National Assembly for Wales

I nominate Delyth.

Okay. So, we'll just check the translation quickly. 

Only normal declarations about cross-party groups on air quality and active travel, in case it's relevant later.

Hi. Good morning, everyone. I hope you can hear me. I'm sorry I couldn't be there in person, but it's good to be able to join you this way. My name is Jenny Hawley. I'm the policy manager for Plantlife, which is a UK charity focused on speaking up for wild plants, lichens and fungi.

Thank you so much, Jenny.

Diolch am hwnna. Eirian.

Eirian Macdonald, principal adviser, Natural Resources Wales—Cyfoeth Naturiol Cymru.

Thank you so much. And Nadia.

Bore da, bawb. I'm Nadia De Longhi. I'm head of regulations and permitting in Natural Resources Wales.

Fantastic. It's lovely to have you all with us. Please don't feel like you all have to answer all the questions, but if there is anything that you'd like to come in on, if you want to indicate or raise your hands whenever people are asking. We'll go straight into questions.

If I could just ask firstly, in terms of the Bill as it's drafted, do you think that it's ambitious enough that it will lead to the improvements in air quality and soundscapes in terms of in its form at present? Who would like to go first on that? You're all being very polite. Yes, Nadia, go for it.

We welcome the Bill in terms of its focus on health and air quality, but we would like to see further strengthening around the environmental elements of it. In particular we'd like to make sure that there's working across departments to maximise the synergies with other areas of policy around things like net zero, sustainable farming, active travel, public transport, those kinds of things, but also making sure that there are no unintended consequences around social inequality, and particularly looking at a whole life cycle of buying products and things that impact on our air quality.

Thank you, Nadia. Haf.

We're really pleased that the Bill has been introduced, to start with. We've been campaigning as part of Healthy Air Cymru to get legislation on clean air for a number of years now. We're really glad that there's been cross-party support and that this Bill has been introduced. So, we're definitely supportive of the general principles of the Bill. Of course, it's not going to deliver everything by itself. There is a whole range of policies and actions that need to sit around it—some already in place, some that need to be put in place as well. So, we can't see it just in isolation. And, yes, there are some ways in which we'd like to see the Bill strengthened, or would like to see clarity on those areas as we go through the Bill process, but generally, we're very supportive that we're in this place.

Diolch, Haf. Did anyone want to add anything or are you largely in agreement? Yes, Jenny.

Thank you. Can I just add, to support what the witness from NRW said, that we would like to see more focus on the environmental side of the Bill? I think there is a recognition in the wording that air quality affects wild plants and fungi and other biodiversity, but that's not really reflected in the ambition of the Bill and the measures that it would set out in law. So, that's something that we'd like to see addressed.

And then, secondly, specifically on ammonia emissions, which affect both biodiversity and public health, which we could talk more about later, that is not really recognised in the Bill and there are no specific measures to tackle that or even an overarching target.

Thank you for that, Jenny. I've got a request for a supplementary from Huw.

Thank you, Chair. I just wanted to pick up on the fact that this has taken a long time of campaigning to get to this point, and we don't want to unnecessarily delay the Bill by adding lots of things in. However, you mentioned the issue of active travel. I just wonder whether any of the witnesses today have a view on whether, with the two primary purposes and the additional aspects of this Bill, active travel could be encompassed within it from an air quality perspective. Nadia.

I think it can. There are obviously a number of other policy objectives already that cover active travel. So, I'm with you; I wouldn't like to see this delayed further in order to do so, but I think there are opportunities to build those connections and those synergies in, but just to make sure that the implementation of the things that we know we need to do in order to improve air quality actually happen alongside the development of any targets, for example. Because we know we need to deliver a lot of these activities anyway in order to get the air quality reduction that we want to see.

So, if it was something simply like a couple of amendments to do with the duty to promote active travel and it fell within the measures described within the purposes of this, that would be okay, as long as it wasn't—

We'd support that.

We want this legislation to go through, but it's also probably the one opportunity that we have to legislate, so it's important that we get it right and that we make it as strong as possible. I can imagine, for example, the section on promoting awareness—. There is reference to promoting awareness of tackling air pollution. For me, active travel is implicit in that, but maybe it could be made more explicit as long as it fits in with the scope. From what I can see from the title of the Bill, that could be a possibility. I'm very interested and happy to develop that area.

That's brilliant. Thank you; diolch.

Diolch, Chair. To what extent do the proposals in the Bill take adequate account of existing inequalities and prevent further inequalities from occurring?

I'll take that. Thank you for the question. I think this is a really important issue. Air pollution is a social and environmental justice issue. That's one of the key reasons why we've been involved in this campaign from the start. We did conduct some data analysis on communities and neighbourhoods in Wales last year that did show that there's a disproportionate impact of air pollution in communities where there is lower income, neighbourhoods with higher ethnic minority populations and areas with lower car ownership as well. So, there is a clear link between air pollution and inequalities. It's also clear that people with existing conditions, such as lung and heart conditions, are more impacted by air pollution.

I don't think there is a specific reference in the legislation, as it stands, to inequalities, but given the disproportionate impact of air pollution on those communities, then strong action should benefit those communities more. I think there is an interesting point, though: I noticed there's evidence been submitted by Coleg y Cymoedd students—written evidence in the form of a petition—that highlights this issue, and it's great to see students and young people engaging with the scrutiny session. I think that they asked the Bill to take into consideration the disproportionate impact on people of colour, young people, disabled people and working-class people. So, there is probably more scrutiny that needs to be done in this area. I've not looked at everyone who's given evidence, but I think, in line with the ways of working of the future generations Act, it is key to involve the most impacted communities, and maybe not on the detail of clauses within the legislation, but I think it's an important part of the Bill process to engage with those communities, and to reach out and to ask those questions. 

Are there any other comments from anyone?

I think that Jenny Hawley, online, may want to come in. 

Yes, please, just quickly. Thank you. Just to highlight, really, that air pollution is not just an urban issue. I think a lot of the debate around air quality is around urban areas and urban populations, which is understandable, but it is also an issue that affects rural communities, particularly communities who live near large numbers of intensive livestock units, for example, where the pollution and the smells from those units can have quite a significant impact on people's quality of life and their health. So, I just urge the committee to take that into account as well, in terms of agriculture as a source of air pollution. 

Thank you. Do you think the Bill adequately balances improving public health and maintaining and enhancing nature and biodiversity?

Can I come in there? Thank you. I should have said also that I'm not just representing Plantlife, but also Wales Environment Link, which is a wider coalition of environmental and conservation organisations.

No, I don't think the Bill does adequately strike that balance. Obviously, public health is a major concern, and that's rightly addressed, but, as it stands, the Bill would do very little to maintain and enhance Wales's biodiversity. There's some really spectacular wildlife sites and species, which are internationally important and Wales should be proud to host and to look after, and, really, this Bill does not strike that balance. It doesn't do enough on the biodiversity side, which I think is a real missed opportunity. 

Thank you. That's me done. 

Diolch. Thank you, Janet. Did anyone else want to come in on that last question?

I was just going to say that we support Jenny's comments. I'm sure we'll go into a bit more detail further on in further questions. 

Okay. Thank you, all, for that. Huw, did you want to come in on this?

No. If we get to it later, that's great. I'm interested to explore that issue of how you enhance nature and improve biodiversity, but hopefully we'll get it to later.

Yes, lovely. Okay. Thank you so much. 

Thank you, and thank you for your written evidence. I just want to turn to what the Bill is doing and what the Bill is not doing. You make some coherent arguments in your papers that just limiting targets for PM2.5 is insufficient. Could I ask Jenny Hawley, first of all, as you're online? You make a very coherent case for having a target for ammonia. The issue is whether it's possible to do this—. Is there a standard way of setting targets so that we can then enforce it?

Thank you. The current target that we have for the whole of the UK for ammonia comes from the national emission ceilings directive under the EU directives. Obviously, now that we've left the EU, that will fall away. The latest target is 2030, so that would expire anyway in 2030. So, there is that precedent for having the target for ammonia emissions. The target for 2030 is a 16 per cent reduction since 2005, and 8 per cent by 2020. The UK as a whole only just kind of squeaked past that target, and there was some juggling of the figures to make that work. So, there is a precedent there for the ammonia emissions target.

Ammonia doesn't come under the World Health Organization guidelines, because, as I understand it, those are about ambient concentrations of the pollutant, and ammonia is a gas that doesn't really chemically work in that way; it's quite short-lived, and it transforms into other gases, or gets deposited onto vegetation, which is our concern here. So, the WHO guidance is not a way to measure ammonia, but there are other ways to do it, and there are quite substantial data sets and analysis that is already done for the Welsh Government and for NRW that we could use as metrics for setting those targets.

You think it is possible to set metrics for these targets. Okay.

Yes, absolutely. There are already figures there. These emissions—I think, in terms of total annual emissions, those have been measured for many years now, many decades. And I think the importance of ammonia targets—. Ammonia emissions have increased by 11 per cent since 2010 in Wales, whereas most other pollutants have had quite a significant decline—so, if you compare it to a 61 per cent decline in nitrogen oxide emissions since 2005, 75 per cent for sulphur, 30 per cent for PM2.5, ammonia is really one of the pollutants where there's very little or no progress being made in bringing those reductions, and I think a target is really urgently needed to be able to drive the action by Government and NRW and the industry to really take this issue seriously and to make some much quicker progress in bringing those emissions down.

Okay, so just turning to your arguments for doing this, clearly, it's good news for brambles and nettles, but very bad news for lots of other species. But the main source of ammonia is presumably the poo from cows. Is that right?

