Is the Clean Air Plan fit for the future? 

As people campaigning for cleaner air, we are disappointed with the lack of ambition in both the plans and the debate around air pollution across Greater Manchester.

The ‘investment-led plan’ submitted for approval to Greater Manchester’s Air Quality Administration Committee sets out measures which claim to meet our legal obligation to reduce levels of nitrogen dioxide pollution to below 40μg/m3 by end of 2025.

But the results suggested by the modelling are only a hair’s breadth below the legal target.  In some cases, the modelled levels remain above 40μg/m3 and compliance is only met by rounding down the numbers. Furthermore, whilst the full details of the models have not been released, the report submitted to the Committee highlights that, under the new plan, 65 sites will remain at more than three and a half times the limit recommended by the World Health Organization guidelines.

We are also concerned that the plan includes local traffic management  measures with the acknowledgement that they will achieve compliance in one location by displacing the traffic (and resultant pollution) elsewhere.  This is not solving the problem of too many polluting vehicles on our roads, along with all the related disbenefits caused by congestion; it is just kicking the can down the road. 

Professional drivers who spend their working day in traffic are amongst the most exposed to dirty air and most at risk of the health impacts. We fully support the financial assistance for taxi drivers to upgrade their vehicles, and would advocate for more targeted support for other small businesses which are reliant on vans. But this must be accompanied by action to help more people move out of polluting vehicles and towards public transport and active travel where possible. Dirty vehicles remain a huge source of pollutants and carbon emissions, and reducing their use will benefit all of us, and reduce the burden on our NHS and social care services. 

Meeting the current legal limit is the lowest bar for success. As evidence mounts about the serious physical and mental health impacts of air pollution, we should be working on the ambitious solutions that improve health outcomes, by cleaning up our air to meet World Health Organization guidelines.  

Dither and delay around the Clean Air Plan has led to the city of Manchester recording the highest levels of nitrogen dioxide of any local authority last year, and this is likely to continue unless we now take ambitious action

We would like to see the measures in the plan implemented quickly, but also for new measures to be added so that we bring the levels of pollution down to safer levels (aligned with WHO guidelines) and in less time. From traffic free spaces to permanent bus lanes, from more school streets to better infrastructure for walking and cycling; from a Workplace Parking Levy to scrappage schemes for dirty diesels; the solutions are well evidenced and available. Let’s get on with it. 

Sarah Rowe, Clean Cities Greater Manchester Campaigner 

Cazz Ward, Walk Ride Greater Manchester 

Pete Abel, Manchester Friends of the Earth 

Liz Godfrey, Mums for Lungs Manchester 

Judith Emanuel, Let’s Talk Clean Air Whalley Range


  • Table 8 in the Appraisal Report notes that there will be 65 sites in the ‘Compliant but marginal’ (35 to 40 µg/m3) category by the end of 2025 under the new plan. The WHO’s guideline is 10μg/m3.

  •  Paragraph 4.4.8 in the Appraisal Report highlights some displacement from Regent Road to parallel routes. 


  • In 2021, the World Health Organization updated its air quality guidelines in response to the “real and continued threat of air pollution to public health”, and in light of a much stronger body of evidence to show how air pollution affects different aspects of health. They reduced the limit for annual average exposure for nitrogen dioxide from 40μg/m3 to 10μg/m3.

  • The latest data from Defra shows that last year, Manchester had the highest NO2 concentrations of any local authority. 

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Updated Clean Air Plan does not meet the scale of the challenge