The EIP: 10 Days of the 10 Goals - Goal 2: Air

To paraphrase the immortal words of 1960s psychedelic pop group The Hollies, sometimes, all we need is the air that we breathe. It is with that spirit in mind (probably) that the Environment Improvement Plan 2025 sets out the most ambitious targets for improving air quality yet, declaring that “we will achieve clean air”.

The supporting text to Goal 2 begins with a note of optimism, noting that air quality in the UK has improved significantly, with “the air we breathe today…cleaner than at any time since before the industrial revolution”. This optimism is deserved: in London alone, annual average roadside concentrations of nitrogen dioxide dropped by nearly half between 2016 and 2023. [1]

Nonetheless, there is much work still to be done. The EIP cites a study by the Royal College of Physicians that identifies air pollution as one of the biggest environmental threats to human health. This has come sharply into focus in recent years. The European Court of Human Rights held in Cannavacciuolo and Others v Italy (application no. 51767/14 and others) earlier this year that a State Party breached the right to life under Article 2 by failing to address large-scale environmental pollution. The Inter-American Court of Human Rights handed down a seismic advisory opinion over the summer confirming that the human rights obligations of States in the face of the climate emergency include taking action to reduce air pollution. Domestically, the inquest into the death of 9-year-old Ella Adoo-Kissy-Debrah concluded in 2020 with a finding that acute respiratory failure, asthma and “air pollution exposure” caused her death.

Outside the legal context, Goal 2 and the commitments therein may be understood as laying the necessary foundations for realising the ambitions elsewhere in the EIP. Improved air quality supports biodiversity by improving the quality of air enjoyed by all living creatures; it aids nature restoration by reducing the pollutants that harm sensitive species; and it boosts the quality of water sources by reducing the pollutants that settle on bodies of water through atmospheric deposition. More generally, improved air quality is a gateway to ensuring that the public can enjoy the outputs of a clean environment safely and healthily.

Against that backdrop, the EIP sets out four commitments:

1. Commitment 19: deliver 2030 emissions targets to reduce anthropogenic emissions against a 2005 baseline level, achieving a 16% reduction in ammonia; a 73% reduction in nitrogen dioxide; an 88% reduction in sulphur dioxide; a 46% reduction in particulate matter; and a 39% reduction in non-methane volatile organic compounds.
2. Commitment 20: deliver air pollution levels set out in the Air Quality Standards Regulations in local areas.
3. Commitment 21: deliver air quality targets for particulate matter concentration and exposure.
4. Commitment 22: improve communication of air quality information.

One striking contrast to the 2023 EIP is the timeframe set out for delivery of reductions in emissions. While the 2023 EIP set out a long-term targeting of achieving an Annual Mean Concentration Target of 10 micrograms of fine particulate matter (PM 2.5) in the air per cubic metre, the 2025 EIP brings that forward to 2030. This is supported by a further target to reduce population exposure to particulate matter by 30% compared to 2018 by December 2030.

Considering the public health consensus around the short- and long-term harms of exposure to particulate matter, this is a very significant shift indeed, and one that brings the EIP more in line with cautionary international health advice. Particulate matter exposure can result in serious respiratory conditions, cardiovascular disease, pregnancy complications and a litany of other health issues. Any hastening of timeframes for reducing exposure to it is to be welcomed.

As ever, the proof will be in the pudding. The supporting text to Goal 2 places particular emphasis on measures to be delivered in the transport sector, with an ‘evolution, not revolution’ approach seemingly being taken to transport modes. For instance, the Goal 2 action plan sets out the target that 80% of new cars and 70% of new vans sold in the UK will be zero emission by 2030. This is to be achieved through existing measures such as the Zero Emission Vehicle Mandate and the Electric Car Grant.

Conspicuously absent from Goal 2’s action plan are firm targets relating to active travel, such as the delivery of new cycling routes. In fairness to it, the EIP recognises that forms of active travel are also essential to reducing emissions, committing to “continue to support councils with a £616 million investment to build and maintain walking and cycling infrastructure.” But it is doubtful whether this will suffice. The Office for Environmental Protection (“OEP”) 2022-2023 report on progress towards achieving the EIP targets in place at the time noted that road transport produces the largest proportion of UK emissions of NOx. However, national funding levels for active travel have yo-yoed in recent years, with the OEP predicting in 2023 that the 2030 vision for 50% of all journeys in towns and cities to be on foot or bike is unlikely to be realised. Coinciding with the publication of the updated EIP, a coalition of non-governmental organisations connected to transport and public health called on the Secretary of State for Transport to set these specific targets in order to “move from good intentions to a clear, long-term, fully deliverable national plan comparable to other strategic transport programmes”. It is not clear whether the third Cycling and Walking Investment Strategy referred to in the EIP, due to be published in early 2026, will go so far.

A critical ingredient to the success of goal 2 will be adequate resourcing for local authorities. This is true not only of active travel infrastructure and strategies, but also of the goal 2 targets relating to the planning system, local transport plans and management of highways. It is a trite point that local authorities face very significant funding challenges, as well as an uncertain administrative landscape, considering ongoing discussions regarding local government reorganisation. Both of these issues have the potential to put the brakes on the government’s ambitious 2030 timeline for reductions in particulate matter.

Overall, there is much to be welcomed in goal 2. If – and this is a big if – it is implemented within the timeframe envisioned for the government, goal 2 is capable of delivering wide-ranging benefits for human health, wellbeing and the realisation of the right to a healthy environment. Let us hope that the commitments within it to improve air quality do not lose steam.

Claudia Hyde is a barrister at Landmark Chambers.

[1] London Assembly, ‘Air quality in London 2016-2024’ (8 March 2024).

This is the second in a ten-part series on the EIP goals. See also:

The EIP: 10 Days of the 10 Goals - Goal 1: Restored Nature