Certainly, the main sources of ammonia are from agriculture in general. I wouldn't wish to comment on the source apportionment of the different activities within that sector, but certainly it's mostly from the agricultural sector. I agree with Jenny that there is, we could—. We do have the data at the moment that we could set a realistic target, and that setting of a target would focus initiatives towards reducing ammonia in general, which is desperately needed by our biodiversity, because what this does—. You're right in saying that some species will actually thrive on the additional nitrogen, but a lot of species, especially our smaller and maybe rarer plant species, won't, and they will be subject to toxic effects from the ammonia directly, and they will also suffer from the fact that ones that thrive on nitrogen and ammonia will grow disproportionately and smother the smaller plants as well. So, what we're doing is—. By the ammonia levels staying high, with time, that reduces the variety of biodiversity that we have within Wales. And from what I understand, there's about 50 per cent of our land area at the moment that is exceeding the target for the lower species and the more sensitive plant species and, consequently, they are under threat in those localities.

Okay. In the context of the biodiversity crisis, it seems reckless, does it not, to not tackle this?

Absolutely. We are in a nature emergency as well as a climate emergency, and this seems a good opportunity for us to be able to actually drive forward some of the improvements that are needed in ammonia reductions for giving biodiversity the space to establish and be maintained and enhanced.

Jenny, forgive me interrupting, sorry, I think Joyce wanted to come in on a supplementary on this point. Forgive me.

On the same theme, in terms of the effect that excess levels of ammonia is having on the plant life that you've described, what effect then does that have, equally, on any wildlife or species that would be dependent, particularly, on the plant life that will be struggling in these cases?

The plant life that would suffer is part of the ecosystem in general. So, when those basics actually suffer from the ammonia, then the whole chain that grows out of that and relies on that also suffers. I think the other interesting thing on ammonia as well is that ammonia itself contributes towards the formation of secondary particulates within the atmosphere, and as such would contribute significantly to the PM2.5 concentrations that are already the focus of the Bill. 

I think that Jenny Hawley wants to come in on this point, and then we'll go back to Jenny Rathbone. Jenny Hawley.

Yes. Thank you. Just to follow up on the biodiversity point, we've found at Plantlife that those smaller plants, the mosses and the lichens and the fungi, can tend to be a bit in the background to some of the more charismatic wildlife, if you like. But, as the other witness said, those species are the foundation of the ecosystem. So, if you think about healthy woodlands, it's not just trees; it's trees that have those lichens and mosses, and those provide shelter and food, they hold back floodwaters. They provide shelter and food for insects, and then obviously the insects feed the birds and it's part of the whole ecosystem, and that makes it a real, good indicator of a healthy, biodiverse woodland. And lichens have been used as an indicator of air quality for many centuries traditionally, so that's a really good example. More than 94 per cent of the all the broadleaved woodland in the whole UK has excess nitrogen levels, as well as most of our traditional meadows and species-rich grassland and montane habitats. So, it's an exceptionally widespread and urgent problem, and I compare it to—. There's a very high profile around water and river pollution at the moment, and the nutrients running off from farmland there, and it's essentially the same issue, it's just that it's much less visible because it's in the air, it's invisible. These invisible gases, they get deposited and then they make what sometimes can be very toxic damage, but more often it's just a gradual change in the species and disappearance of species, which is much less obvious to the untrained eye. But it's really just quietly devastating some of the most important wildlife sites in Wales, which is just a tragedy, because it's such a fantastic part of what makes up Wales's great countryside.

Diolch. Thank you for that. Back to Jenny Rathbone.

Okay. I just want to pursue this issue with NRW, because, obviously, you're both adviser and enforcer on behalf of the Welsh Government. We had some concessions from the Minister for rural affairs in the discussions about the Agriculture (Wales) Bill 2022 last night in terms of moving towards the Kunming-Montreal COP15 targets in relation to the agriculture Bill. So, in your paper, you argue for the joining up of the dots on this. What discussions have you had with Welsh Government on ensuring that all our legislation is aligned towards the main issue, which is, obviously, the climate and biodiversity emergency?

Shall I pick up first, and then you can top up? So, yes, there are ongoing discussions around a number of regulatory reform areas, particularly around environmental permitting, where, as an example, we permit poultry farming, but only at thresholds above 40,000 birds. So, there are discussions around things like the thresholds for that, the scope of whether other farming sectors should be covered by environmental permitting, and then making the connections through from environmental permitting through to the intentions of the Environment (Wales) Act 2016 and the Well-being of Future Generations (Wales) Act 2015, because sometimes there are conflicts between the planning and permitting legislation and the intention of those broader environmental Acts, and the two don't always marry up. So, there are early discussions around how those pieces of legislation could be reformed and brought together more closely to deliver the aspirations against the nature and climate emergency. 

Okay. So, it's a work in progress. Okay. Can I just—?

Can I just say—?

Yes. Sorry—go on.

Can I just add to that? I think it's worth noting as well that we are actively working with Welsh Government in relation to the sustainable farming scheme and the development of that, and that should give us opportunities as well to see some of the improvements delivered to minimise the ammonia releases from agriculture.

Okay. Thank you for that information. So, just moving on to—. I'll come back to you, but just moving on to Friends of the Earth's argument that we need to set a target for nitrogen dioxide, can you just expand on your paper, really, as to why we wouldn't be—? I mean, we're already not compliant, and the levels required for it to be reduced are already being tightened, so it's surprising that we aren't addressing this issue in this Bill, and I just wondered if you've had any discussions with Welsh Government on why they're not grabbing this one.

I should say, to start with, although we haven't addressed ammonia in our evidence, we are happy to support the co-panellists in the inclusion of that in this Bill. But, yes, we have focused on the PMs and nitrogen dioxide, and we were disappointed, to be honest, that there wasn't a specific reference, that the only requirement in this legislation is to set a target for PM2.5. It is absolutely essential that nitrogen dioxide is included. We know the impact from road transport and energy generation and other combustion. There's such a big impact on health conditions, and it's such a big air pollution issue, it would be wrong to leave it out or to leave it to the discretion of this or any future Government. So, unless we specify all the relevant pollutants, then we're not going to get to clean air, and, in particular, leaving something as clear as nitrogen dioxide out would make the Bill much weaker. We understand that it's linked to what evidence is already there, what work has been undertaken, that PM2.5 was specifically named in the Bill, but we do think there is enough data and evidence and work that has been done on other pollutants, including nitrogen dioxide, that means that it should be strengthened in the Bill and it should be named that there is a requirement on Welsh Government to set a target.

So, why, then, is the Minister arguing that it wouldn't be possible in the short term, due to a lack of data?

I'm not sure. From our position—. I'm not a scientific expert, but, from what we see, there is clear data out there. There's been rigorous research, obviously, by the World Health Organization; we have those limits. There is of course a process in the Bill, which I'm sure we'll get on to, in terms of setting targets by regulation. So, that does allow for more time, if there are specific gaps in knowledge, but it is essential that there is at least a requirement on the face of the Bill to set a target for nitrogen dioxide.

Thank you. And in relation to ammonia as well, why is the Minister arguing that there is insufficient data to set a target?

Similar to what Haf has said in relation to nitrogen dioxide, we're not quite sure why that may be the case. Certainly, there is evidence of the impact that ammonia has on biodiversity, and Jenny was talking earlier about how we have to already report on ammonia, from a NECD perspective, a national emission reduction commitments directive. So, that data is already being gathered for that purpose and, at least initially, that data, hopefully, should enable us to set initial targets and then refine those, as we move forward, to make that focus even more so on ammonia. But I would think that there is an opportunity for us to do that at this stage.

Thank you.

Forgive me, Jenny, I think Huw wanted to come in on this.

Thanks, Jenny. I just wanted to clarify: are you looking for ammonia and nitrogen dioxide to be on the face of the Bill, but not with the target for them on the face of the Bill, to specific reference to them that targets must be set?

Absolutely, yes.

Yes, that's correct.

Okay, thanks.

Thank you. That's useful. Just to go back to Haf, you're calling for air quality targets to be consistent with WHO guidelines. Can you explain why you don't think the Bill already makes that commitment?

Well, we do accept that the targets don't have to sit on the face of the Bill, and that it does make sense to have those in regulation. I think we probably started from a different position when we were looking at legislation maybe four or five years ago, but we accept that that is a valid process. But we do think that the Bill as it stands leaves too much discretion and doesn't—. There needs to be clearer wording and more conditions set on this. We do welcome the reference in the explanatory memorandum to the WHO guidelines, but we do think it's necessary to reference it on the face of the Bill as well, to ensure that, when we get to the regulatory process, they are set on sound science and are ambitious enough to meet the need. The WHO have undergone a really rigorous assessment of the health effects, and found impacts at levels below previous guidelines, so it is important that legislation and policy is evidence-led, is based on the most recent rigorous evidence, and that is the best there is.

So, the Minister's arguing that we don't yet know whether it's possible to achieve the WHO guidelines everywhere across Wales, and by when this could be achievable. This seems a bit of a weak argument to me, and I wonder if that's something that you've had the opportunity to rehearse with her.

No, not directly, but it's an argument that's often made when we're talking about targets. I remember when we were setting recycling targets for Wales—they were thought to be too ambitious, 'There's no chance of getting to those', and then, here we are, we have. The same with the climate change targets; the last environment Act, when we were involved in that, they were set, 'What's realistic for Wales to achieve?', and actually, we've gone further, and we've already had to review those. So, sometimes, you have to set the target in law for it to become achievable and to drive that change across the public sector in Wales.

I think Huw wants to come in on this as well.

Yes. Sorry, Jenny.

No, it's all right.

On the WHO targets, you're looking, I suspect, for something that would set out that it has to be compliant with WHO targets as the science emerges as they change. There's a clear difference between that and 'having regard to'. The reason I flag that is that, within the Bill also, of course, there's the ability, the Minister is taking the powers to vary the targets in accordance with whether they are achievable socially, economically, environmentally as well. And there are good reasons for doing that. So, if you bolt on—. I'm just playing devil's advocate. If you bolt on that you've got to be compliant, whatever legal words you use, that blows out of the water the ability to be flexible.

