration to the long-term risks posed to babies and children via exposure to air pollution. The old DoH/WG classification doesn’t.  This daily air quality index (DAQI) is also based on quite outdated standards for adults.

The World Health Organisation produced guidance in 2012/13, including identifying PM2.5 as a human carcinogen, but the WG took no notice until the Minister’s statement of June 2017. Revised WHO Air quality guidelines are due out in 2020. 

The WHO annual mean concentration guideline for particulate matter stipulates that PM2.5 not exceed 10 μg/m³ annual mean and 25 μg/m³ 24-hour mean; also that PM10 not exceed 20 μg/m³ annual mean, or 50 μg/m³ daily mean ( 24-hour).  PM2.5 is most closely related to ill-health impacts (see below).

The DoH/Welsh classification clings to the pre-WHO numbers, calling PM2.5 values below 35  “low” (40% higher than the WHO limit) and below 53 “moderate” (double the WHO limit).  It’s highly remiss of the Environment Minister that she has failed to withdraw this completely misleading classification and issue a new one for guidance of the people of Wales.

Vale of Glamorgan monitoring of the Barry 'Biomass' Incinerator

The Council has purchased two monitors that measure PM10, PM2.5 and NO2 every 15 minutes.  The averages for each hour are now posted daily.   We presume the numbers are accurate as the monitors have been working for two years.  However, users should ignore the low/moderate/high classification and colouring, which are the old defective WG/DoH ones above. 

View of the World Health Organisation (WHO) on particulate pollution (link)

Outdoor air pollution is a major environmental health problem affecting everyone in low-, middle-, and high-income countries.

   Ambient (outdoor) air pollution in both cities and rural areas was estimated to cause 4.2 million premature deaths worldwide per year in 2016; this mortality is due to exposure to small particulate matter of 2.5 microns or less in diameter (PM2.5), which cause cardiovascular and respiratory disease, and cancers.

  People living in low- and middle-income countries disproportionately experience the burden of outdoor air pollution with 91% (of the 4.2 million premature deaths) occurring in low- and middle-income countries, and the greatest burden in the WHO South-East Asia and Western Pacific regions. The latest burden estimates reflect the very significant role air pollution plays in cardiovascular illness and death. More and more, evidence demonstrating the linkages between ambient air pollution and the cardiovascular disease risk is becoming available, including studies from highly polluted areas.

  WHO estimates that in 2016, some 58% of outdoor air pollution-related premature deaths were due to ischaemic heart disease and strokes, while 18% of deaths were due to chronic obstructive pulmonary disease and acute lower respiratory infections respectively, and 6% of deaths were due to lung cancer.

  Some deaths may be attributed to more than one risk factor at the same time. For example, both smoking and ambient air pollution affect lung cancer. Some lung cancer deaths could have been averted by improving ambient air quality, or by reducing tobacco smoking.

  A 2013 assessment by WHO’s International Agency for Research on Cancer (IARC) concluded that outdoor air pollution is carcinogenic to humans, with the particulate matter component of air pollution most closely associated with increased cancer incidence, especially lung cancer. An association also has been observed between outdoor air pollution and increase in cancer of the urinary tract/bladder.

Origin of the Air Quality index and Banding

COMEAP first introduced the UK’s Air Quality index in 1998 (Committee on Medical Effects of Air Pollutants:  Statement on Banding of Air Quality, 1998. Link).

Their subsequent 2011 Review of the UK Air Quality Index (Daily AQI or DAQI) was introduced by Defra and devolved administrations from 1 Jan.2012.  It was COMEAP’s final publication before being disbanded and the last effort of British medical pollution ‘experts’ to maintain that only sensitive people need worry about air pollution (even said as “exquisitely sensitive” in Prof. Harrison’s evidence for an incinerator company – Portsmouth Incinerator Inquiry, 2000**).  British medical policy leaders in COMEAP, including Prof Harrison, were compromised in favour of incinerators at that time. Evidence on permanent harm to child-lung development was accumulating, measured as lung function, US/Calif authorities were recommending against children exercising outdoors during high ozone episodes, and European experts were developing the WHO guidance.  Prof Stephen Holgate chaired the COMEAP Review, which is thick with material on asthma, Holgate’s speciality.  They devised the irresponsible advice that only children with ‘lung problems’ should ‘consider’ ‘reducing’ ‘strenuous’ exercise at times of moderate or high pollution. The report says they were motivated by inter alia 

•          the need to avoid an exaggerated level of worry and concern
•          our view that children with no known respiratory disease were unlikely to be particularly susceptible to the effects of air pollution.