There are lots of different ways that we could achieve this with amendments to the Bill. We could say, 'Setting targets in line with WHO guidelines', or, 'In line with the latest international guidelines', if the Minister, I understand, isn't keen on naming organisations in legislation, although I don't see a problem with it personally. But there are different ways around, and then there is the flexibility of reviewing the targets. But I think we do have to take a strong stance, that we're talking about nearly 2,000 people a year dying in Wales because of air pollution—this is an urgent issue, it's an issue that we have to tackle, and we have to be ambitious, and we've got a duty to the people of Wales and to future generations to do that. And having a reference to the WHO guidelines would be, in our opinion, the best way to achieve that.

Sorry, just to push back a little bit—I get what you're saying, but you could have that reference by something like 'have regard to' a law, and that's well understood legal terminology, although some would say that's slightly weaker, 'to have regard to'. But 'have regard to' does mean, in legal terminology, 'you have to take account of it', but you can flex. So, would that be sufficient? Sorry, I'm asking you for a legal drafting opinion here, but it's important for us.

There are wordings that are stronger than 'have regard to' but it doesn't say on the face of the Bill the target set will be WHO guidance. I think we wouldn't push for that exact wording. So, I think there's somewhere in the middle that we can meet that's stronger than just 'having regard to' but does take into account the societal, the environmental context in Wales. 

Obviously, these WHO targets and guidelines are health-led guidelines, so we would normally defer to our health colleagues rather than us as environment. But we would acknowledge that they are based on the best science that is around globally, so they definitely need good consideration. 'Have regard to' may well be strong enough in legal terminology. I think one of the things we would highlight, though, is that certain pollutants obviously have trans-boundary impacts, or coming in trans boundary, not just from local. So, the WHO guidelines don't necessarily take account of the conditions that we would find in Wales, and we would need to make sure that that was properly assessed in setting the targets rather than just blindly going with WHO. 

And based on your arguments—sorry, Jenny—about things such as biodiversity and nature, it may not only be the WHO we need to be looking at, as well; it's other leading international setting of good standards [Inaudible.] the science is. Okay, thanks.

Yes. I agree. 

Okay. So, it makes good sense, I would argue, to set the targets in regulations, because then you can strengthen them when new information becomes available. But, at the moment, there's no requirement on Welsh Government to consult with stakeholders prior to setting targets. How important do you think it would be to put in the Bill that the Government must consult on targets in order to get the considered advice of experts?

Before you answer—and forgive me, because this is all so important—if I could make an appeal to you for slightly briefer answers on some of these points, because we've got so much to get through. But forgive me, I know that this is all very important, but it might be that there are some more detailed points that we'd like to press with you, that we might follow up in writing, but if I could ask for slightly briefer answers. Nadia.

I'll speed up.

I'll just give a very brief answer: yes, we think stakeholder engagement is very important. 

Oh, I didn't mean for it to be—. [Laughter.]

Okay. So, at the moment, the Bill gives the powers to Welsh Ministers to revoke or lower targets, and whilst I wouldn't have concerns with the current leadership, Governments change, so surely this is a get-out clause. 

I think it's fair to say that we can't imagine a scenario where we would want worse air than what we've decided is needed in the target, by regulation. We do accept that the review period—that is welcome, that things do develop, and the five-yearly cycle seems to make sense for that, but we don't—

Forgive me, Haf, I think Jenny Hawley wanted to come in as well. 

Hello, Jenny Hawley. 

Hi. Yes, sorry—it wasn't specifically on that point about revoking or lowering targets, although, obviously, it would need safeguards against that. But just on the stakeholder point, I would agree absolutely that stakeholders should be consulted and that would be part of the way of engaging stakeholders in taking action to help achieve the targets. 

And just while I've got the floor, just to mention there is a global target on nutrient pollution now as part of the global biodiversity framework that was agreed in December last year, and that target is actually very ambitious, which is to halve excess nutrients in the environment by 2030, which is a massive target. Those nutrients—we think about nutrients in water, but it's the same for the air. So, ammonia, but also nitrogen dioxide can also have the same effect on wild plants and fungi. So, yes, those are all nutrients in the atmosphere that affect the environment as well as public health. So, I just wanted to mention that global target. 

Okay. I'll stick with you, Jenny. This is my last question to all of you, which is: how adequate are the current arrangements for monitoring and reporting air quality data? Because this is key to ensuring that we don't just have words on the page, we actually have action. Do you have anything further you want to say on that? 

On monitoring and reporting?

Yes. Perhaps it's not so much your area of expertise, because you're presumably—. Your organisations are involved in gathering data, are they?

Not specifically. On a few individual sites of our own nature reserves and some of the sites of special scientific interest, but not in the broader monitoring programme. In terms of ammonia, that could be a much stronger monitoring framework, and if we had a target, hopefully, that would drive that change to come through. The reporting at the moment, as far as I'm aware, is only, really, at a UK level to the EU, so, obviously, that would need to change and we would need to be reporting within Wales. A target, again, would be the driving force for that. 

Okay. So, NRW, obviously, you have a big role in all this. We're clearly not meeting the nitrogen oxide targets. How can we strengthen the monitoring in order to enable us to identify where we've got to put in more activity?

One of the things that are alluded to in the Bill is an enhanced monitoring network, and I do think that that is something that is going to be important for us to deliver. That said, I don't think that should slow us down from going ahead with some of the initiatives to reduce pollution. What we have already with the monitoring across Wales, especially for the human health pollutants, such as PM10 in particular, PM2.5 maybe less so, but nitrogen dioxide definitely, is sufficient for us to be able to also use air quality modelling in order to get the picture across Wales of what these levels are likely to be. So, I think, initially, that should be enough for us to identify where we need to target our efforts in reducing pollutants such as nitrogen dioxide and particular matter.

But it would also be beneficial to have that enhanced monitoring network, because the more data points you have, the more monitoring points you have and you feed that into the models, it makes the models more robust and it gives us a more realistic picture as we move forward. But, as I said, we shouldn't wait for that to happen before we start putting some of these initiatives in place.

Okay, thank you. I think I'll hand back to the Chair.

Thank you, Jenny. That's great. We'll move on.

Diolch, Cadeirydd. The Friends of the Earth submission there suggests that there should be more focus on being more prescriptive about the duty to promote awareness about air pollution. Can you expand on that a little bit? What would you like to see?

Yes, certainly. We're really pleased to see the section in the Bill, that it's an active duty and that it applies to all Ministers, so it's a good section to have in there. But we do think it could be strengthened. For example, looking at the report to prevent future deaths, which was the coroner's report following the tragic death of Ella Kissi-Debrah, it refers to the role of medical professionals and the importance of air pollution alerts for vulnerable groups, so preventing harms through—. It's going back to you need the monitoring to be in place, but then you also need alerts to inform the public. So, we do think there could be references to these in that section as well.

Public awareness is essential to avoid harm in that way, but also to get buy-in and acceptance for changes that are necessary, because this is strongly linked to behaviour change. People can make a difference in the way that they travel and live, and need that information on cleaner, greener ways to move around. So, we do think that that section could be bulked up and the references you made earlier to active travel, of course, are key to that as well.

Yes, really interesting. So, there's the reactive aspect of it, where there are significant issues with air pollution on any given period and any given day, but there's also the positive thing of promoting awareness of air pollution. Do you think we're close to the point where we have something similar to what we've been doing with flood alerts over recent years, where neighbourhoods that are particularly affected by repeated air pollution problems, where residents are made aware on mobile phones and so on, to say, 'You have issues today', et cetera. Should that be part of it?

We believe it should. It does go back to the monitoring issue, and if that information is in place, and then it’s a question of technology and finance, of course. So, there are financial implications to this, but it is possible. There is technology that has been developed, and I think it’s something that we should definitely be looking at and prioritising. And I wouldn’t expect to see that level of detail on the face of the Bill, but I think it would be worth while exploring it and getting commitment to that in Wales as part of this process.

That’s great, thank you. Could I just open up to all of our witnesses today the question about whether the duty to promote awareness about air pollution should be extended beyond the Welsh Government to the wider public sector? I can see you nodding, Haf. Do we have any other—? I can see on the screen as well, nodding that it should be extended beyond just Welsh Government.

Yes, and I think we would agree with that as well, especially where local authorities and local health boards are concerned, because they will have that local knowledge and also that relationship with the local communities, and be able to disseminate that message in a more efficient way and a way that’s geared towards that community.

Good, okay. There’s no dissent from that, so I think we can probably—unless somebody wants to add anything. No, we can move on, then.

But I think also, to just add: to extend that to awareness about agriculture as a source of pollution that affects public health and the environment, because I think the more farmers and the farming communities are aware of that as an issue and the contribution that they’re making to the damage to public health from air pollution, then that will drive them to be taking action and to welcome action by the Welsh Government and NRW to support them.

I wonder whether we could ask you to submit to us, after this session, any ideas you have on how that would practically happen and who would be the agents of disseminating that information amongst the farmers and the farming community and landowners. That would be really helpful. Thank you.

Thank you. Do you think the Bill should include a requirement for the Welsh Ministers to report on progress towards delivery of the clean air plan or strategy? If so, how often should progress be reported?

Shall I take that first? Yes, I think the reporting of progress is always going to be imperative, obviously, to show that we are on track. It’s difficult, because trends in air quality don’t happen that quickly, so it is debatable how often you would want to report. I’m thinking kind of a minor annual report, but then a more significant report maybe every two to three years, when the trends are established a bit more. We’d see that as a sensible way forward.

And just to pick up on that sort of timeline as well: that fits as well with the clean air plan commitment, so the review of that. So, the suggestion would be halfway through any clean air plan period, so that the trends and the data that are gathered at that point can inform where we need to go with the subsequent clean air plan.

Thank you. And can you expand on your concerns about the way provisions in the air quality strategy, which seek to amend the UK Environment Act 1995, are drafted, and outline what changes you think are needed?

Haf, do you want to go on that?

Shall I come in on this? And just on the previous question: yes, we agree that we do need a timetable or at least a minimum reporting requirement on the face of the Bill.

And then, on the national air quality strategy, we are satisfied with the intention of the Welsh Government and the intention of the Bill as drafted, but we do feel that it’s quite complex, the way it's been drafted, in that sections of this Bill seek to amend sections of the UK Environment Act 1995, which has been amended by subsequent UK Acts. I’m not a lawyer, and it might just be a little constitutional quirk that I need to put up with, but I feel that we’re quite early on in establishing a body of Welsh law—this is the first clean air legislation that we’ve got—and it makes it much more complicated if we’re referring back to previous Acts and to UK Acts. So, our preference would be, if it's possible within powers of course, that there is Welsh legislation that can be read through, rather than referencing UK Acts, which of course, could be changed by the UK Government or Parliament with unforeseen consequences for this legislation as well.

I think it was reported in the media just yesterday that, as a result of the Retained EU Law (Revocation and Reform) Bill, the duty to have air pollution pathways in England might be part of those provisions that are to be scrapped. So, I think there are unforeseen consequences to our constitutional situation of referencing UK laws rather than having clean little sections ourselves. So, we'd prefer that something like section 22 on soundscapes, which is setting a duty to have a strategy—. So, yes, that would be our preference, and we'd be interested to talk to lawyers and see what is possible.

And would there be any resource implications if NRW were subject to the new duty to have regard to the air quality strategy?

Obviously, we have a permitting and licensing role where we have to take account of air quality, and also we provide statutory advice to planning authorities, so we would have to obviously amend our guidance and our position based on the new legislation. So, there may be some additional resources required, but we haven't scoped up in any detail what that might look like at this point. 

Thank you.

Sorry, I should add as well, for fees and charges, we have fees and charges for our permitting, so we may be able to add those into our fees and charges scheme, but not for our statutory advice to the planners.

Okay.

Thank you. I'm going to bundle some things together on local air quality management. What I'd like is to get your ideas as to how, currently, the regime around local air quality management is working and whether this Bill will provide progress there and improvement in any areas; whether the proposals in the Bill will lead to any changes in working arrangements; and also, your thoughts on extending the application of what's in the Bill beyond the hotspot areas to wider areas, including what you've touched on before, which are the agricultural issues as well. So, rather than answer those one by one, I'm going to bundle them up and just ask for your contributions on it. Who'd like to start?

I can make a start on the bundle. So, it's recognised in the explanatory memorandum that the current local regime isn't particularly effective, and we do welcome the changes and that it looks at the broader, local view of air quality rather than a patchy approach or just focusing on known hotspots. 

We do have questions about how the local and national cycles of reporting fit together under this Bill—so, some questions around that. We don't want to replicate problems of having local and national systems. So, hopefully we can get clarifications on that, and also issues around adequate funding for local authorities for monitoring and for improving air quality. 

Brilliant. Anybody else? Jenny, did you want to add anything to that?

Yes, thank you. Yes, absolutely, like you said before, to take into account the agricultural emissions and other emissions outside those hotspot problem areas, I think. There is a need for those broader air quality plans, but really for those to be joined up, I think, with other local plans for climate change mitigation and adaptation, for nature recovery, for woodland and tree planting or whatever—so, to have that real joined-up approach at a local level to try and find the win-win solutions, where you can improve air quality and reach some of the other goals that the Welsh Government and local authorities are trying to reach. And, like I said, the current system at a local level doesn't take into account the impact on the environment and biodiversity or the agricultural sources of pollution. So, yes, that broader approach will definitely be needed to take that into account.

But you're specifically advocating in your suggestions for clean air zones for nature and rural ecological air quality management zones as well. Based on contributions earlier in this session, I understand the rationale for that, but is this the appropriate legislative vehicle, do you think, to do this?

I think it's probably quite a new idea, and I think we just need the air quality, the narrative and the thinking around air quality, to move beyond the public health or the transport issues, which are obviously—. I'm not disputing that they are incredibly important as well, but there's this bigger picture on air quality that this Bill doesn't really represent. So, it is a missed opportunity, and maybe there could be some provision in the Bill to require the Government to look into how to extend that local air quality management regime to take into account the agricultural sources of pollution, and the impacts on biodiversity and ecosystems, and, then, that would pave the way to explore some of these other policy options of what that might look like. Because we do have these hotspots for air pollution in rural areas. We know there are clusters of intensive poultry units, for example, which have this cumulative impact, which is not always taken into account by local planning authorities.

And we also have areas of Wales that still have quite clean air, obviously, and have some of our best, internationally important wildlife sites, and it's becoming really imperative to protect those, to create these clean air zones around those sites, so that you can't have new sources of air pollution developing in those zones. So, I think there's lots of potential to apply the kind of thinking that's been taken in urban areas, and apply that in the rural areas, with biodiversity and ecosystems in mind. And perhaps the Bill could drive the Government to be picking up that issue with more urgency. 

Okay. If you have, amongst your members, any further detailed thoughts on how that might be addressed through this Bill, I think the committee would welcome receiving them.

Okay, thank you. 

Just very briefly—we're really up against time, I know—I just wondered, from an NRW perspective, do you see any changes to working arrangements that will impact on you as a result of the Bill, in terms of the local air quality management issues?

I think, supporting what Jenny's said, I just want to iterate that we'd be supportive of broader air quality plans, and that should, in our view, give an opportunity to actually identify potential air quality issues and prevent them becoming exceedances. As with the current air quality management areas, we're concentrating on where we found exceedances, whereas a wider plan would enable us to stop getting to that point, so, therefore, to be preventative. 

From our perspective, we work with the local authorities, not only in the air quality management areas, but across the air quality spectrum, through our regulatory role in controlling the emissions from various industrial sectors, including intensive farming. We've heard intensive farming mentioned a few times. That will continue. It may need to broaden if the air quality areas and the air plan cover a broader area, and also if that plan identifies areas that we weren't aware of previously as potential hotspots on air quality. I think, fundamentally though, it would be mostly the same type of interaction as we have now. We haven't evaluated how much extra it would mean, but it is the same working together practices that we would employ.

Right. 

Thank you for that. We are, as Huw is aware, really up against time. I'm going to propose, if it's all right with witnesses, that we run until 10:45, but we still have quite a lot that we need to try and get through, so I'm going to make an appeal for as brief answers as possible, please. And I appreciate that we will be needing to write to you seeking more detail, and we really appreciate the detail that you're giving us. Janet, we'll go to you for smoke control. 

Do you think that proposals on domestic burning should be included in the Bill, and what are the risks of them not being included?

We would like to see definite proposals on domestic burning. We do understand that not all of this requires primary legislation, that there are powers the Welsh Government already have or related behaviour change that can be implemented in different ways. I think our request would be that, if not here, can the Welsh Government set out what its proposals are to achieve this in different ways, for example proposals for moving away from domestic solid fuel burning. We do accept their argument that maybe it's not necessary for legislative reasons to include it in the Bill, but we would like to see their proposals for achieving that as part of the scrutiny process, as part of the discussions, because they are urgent. 

Can I declare an interest at this point? I've got a log burner. In fact, I've got two. [Laughter.]  

Is it on your register of interests? 

Now, there's a thought. Do you think it's feasible, out in rural communities, where people have to rely on alternative fuel, if you like, if they're off the grid or the main track—? What kind of action would you like to see? 

We would like to see some bans in place, but we do accept that there needs to be support for households who actually rely on these sources, as well as bans on wet wood, so that it can be more subtle—

I can understand the wet wood, because that's very unhealthy. 

Exactly. It can be more subtle. So we can have absolute bans on certain fuel sources, and then a different timescale for communities and for households where it is the main fuel source, and support for moving away from those sources. 

There's a trend, at the moment, also, of outdoor living, when we do get nice weather, because very popular now are these portable barbecues, and pizza ovens are all the thing now. You can buy wood pellets and things like that. Would you be looking at banning those?  

Again, as you suggested, the source of the fire is really key on this, so I think there's a lot of work that needs to be done in this area—

So is it more about education?

It's probably about a combination of banning the worst pollutants, educating and innovation. 

And what do you consider the worst pollutants? 

Well, things like wet wood, of course, and coal, I should say, as we're known for campaigning against coal sources. 

I agree. We don't want people burning wet wood. 

But I'm sure there is some innovation—linking it back to the monitoring and when there are peak periods or areas where it is impacting health, like residential areas, where it is having an impact and shouldn't be allowed. But we would like to see more detailed proposals from the Welsh Government on how this could be introduced. 

And what about people having home bonfires and things? You don't see them as much. When I was growing up, you often saw people burning their rubbish and things. But now, I think, they warn you, don't they, if you're going to have a fire in your garden, to contact the fire service as well so that they know and they're not going to get lots of calls coming in. But would you look to ban people burning rubbish? 

I think we have moved a long way from those days, and people are much more responsible about what they do with their waste and it's more about recycling and reuse now. I can see, Chair, you're concerned about time. 

Forgive me; I'm so sorry, but because of the time, we're going to have to move on. I'm so sorry. We're going to move on to Joyce with the trunk road charging schemes.   

It is what it says: trunk road charging. Do you agree that the Welsh Ministers should have expanded powers to create charging schemes for trunk roads to tackle air pollution? 

Shall I start on this as well? I'll make a start. We do support the powers that are in the Bill. We note that the Minister has indicated, so far, that she has no intention of using those powers. There are currently the 50 mph restrictions on five trunk road locations. I think we'll have to see if that is sufficient to meet the new targets and keep an open mind as to whether more action is needed and whether this will be necessary. We think it's a shame that, because of legislative competencies and how things are split, this does only apply to trunk roads, and we are a little concerned about unforeseen consequences—for example, if there's a charge on trunk roads, that that just displaces vehicles onto more residential roads. So, I do think we need clean air zones and city-centre clean air zones and road-use charging to be co-ordinated and to be seen as part of the full picture to avoid unintended consequences. That would be our only concern. But we do welcome the powers under the Bill.