Most or all of the Review group published a scientific paper (Gowers et al. 2012) which found “outdoor air pollution might play a role in causing asthma in susceptible individuals”, but dismissed it as only a small contribution and a small proportion of the population. COMEAP in effect dismissed the then evidence of the pollution causing onset of new asthma cases, instead of taking a precautionary approach ("exaggerated level of worry and concern"). They had failed to learn from the BSE episode - scientists...part of the problem: Nature, Oct. 2000).   Their advice to asthmatic children was just use their inhaler.

Nowadays, however, Stephen Holgate talks of pollution worsening asthma and COPD and even emphasises the need to reduce NO2 as a cause of new-onset child asthma.  Prof Harrison likewise changed his view, but their COMEAP report lives on the DAQI.  Even though Welsh government policy is reduction of NO2, their Health Boards play it down and their NRW permits increases in NO2 up to the old limits. 

** Unpublished Evidence, via Public Interest Consultants, 2000 

Cardiff Incinerator challenge by CATI in High Court

NEWS FROM HIGH COURT    17-18th Dec.

The barrister Alex Goodman' case explained why Cardiff Council’s repeated delay to enforce against Viridor’s unlawful building work and failing to require retrospective permission was unique in British law.  Then Cardiff Council’s lawyer took 80 minutes, making brash assertions, some obviously in error. Viridor's barrister came in on Cardiff's side, claiming nothing wrong with starting building 8 months before permission, despite the Council telling them it was unlawful. There followed detailed argument on case law (Whitley Principles) then judge Wyn Wuilliams reserved his decision till later in January.

Cardiff council attacked over city incinerator

www.walesonline.co.uk

Cardiff council must “quash” decisions that allowed work to construct an incinerator to begin because they were taken unlawfully, Cardiff High Court heard today (17 December).

In an action brought by Cardiff Against The Incinerator campaigner Pauline Ellaway, barrister Alex Goodman told Judge Wyn Williams the authority had flouted regulations and allowed waste management firm Viridor to build in Splott when it should not have done so.

Dubbing the council’s actions “procedurally inept” he claimed the authority’s reports and consultation process were flawed and that it failed to stop work when it should have.

Mr Goodman insisted CATI’s “submissions fell on deaf ears because work was allowed to proceed.”

“No robust action was being taken in respect of development that was continuning apace,” Mr Goodman said.

Construction of the £185m plant started in July 2012 before planning conditions had been met.

Developers must “obtain consent and then commence works,” Mr Goodman insisted. “It is a simple sequence,” he said.

CATI’s solicitors repeatedly sent letters requesting enforcement be taken.

“Throughout the claimant has taken considerable action to encourage the council to take action,” Mr Goodman said.

“The council has always acknowledged it was unlawful and that the development was at risk.”

Despite this Mr Goodman said the authority allowed work to go ahead.

Petitions Committee acts over Waste Incineration policy

The National Assembly Petitions Committee held its 3rd oral session on petitions against incineration on Tuesday 29th, taking evidence over video-link from Prof. Vyvyan Howard of Ulster Univ. and Fellow of Royal College of Pathologists.

After questioning Prof. Howard, the committee agreed to:

• Issue a report on the issue of incineration of waste, and request a Plenary debate.
• Write to the Minister for Environment and Sustainable Development to ask him to consider the weight of support for this petition when considering the committee's letter calling for the Cardiff Incinerator plans to be called in.
• Write to those who have given evidence to Committee on this subject to seek their views on the modeling used to inform decisions in relation to Incinerators".

You can find Professor Howard's evidence on the Petitions Committee webpages (Item 2 of 29 May: P-04-341 Waste and Incineration) and see him answering questions from the Committee on the Senedd TV archive – click on 29th May.

His central argument was that official estimates of 'risk' from incinerator pollutants are flawed, giving single numbers when there is a wide envelope of uncertainty. The government relies on epidemiology, which is a "very blunt instrument". The research has not been carried out – both the hazard characterisation and exposures are very uncertain.  Those who present "unparameterised" modelling express an "opinion dressed up in numbers".  He explained exposures may be 100 times higher than estimates by comparing the Viridor claim for Cardiff of 0.24% of PM2.5 expected to come from their incinerator with the 17-32% actually measured in a small Swedish town due to a modern incinerator (meeting Euro-standards). The hazard of average incinerator PM2.5 may be many times worse than a power station's because of the toxic chemicals in waste and produced in burning. The very smallest (nanoparticles) fraction of PM2.5 are a worry as little can be done to filter them out and the volumes of emissions are very large.
[PM2.5 means particles smaller than 2.5micrometres, or 2500 nanometres, which humans breathe into their lungs. 
Nanoparticles means particles in the 10-100 nanometre range]