In NRW's paper—I know you were about to speak, so you can put the two together—you said that there should be a more regular review on the pollutants in the air, when we're talking about clean air. If you put together the trunk road charging and then if you put together the monitoring and the fact that those pollutants might have changed—. You then said that there should be a requirement for the impact of the clean air zones to be monitored and reported on. I know you've alluded to this in previous answers, but in this specific area, what do you think the thresholds and the criteria should be, bearing in mind what Haf has said and what many other people have told us?

Can I pick up the first bit about the powers, and then I'll pass over to Eirian, I think, if that makes sense? We're fairly neutral on the charging powers discussion. I think what's important, as Haf said, is that we avoid the unforeseen consequences of moving people away from those trunk roads and look at what those alternative measures for reducing pollution could be. Really, it is a bit of a carrot-and-stick argument sort of thing—you don't want to impose the stick without the carrot being in place. Until the public transport systems, for example, are adequate to provide a service and deal with inequality arguments as well, we wouldn't really want to see charging—. It's which one comes first. We'd rather not see charging coming first ahead of the improvement measures being in place. I'm going to let you tackle the other bit, sorry, Eirian. [Laughter.]

Joyce, the other bit was around targets, was it, sorry?

Yes, and the thresholds, the criteria and the monitoring.

The thresholds, yes. The thresholds in terms of the levels of pollutants—

Yes, should they be set out?

I think that's where what we've talked about already in terms of setting targets not only for PM2.5 comes in. Haf has mentioned setting the targets for nitrogen oxides, which, around trunk roads and transport in general, is very much a key pollutant that does have an impact on human health, especially in terms of asthma and so on. So, in that respect, I would see the targets that are being set as key to what the monitoring would be aiming to achieve. As time moves on, and we learn more, we are achieving the targets routinely, then there's no reason why targets can't—. It's a continuous improvement, so targets can be lowered with time, as well. So, I would see that monitoring based on the targets that would be set as part of the Bill.

The other thing we're interested in is that, at the moment, if you do have a charging scheme, there is no ring fencing for those moneys to be used on improving this particular area, but they can be used more widely. Do you have any views on that? Do you think it—? Or if you don't, that's fine.

I think from a public perception point of view, as much as anything, if there is an opportunity to ring-fence, that's always—. It's the cause and effect. You can see the benefits of where the money's then going to be spent, rather than it just going into general coffers. So, I think if there are means to do that, we would definitely support that.

We'd support that as well.

Okay. I think that's it.

I just wanted to pick up with NRW the point about not introducing penalty notices until improvements to public transport and active travel infrastructure are in place. However, in the case of vehicle idling, I just want to make sure you're not arguing that we should wait for imposing penalties on that. You wouldn't argue that litter is allowed when there's no bin.

We'd not argue against that specifically, but, equally, we're not the enforcement body for that either. That would be local authorities. But no, we wouldn't be arguing against that specifically.

Fine, thank you.

Great. We will go to Huw on soundscapes.

That’s brilliant, thank you. On soundscapes, really it’s just a broad question at this moment in time about your views on the provisions relating to soundscapes. We’ve heard some interesting evidence, so do you have any thoughts on this from an NRW perspective?

We welcome the soundscapes being brought into the Bill and being included as part of the Bill. We’re conscious that sound can also impact adversely on people’s health, and it’s important that it’s brought in. There are synergies very much with air quality as well. The types of activity that produce air pollution also have inherent noise associated with them, so it’s useful that they’re both being brought in to the same Bill, so that we can have a holistic view on those. And in some respects as well, the decarb agenda also comes into that picture as well.

Do you see any potential positives here from the nature and biodiversity perspective of promoting positive ambient soundscapes?

I think that is definite. Because disruption of species can occur due to the noise environment, and therefore, that will inevitably help where biodiversity is concerned as well.

I'd support that.

Yes, Nadia supports that. Haf or Jenny?

We’re staying out of this one. We haven’t looked specifically on the soundscapes element of the Bill, so we’re focusing on the clean air.

Okay.

To back up what was just said about the impacts on biodiversity, there is good evidence that many species are affected by noise. So, yes, we welcome this part of the Bill, and obviously then reducing human noise pollution will allow people to enjoy the sound of the natural world, the birdsong and so on, which is very good for people’s health and well-being as well, so we welcome this. Thank you.

That’s great. Any other thoughts you have on that as the detail proceeds—. Because it’s certainly come forward in evidence to us already that some of the benefits of better public planning policy on soundscapes could also be used to promote wider nature biodiversity as well as quality-of-life issues and well-being. So, anything you have as this goes forward would be really welcome. Thank you, Chair.

Diolch. Congratulations, everyone, because we did manage to get through just about all the questions, so thank you for that. A transcript of what’s been said today will be sent to you to check that it’s an accurate recording. As Huw said, there will be some areas that we might want to raise with you in writing that we weren’t able to get into quite as much detail as we had hoped to, but everything you said has been incredibly helpful.

My name's Kristian James. I'm a chartered environmental health officer, and today I'm here to represent the Chartered Institute of Environmental Health. Thank you.

Thank you so much. And, Colin, could I ask you to introduce yourself?

Hello, everybody. My name is Colin Cobbing, and I am a chartered fellow of the Chartered Institute of Environmental Health and also a fellow of the Institute of Acoustics, but I'm here today representing the Chartered Institute of Environmental Health.

Thank you, both, so much. We'll go straight into questions, if that's all right, and I'll go first to Janet.

Thank you, Chair. Good morning. Is the Bill, as currently drafted, sufficiently ambitious to lead to significant improvements in the quality of air in Wales and soundscapes, and if not, why not?

Okay, thank you. Well, first of all, we're very grateful for engaging constructively with us and we think it's great that Welsh Government is taking this subject very seriously. We have to remember, with a Bill like this, it needs to become a flagship and a beacon for action. We already know a great deal about air quality. We know it's harmful to health. We certainly need to reduce it. We know what causes it and we know some methods of trying to reduce it. So, the Bill needs to be ambitious. It needs to not unintentionally delay action that's already in place to try and address air quality—there are good actions in place that we need to do it. What we don't want to see is delays because of the well-intended but technical nature of the proposals, gathering more and more evidence. We don't want to distract from actions that need to be taken. So, we have an opportunity to be ambitious, but we don't want it to stymie work that's already in hand.

Thank you for that. 

Thank you. Any my next one—

Oh, quickly—Janet, forgive me—Colin, was there anything you wanted to add?

Oh, sorry.

I'd like to mirror what Kristian said, and would like to applaud the Welsh Government for its efforts in aligning noise policy, soundscape policy, with air quality. In doing so, it really cements your position as leaders in this field, so congratulations for that.

As for as the ambition—and I'm mainly speaking to noise and soundscapes today—it's great that you're setting in place the process for developing a noise strategy, but, from my perspective, I think you can actually make that element a bit stronger if you adopted objectives for noise and soundscapes in pretty much the same way as you plan to do for air quality. I note that, as the Bill is drafted, it doesn't have the same target-setting process as it does for air quality, and if you wanted to align them and strengthen them even further, I think that could be a good starting point.

Thank you for that, Colin. The committee is a cross-party group of representatives from different parties, but we can certainly pass on the comments that you made to the Welsh Government as well. And they will be monitoring what's happened today, so those points will very much be on the record, so we really appreciate what you've said there. Back to Janet. 

Thank you. Do you think the Bill adequately balances improving public health and maintaining and enhancing nature and biodiversity?

Okay, I think it's extremely well intended, the Bill, but—

There's a 'but'. I knew there was a 'but'. 

—what we need to make sure is that it fixes some of the issues that we're already experiencing now. For example, the current air quality standards, as applied for the last years, tend to be a level of pollution that people want to pollute up to. So, you might have a level of pollution in an area that might be very good. The current objectives may be higher than that. So, in the planning and permitting process that you may have already taken evidence over, there's an incentive or an unintended consequence that you'll keep polluting and polluting up to. So, what we need to make sure is that the new Bill strikes objectives and standards that drives down and changes that narrative, to take away the perception to increase pollution, to try and drive it down. 

One of the benefits of tackling both air quality and noise, and air quality generally, is that this has co-benefits. And I'm sure you've heard the benefits of tackling things like carbon reduction, increasing active travel, for example. One thing we've mentioned in our submission to you is the need to consider agricultural pollution as well, because we know that the chief sources that we're more familiar with are traffic and domestic burning—that, I'm sure, we'll come to later—but, also, we need to be aware of the agricultural contribution to air quality that might, until now, not have been given the attention it might need. So, in that case, if enacted, and action is taken to further restrict emissions from the agricultural sector, then there will be co-benefits to the natural environment too. 

Can I come back to you on something? I hope you don't mind me asking this question. When I was growing up—and I grew up in areas very close to many farms and things—as children, we were told, especially if there'd been muck spreading, 'Oh, it's good for you, good for your lungs, take a deep breath.' So, now is it classed that that kind of activity could be harmful? 

Well, agriculture has always had spreading, as you well know. From my professional experience day to day, working in Wales, we do get enquiries more about the nature of intensification of farming. I'm sure you've heard more about the intensification of agriculture, and about poultry farming, and the shift towards—

The ammonia side of things. 

That's correct, yes. So, you'll find that there's a threshold in permitting, which you may have had evidence of this morning, below which you don't need a permit; you might not even need planning permission. So, what we are seeing is the increase in muck that's available and, therefore, that becomes an issue in itself—how do you distribute that without having negative impacts? Now, odour is a health impact in the sense that it affects well-being. It might not affect you necessarily physically; some chemicals will. But odour can upset your general well-being, especially if it's not something you're used to, as well.

Janet, forgive me, I think Joyce wants to come in on a supplementary here.

Thank you. Yes, I've taken notice of poultry units, particularly in Powys, for example, and what you just said is that, below a certain threshold—. But there's an accumulation effect along riverbanks. So, if you were going to say something to us that we could then pass on to the Minister, do you want to elaborate on that accumulation effect and how this particular Bill, if you think it's the right one, could address that impact of ammonia? Because that's what we're mostly talking about.

Okay. Well, I'm not an expert on nitrogen in watercourses. There are other people who are more expert than I on that. My observation is from a professional view where I receive planning applications or enquiries from the public, or permit applications—this is in my personal professional role, where I'm seeing more enquiries about the level of manures. So, if you have manure, you have to be able to spread it, and that's a practical problem. There has to be enough land to receive it, and there has to be enough mechanisms to receive it, and it has to be the right weather, for example. But I'm straying into an area now that is practical farming, and I'm not a practical farmer, I'm sorry.

Okay. So, is there a particular recommendation, from what you said earlier, that you think we could make?

Well, I think the recommendation we have as the CIEH is that we need to acknowledge that agriculture is a contributor to air quality and that the issues around air quality are a symptom of other things, which might be the manure management, which is beyond my specialism, but this is where we start to tackle co-benefits, isn't it? If we know that air quality is an issue and it's arising as a symptom of a practice, then addressing that practice will have co-benefits.

Thank you.

Okay. Diolch. Janet, was there anything else you wanted to ask on this?

No, I've asked them. Thanks. 

No. Okay, great.

Good morning. You've made some coherent arguments about agricultural emissions being responsible for more than a quarter of particle pollution in cities, and that is not always appreciated. We heard cogent evidence from the environmental organisations earlier this morning certainly that ammonia and nitrous oxide should be included in the emissions. You seem to be arguing that these are really important issues. So, I just wondered if you wanted to add what impact that would have in terms of improving public health.

I think it's the area that's least understood and explored, perhaps. And I think, in the working groups that the Welsh Government have set up to look at source apportionment—where these pollutants come from—we need to acknowledge more the contribution of agriculture, given its significance in Wales. We want good farming, we want sustainable farming. We tend, usually, to think about pollution as being urban, and clearly it is, and we've got issues around wood-burning stoves, which I presume we'll come to later, and the traditional traffic sources. But our CIEH view is that we need to make sure that agricultural sources are not lost in this wider perception of pollution that it is just from traffic and burning. It's a sector we need to pay more attention to.

Okay. So, could you just expand on your point that once ammonia mixes with industrial and transport emissions, it increases the levels of PM2.5 in the air, because that's not something I was aware of?

Yes. This is a phenomenon that makes it also sometimes trans-boundary as well. We know that PM2.5 can be influenced by activities on the continent and from Ireland, and we know that from evidence that you will hear from other experts as well. It can travel, so it might be exported from the countryside to the towns and cities, and we've provided evidence in the submission where we know that's the case.

I think that Huw wants to come in on this point, if that's okay.

Yes, and I hope I'm not overlapping on something that Jenny might come to now, and I don't want to put words into the Minister's mouth, but I suspect the Minister might well say that there's a valid point about incorporating these other aspects into it, but this Bill probably isn't the place for it and we don't have the data and the knowledge yet of quite how to apply it. So, what would your response to that be? Put an enabling power within this Bill? Put something within this Bill that refers to it, even if you haven't got the detail?

Yes. Essentially, we believe that it needs to be considered as a third source, at least, of significant pollution in Wales, and therefore tackling it can be a practical issue. It's the best available technique—a term you might have heard about in previous evidence—about how to best manage. At the moment, that might not apply to certain agriculture that's intensified because it fails to meet the pivoting threshold, and it might not need planning permission because it's an existing farm. So, I think it needs—. In an Act that's intended to be ambitious like this, I think we would be unwise to not acknowledge that, and therefore we've given lots of attention to wood burning and traffic—quite rightly, too; it's a missed opportunity if we don't include reference to agricultural sources.

So, are you saying that they should be—? Sorry, I don't know quite what level of detail both of you have looked at this at, but are you saying that there should be a separate subsection in the way that there is also with smoke control, and so on there, that would specifically refer to agriculture land use management?

Well, that would be a way of highlighting it as a distinct issue, yes.

Okay, thanks.

Okay. Jenny.

So, given that you're asking for a nitrogen reduction strategy and for the Bill to adhere to WHO air quality guidelines, how satisfied are you that the target-setting process is sufficiently robust in terms of ambition as well as being achievable air quality targets?

Okay. Well, we know since the setting of the last air quality objectives that things have changed. The WHO guidelines have become the new best evidence that we have, so anyone involved in health protection, which the Chartered Institute of Environmental Health is, has to acknowledge that, and therefore that has to be the benchmark, in our view, as to what we should be aiming for. That should be the purpose—to drive down air pollution and not increase it unintendedly as it does now with the objectives. 

The WHO itself recognises that achieving such levels will be hard and tricky. We've provided evidence to suggest that levels of pollution can be reduced to the 2030 WHO levels perhaps sooner than is aspired to in other parts of the UK. We might be lucky in Wales that we have a landscape and environment that enjoys better air quality to start with, but that's not a reason not to drive down the pollution levels. So, we have to use the WHO guidelines as the benchmark for which to aim for, recognising that we probably could achieve lots of it in many places. There will be sticky points, I'm sure, in the future, and that's where things like the cost-benefit analysis that's built into the regulations and in the Bill ought to be helpful.

Obviously, there are pollution plumes from particular industrial emissions and also concentrations of illegal levels of air pollution in constituencies like mine—inner-city Cardiff. So, we're already not meeting the guidelines. So, the more stringent WHO guidelines, are they achievable? Because it needs to be ambitious in the Bill, but can we achieve it?

Well, we've submitted evidence and a paper that you can refer to subsequently where that's been—. I think it was a paper by University College London that explains different routes using current policies and practice where we think that will help that process along. My personal and professional view is that there might be occasions where that does get difficult and where the cost-benefit analysis will come down to just practical implementation, but at the moment, there is no drive for reducing pollution. At the moment, it's polluting up to well-intended previous objectives that have now really been superseded in terms of protecting health. So, there will be practical difficulties, but we need still the ambition to try and drive it down. So, in a debate locally through planning or permitting, there's a reflection of the urgency and need to reduce air quality, or improve air quality by reducing pollution.

Okay. Thank you for that. There's no requirement on the Welsh Government, in the way the Bill's drafted, to consult with stakeholders before setting targets. What role do you think consulting stakeholders like yourselves would have to support these more ambitious targets?

Well, the CIEH is made up of members that you've already had evidence from, people who are working currently on the front line of air quality. They're already aware of initiatives that can sometimes help to improve air quality, and some of the difficulties that we encounter. Currently, air quality management is very focused on hotspots of pollution and not the root cause of pollution, and this is a bit of a frustration. So, we've got all this time and effort of monitoring, we're finding hotspots, but the hotspots themselves are not the places where pollution is derived from; it's usually traffic passing through. So, it's the conundrum of dealing with the root cause.

So, using that expertise—and CIEH welcomes being part of that, as other members you've consulted with—yes, we think it's necessary, because we can give you the real life front-line interface experience between the science, the data, the public concerns. Because lots of environmental health officers deal with the first complaints from the members of the public, in local authority environments especially. We know how that interface plays, so we would welcome being consulted in these times.

Okay. So, at the moment, all the information that your members are gathering does or doesn't get fed in to Welsh Government—it just gets filed or—?

Well, members produce the air quality reports on a routine basis. They're sent to Welsh Government. It's incumbent, then, on local authorities, if they identify problems, to act, and often, that's where things get a little bit tricky in practice. There might be some quick fixes in some cases; there might be some practical difficulties in others. The source of the pollution might be beyond the local authority boundary, so I think there's an opportunity, then, in this Bill, to make sure that we are using what we're currently collecting in a more effective way.

I think—. 

Joyce.

Joyce, yes.

What this makes me think is that there's a need for an overview of planning, particularly if we look at routes—roads, particularly, public transport—and also a requirement that is going to be met by new housing or maybe a new hospital or maybe a new school, and cross boundary. So, if we have an area plan—we have local plans and area plans and national plans—would it not therefore—? And people like you would be involved at a local level, but not, maybe, other levels. Is there an input there for some thinking ahead? You know, we've got what we've got, but we're going to create something else, to involve planners—to involve people like yourself, sorry, in planning—would that be adequately addressed in this Bill?

Well, I'm absolutely of the view that health and environmental health should be engaged as a statutory consultee, as a minimum, in all such large developments. We may or may not have to contribute to all, but in ones where there are air quality issues or others, we need to be part of that process. I don't see any—. Well, I see the intention in the Bill to consult, but it would be important that we are listed as defined consultees, whether it's local authority, environmental health or other practitioners in different disciplines or organisations. Yes, it's vital, in my professional view. 

And is that the case now?

Health is not always engaged.

Okay. Thank you.

I think Colin wanted to add to this, as well.

Yes. I just wanted to add that, if we're talking about initiatives and interventions of improving health—health in the wider sense—we've got to take holistic views. [Inaudible.] One of the problems we've had is that, by looking at these things in isolation, you get suboptimal solutions. And when you're dealing with noise and air quality, there are opportunities, and potential opportunities, for improving both. But there are obviously tensions, in some respects, with some of the interventions. You know, there is a tension between air quality and noise. And, as environmental health practitioners, we are more than aware of the holistic approaches towards health, and we can provide, or our members can provide, invaluable contributions and input to the planning process. So, if you are interested in making improvements to public health, we would be a natural consultee, as Kristian has explained

Thank you.

I just want to—. Two more questions, really, from me. What's your view on the get-out-of-jail clause, to allow Welsh Ministers to revoke or lower targets in this Bill? Why would that be necessary, under what circumstances?

Well, again, I go back to the fundamental argument that, if you have any interest at all in protecting health, then you're going to have to defer to the best evidence, which is the WHO guidelines at the moment. That would be our default position. I've mentioned that, sometimes, there are practicalities around that, and cost-benefit analysis, et cetera, that is alluded to, but what we don't want is to lose that strength and link back to that strong evidence. Why decouple? It would be a backward step. Yes, I acknowledge that there might be practical difficulties in some cases, there'll be difficult decisions to be made, but the default position must be that we aim always for those targets.

Thank you. So, that takes me to the final area of questioning, really, which is on the gaps that there may or may not be for monitoring and reporting air quality data, and what changes would be needed to give the Minister more confidence that she can take less than three years to set PM2.5 targets, for example.

Okay. Well, I'm sure you've heard evidence about the practicalities of local authority monitoring, and there's a difference between what local authority officers do, who are mostly environmental health practitioners, and there are the Government schemes, then, that are looking at wide areas along trunk roads, et cetera. And you'll have heard practical issues around that, about resource management, and the need for monitoring. What I'd like to do, though, is make a fundamental point: we already know that certain pollutants are a problem, we know that there are no safe levels, and, therefore, we don't want to get too tied up in that. We know that the pollution is out there, we know what the causes are, and we know that we need to take action to protect public health. So, we need to be careful in how much more monitoring we need. Is it better just to invest in action? Why do we need more monitoring? Again, my personal professional caveat would be that we know perhaps a little less about agricultural sources in communities that are affected by intensification. It doesn't mean that air quality is bad, but, at the moment, it's assumed that air quality in rural Wales is good, and that it's modelled usually that it's good, but there isn't much practical monitoring on the ground, in my professional experience.

Well, I think the thing about rural pollution is it's not so much the impact on people as opposed to the impact on biodiversity, where it seems to be really significant.

That's correct, and it goes back to the co-benefits of managing, doesn't it—that it has benefits to the environment as well as to humanity.

Yes, okay. What comment might you have on the reporting requirements set out in the Bill as to whether they're sufficiently robust, to ensure that Welsh Ministers are held to account if they fail to meet air quality targets?

Well, I appreciate that there's been an adjustment, to try and marry the reporting regime into the more conventional cycles that you deal with, so that there's a time to interface reporting information in the decision-making process of the Senedd, et cetera. So, I welcome that that's an opportunity, so that people have got time to act on findings.

Fine. So, other than that, you think that—. Okay. I think I'll leave it there, as we're short of time.

Okay. Thank you.

Just a couple of questions, please, on promoting awareness about air pollution. And the first question is whether you think the Bill should be more prescriptive about the steps Ministers can take to promote awareness about air pollution, and, if so, what would that look like?

It's a good question, because, at the moment, we have interfaces that are public. I don't know the statistics around it in terms of people who access it on a daily basis, but there is very good information on air quality for lots of parts of Wales already available. I think that needs to be looked at, to see if that is effective. There have been experiments to try and alert people to local pollution hotspots that have sometimes worked and sometimes haven't. 

There are local initiatives that have been tried by colleagues at a local level to try and improve information on air quality. I think what we need to do is two things. One is that air quality can still be seen, or might still be seen, as a technical subject, and perhaps one of the things is that we need to think about addressing the sources again, and maybe air quality as a surrogate point, that we need to make sure that we're reducing traffic, traffic measures, why people will benefit from using the car less, and air quality will become reduced as a result of that.

Nevertheless, there are probably routes and mechanisms to improve knowledge about air quality. Not everyone’s connected to the internet, of course, so we have to be minded that there are other routes. I’m not sure how prescriptive we need to be, because we also need flexibility to deliver. I’m not an expert in media and public interfaces on that level, I’m sorry, but there’s always more that we can do. In the wake of the Ella Kissi-Debrah inquiry and evidence from that, there’s a clear need to explore how we can interface more, perhaps with the medical profession and people who are directly affected because of pre-existing conditions, for example.

Yes, indeed.

I don't have a magic bullet answer for that. I think it's—

No, no—it's fine. It just strikes me that, in raising awareness, there's one thing about the reactive raising of awareness of people, that there's a particular issue that you need to be aware about, but then it's that longer term awareness raising that helps to drive the change in terms of promoting active travel. I used to cycle every day along the Old Kent Road in London for 10 years, from Pimlico. That's probably taken 10 years off my life, because the cycling was healthy, but the particulates within that stretch—you could taste them in the air. So, raising awareness is a key thing. 

I think one thing we've been finding is that the evidence about impact has talked about deaths, and you're not likely to know someone that's died of air quality per se. 

Indeed, indeed. 

So, one thing that would be useful is to inform people that everyone is sharing the burden to some extent, even those of us that are healthy—maybe not so much as those that are already with pre-existing conditions, but we're all shouldering the burden of poor air quality. 

One thing that's specific to a type of pollution is the use of wood-burning stoves, and there’s probably a perception that they are ecologically friendly, and that people are doing the right thing for carbon emissions et cetera, and we would argue as CIEH that, in many cases, where you’ve got on-grid connections, having solid or wood fired burners is not desirable, or needs to be regulated—[Inaudible.]

That takes me quite neatly to the other question on raising awareness: it's whether the duty in the Bill to promote awareness should be extended beyond Welsh Government to the wider public sector—so, local authorities, health boards, other public sector bodies as well.

Yes, in my view, I think that's going to be useful to do, yes. 

Okay.

And I think Colin wants to come in on these questions as well. 

Yes, I'm going to come back to your comment about cycling down the Old Kent Road. One of the best things, or the most positive things, about raising awareness about exposure to air quality, or air pollution, is that you can influence behaviours. If you were to take an alternative cycle route so that you weren’t cycling along major arterial roads, and using less polluted roads, then that could help to reduce your exposure. So, that could be a significant benefit of targeted awareness, in helping people to change their behaviours in a more healthy and positive way. 

Yes, it's a very good point. And the practical realities of this is then the need to invest in that direct route, active travel routes. Because meandering through the parks of London is very pretty, but if it adds 20 minutes to your journey you're not going to do it. But it's a point well made that these things tie together. Sorry, Chair. 

No, nothing to apologise for. It's important. Colin, you wanted to come in.

It's an excellent point, and you could look at that as part of the strategy and this is where this combines with this holistic view of health. Let's start taking people away from major roads wherever possible, providing them with facilities to actually exercise and minimise exposure to pollution, and take a holistic view about all of those things. 

So could I ask whether you—? Sorry, Chair. Could I ask you, then, whether you would support something we've been asking in every evidence session—within the purposes of this Bill as described, the unfinished business of a duty to promote active travel? Because that was not in the original active travel Bill, curiously—a duty to promote.

Yes, I think. Yes.

Colin.

Yes. 

My work here is done. [Laughter.]

It goes to the fundamental point, that air quality is a symptom of things that we do, and, unless you address the root cause, then air quality will always be a symptom.

Yes. Thank you, great.

Thank you. Do you think the Bill should include a requirement for the Welsh Ministers to report on progress towards delivery of the clean air plan and strategy? If so, how often should progress be reported?

Okay. Well, I agree, yes, they should report, and report—

How often would you say that's reasonable?

Well, it has to take into account the acquiring of the data. I've mentioned about local authority requirements reporting on an annual basis, which is actually quite burdensome, but it's done routinely anyway. You have to take into account, maybe, trends—so, were there are exceptions in years? I'm sure you've heard evidence on the effect of COVID as something unusual. Is there a period of time that would reflect interventions that are already in place that need to bed in and work? Yes, I think it is a balance. I don't have a particular timescale in mind, but the sooner that is practicable the better. I'm sorry I'm not giving you a precise year.

No, no, it's all right. A suggestion has been around two to three years. Would you say that that seems reasonable?

Yes. I think that would address some of those points, yes.

And then—. Does—? No. Okay. Some witnesses have expressed concern that the duty for designated public authorities to have regard to the strategy is not strong enough. 

Well, I think it goes back to some of the points that we've already discussed about that there are certain key agencies that might be well placed to talk about air quality and promote awareness about co-benefits et cetera. It goes back to the planning processes as well, where we need to make sure that the appropriate people are engaged routinely and not just by the way, because there is a list of statutory consultees and those that are not, so some might need to become more on-the-books. From my perspective, the more people who are engaged the better. 

Okay.

Can we turn to the local air quality management approach? How effective do you think the proposals in the Bill will be in getting real, tangible improvements in local air quality? 

Well, the problem with current local air quality is—I alluded to it earlier—that it tends to look at monitoring where you suspect the pollution is going to be. You might have background monitoring for comparison purposes, but it's there to show how bad the hotspots are, in essence. So, at the moment, LAQM works just purely on a hotspot; it doesn't address everybody's exposure to air quality. If it goes back to the discussion about, 'We're all shouldering the burden', then what LAQM needs to do is address air quality for all. By doing that, you're also looking at being able to consider initiatives around new housing developments that may be in or out of town. It all becomes part of the overall burden reduction.

The expertise in LAQM is great, and I promote and support the technical ability and prowess of our CIEH environmental health practitioners, but it doesn't address the whole population. It's hotspot focused, so I think we need to address that in the Bill.

I'll come to Colin as well, in case he has any thoughts on this, but the resource implications for extending this wider, are they necessarily—? Does that necessarily mean that we have to double, treble, quadruple the resources in local air quality management to do it, or is it a sort of as and when new developments come along, looking at issues that came up in the previous evidence session about agricultural air quality within zones within rural areas and so on?

Yes. I mean, these are real operational questions, and I think it's going to have to be by local authority area for now, because that's where LAQM is practised, and that's going to depend on resources within each of the authorities and the current perceived needs of that community, so there are practical decisions being made there. I know, as a practitioner myself, and this is in my own personal professional practice, in austerity we were switching off monitors in order to maintain a half-post professional who could do lots of things, not just air quality. So, we've gone through a phase where the cuts have been immense.

Some local authorities will be well resourced because of historical links with academia et cetera. Others may be rural, who at the moment, perceive that air quality may not be an issue on their patch. So, I think it's a practical question. There are lots of facets to that, and I don't have the knowledge right here and right now to give you facts—you know, accurate quantities. 

But the approach should be to extend air quality management beyond hotspots and into a wider analysis—

The benefits in terms of health would be to do more for more. 

Yes. Okay. Colin. 

I think two points I'd make: in terms of local air quality management, I think that it's important that, if you're asking people to manage air quality in certain areas, they've got control and powers to actually deal with the sources, and, in my experience, that's not the case, as far as to deal with road traffic that's going through the areas and so on. So, the strategy's got to deal with the sources and appoint responsibility to those bodies and authorities who've actually got the powers and the provisions to deal with those sources. In terms of resources, what we're seeing across the CIEH, generally, is that resources within local authorities are becoming more difficult and far more challenging, and that affects their ability to implement air quality strategies and noise strategies. So, the local authorities have got a key part to play in all of this, but are finding that they're getting less and less resource to deal with it. Certainly, that's my experience. 

So, the Minister might well resist pushing too far on this, knowing that you can't adequately resource it. Why would you put it into a Bill if you can't actually promise either the levers to deliver it, but, secondly, the resources to deliver it? 

Well, that comes from having a strategy, doesn't it? So, you have a strategy, you set your targets, and then the proof of the pudding in the strategy is whether it actually delivers meaningful benefits. You've got to resource it appropriately to meet the requirements of meeting those targets and achieving the plan. The way in which I see it is you set targets, you carry out your cost-benefit analysis, you work out what your priorities are and you look at where you need those interventions most, and then you apportion those responsibilities, but also apportion the responsibilities where they're needed to achieve that plan. 

Yes. Thank you. 

What are your views on the Welsh Government’s decision not to include the following smoke control proposals from the White Paper in the Bill: to ban outdoor combustion, including bonfires, in smoke control areas; mandate the application of smoke control orders in all urban areas that meet specific criteria; and include a requirement for local authorities to review smoke control areas on a regular basis? 

Okay. Well, we, as the CIEH in this case, believe that there should be regulations around the control of smoke in urban areas, chiefly from the sources of wood burning. In air quality, we know that pollution will travel, so where would you practically draw the line? You could draw a line based upon people who are on grid and off grid. We also understand that there's a concern that by putting in smoke control and limiting wood burning that might affect people who are using solid fuels or alternative fuels because of the energy crisis et cetera. We can come back to that— 

Is it practical to try banning this kind of thing? 

We certainly need controls, at the very least. Controls come with the requirement to regulate. So, again, it goes back to the questions and issues previously: if you want these things to happen then there has to be an enforcement regime and a policing regime for that. 

Will that fall on local authorities, do you think? 

It would fall on local authorities, yes. 

Joyce wants to come in on this, and then we'll come back to Janet. 

You very briefly mentioned the equality part, because on grid and off grid is—. I understand where you're coming from; I cover most of rural Wales. But you did, very briefly, mention the cost-benefit to the individual in terms of—they've got a wood burner, they can't afford the gas or the electric. So, do you have any thoughts on how you deal with that? Because most people who have got wood have stockpiled it, and, because it's dry wood, they'll have it ready for next year and so on. So, what are your thoughts about trying to do two things: one, make sure people aren't adversely affected because they've got what they've got and they can't afford anything else, but at the same time trying to safeguard the air for all the rest? Do you have any thoughts on that?

It's a great and quite a complex question, fundamentally, isn't it? The view from the CIEH is that the evidence we've got is that installing a decent wood burner can cost £2,000. So, on that basis, you would have to argue whether it's really a cost-of-living issue for some? Is it just perceived as a luxury item, is it perceived as a nice thing to have, does it remind you of your holidays in the countryside or abroad? You have to argue, 'Why is it necessary in a built-up area where there are on-grid alternatives? What is the real justification for it?'

Going back to the inequalities, we would hypothesise that, actually, there are probably not that many in those circumstances where people are purely relying on solid fuel or these innovative alternatives, perhaps. We have to acknowledge that, but we have to acknowledge, at the moment, there's the energy crisis that's bringing its own health disbenefits. But we can't see it as a way of hindering the progress towards better air quality.

Okay. Can I—?

Yes, a brief—

Just very briefly, is there a survey that's been done? In Wales, we have the oldest housing in the UK, so a lot of them will still have open fires. We're not even talking about wood burners, they'll have been built over 100 years ago, and it's just if there has been work done on that, if you know of anybody who has done it and you're able to send it to us, that would be helpful.

At this point in time, I don't. It doesn't mean that has or hasn't happened, but I don't, at this stage, I'm sorry.

Okay, thank you.

Colin.

I just wanted to add one point. When it comes to implementing personal choices, I think that you can look at that at two different levels, one of which is the planning of new homes, new residential buildings, and designing homes such that you're avoiding the need for people to rely upon—or, indeed, futureproofing new homes so they can't incorporate wood burning and they don't need to, because the homes are really well insulated and you've got alternative means of heating homes, et cetera.

As the problem relates to existing homes, there is a lot of interest at the moment around retrofit and the retrofit of existing homes. If you have got somebody who's deprived and relying upon wood burning because they need to, then retrofit solutions can help the most deprived people in the community, because those people tend to have poor housing conditions, they're the ones who are, perhaps, least well insulated in terms of keeping the house warm and so on, and they're poorly insulated against noise and noise ingress and so on. So, I think if you look at noise and air quality within the wider context of retrofitting, then we can look at that in terms of maximising—. If there are interventions around retrofit, by taking a holistic view, by looking at retrofitting around carbon, around air quality, around noise and wider aspects of health, we can ensure that we get the biggest bang for the buck. But we don't do that at the moment because what we tend to do is retrofit around single solutions.

So, within a noise strategy, for example, the responsible authority might go and retrofit around noise, and that's an opportunity missed, because we're failing to retrofit around carbon and air quality as well. Similarly, if we've got retrofit schemes where we're looking at carbon reduction, that's an opportunity missed, because we've not looked at air quality and other things that can affect health and well-being. So, I’m pretty sure within the air quality and noise strategy, retrofit will be part of the armoury of things that can be used, but if we want to really maximise the bang for our buck, we’ve got to start thinking a little bit more broadly, and a little bit more holistically.

Thank you for that, Colin. Okay, Janet, was there anything else that you wanted to ask on this?

No, that covers it, really. I’m next on stationary idling.

Okay. We’ll go to Joyce.

Trunk road charging schemes. I have no doubt that you’re probably in favour of them, and I just have to ask for the record: do you agree that the Ministers should have the power to expand and create trunk road charging schemes to tackle air pollution?

Okay, and just to say that CIEH hasn’t provided a view on trunk road charging here, and I’ve not expressed a view either for or against. I think trunk road charging is part of options appraisal, if you like. I’m going to give my professional view here now that we have to travel between destinations practically in Wales; we all have to. That will bring its own environmental cost, but it goes back to the point you made earlier about inequalities, and that sometimes people who can afford to pay will pay and travel, and they’ll be the most polluting, but for those people that can’t afford, who need to travel anyway just to sustain themselves, there might be unintended consequences. So, I would say my own professional view is that it’s an option; it needs to be looked at. It’s probably a last resort in some cases where all other options have failed, and it should certainly only happen where there are viable alternatives to enable people to make those journeys in more sustainable ways.

Okay. Any of you—? No.

No?

Okay, that’s fine.

Okay, great. We’ll go back to you, Janet.

Thank you. What are your views on the provisions relating to fixed penalties for vehicle idling?

Okay, we’ve not given a view in the submission, but from experience, you need to go through the hierarchy, basically, around schools and idling, because schools is where it’s usually brought up as the chief—

I was in a queue the other day. On the A55, we’ve got roundabouts and we were hoping to get rid of those, because there’s a lot of queuing, and I was in this queue for 23 minutes, and I was like, 'Do I turn my ignition off?' I just felt really guilty for 23 minutes. Anyway, I did, but then, as it moves, it’s not practical. So, how do you think people are going to cope?

Yes, I think we’re entering also a bit of a technical conundrum as well. I think the idea is just to try and prevent idling and emissions—exhaust tail emissions in this scenario. My understanding is that engine technology varies across the fleet, so you might have the smoky old bus that was the start of all these debates, probably, but you now have technologies where you have engine controls that sometimes require them to be kept hot in order for them to actually reduce the emissions, and I think you may have heard evidence that, sometimes, when all the engines start up together, you’ll get a bolus, a cloud of pollution that happens.

But, again, we’re addressing a symptom, aren’t we? We need to go through the hierarchy of why do we need to have buses in the first place. There are probably good cases in places in Wales where that has to be. But we go through that: do we need them in the first place? Are there alternatives to get to school that don’t need these buses? And when those buses are needed, can you specify through contracts with providers for a certain level of compliance, et cetera? So, I think it’s quite a complex problem. Fundamentally, yes, we would like to see less tailpipe exhaust emissions in those localities, yes.

Again, a professional observation, which is my own, is that we did see an application for a bus centre not far from here that terminated in a basement or at ground-floor level. That, from our perspective, was a problem because it’s like seeing something in the US, where you have a terminus in a building. We need to move away from those kinds of scenarios.

Okay. I think Jenny wanted to come in.

I can see there are complex arguments around idling while you’re in a traffic queue, and the adverse impact of everybody starting up together, but surely keeping your vehicle idling because you want to keep the central heating on or you want to charge your phone should be never-events. There just have to be other ways of approaching a desired outcome than keeping an engine on of a machine that’s not moving.

Yes, I’m straying into areas that I'm not an expert on, but you could probably charge your phone without putting your ignition on, I would say. You put the ignition on, but these are engineering solutions that—

Anyway, people do it and they give that as the excuse, because I regularly—