Our letter to Defra
In October 2024 we wrote to Defra to state our position on the latest update to the GM Clean Air Plan. We received a response in December 2024 saying they hoped to reach a decision shortly on whether they accepted the plan. As yet there has been no further update. This is the letter we sent:
“We are writing to you as a coalition of health and sustainable transport campaign groups in Greater Manchester regarding the latest update to the Greater Manchester Clean Air Plan (GMCAP).
We are dismayed that Greater Manchester is not planning to meet the legal air quality limits before the end of 2026 (with verification data not available until 2027).
The original deadline for compliance with the legal limits on nitrogen dioxide (NO2) was 2010. According to the latest Defra statistics, the annual mean Limit Value for NO2 in 2023 in the Greater Manchester Urban Area was 55μg/m3, well over the legal limit and higher than the previous year.
After so many delays, we are keen to see a quick decision from government on the current proposed plan. But given the severity of toxic air in the city region, we would urge you to insist that this iteration of the plan is considered only as an interim version. Approval and resources should be given on the condition that the scope of the interventions in the plan are expanded in a final version with an aim for GM to meet legal compliance by the beginning of 2026 or earlier. It’s imperative that the upgrades to the taxi and bus fleet begin quickly, but they should be matched with action at the level of ambition that has been seen in other cities, such as targeted restrictions for high polluting private and commercial vehicles.
The people of Greater Manchester have been breathing illegally toxic air for far too long, with serious health consequences for millions of people.
The legal case for stronger action
The judgement of the High Court in ClientEarth (No. 2) established important legal tests that apply to the preparation of air quality plans. In his ruling, Mr Justice Garnham set out a three-part test for assessing air quality plans. We believe that these legal tests should also apply to Local Authority Clean Air plans and require that these plans must:
1. Aim to achieve compliance as soon as possible;
2. Choose a route to compliance which reduces human exposure as quickly as possible; and
3. Ensure that compliance with the limit values is not just possible but likely.
It was ruled that the Government had acted unlawfully by fixing on 2020 as a target date for compliance, which it viewed as too distant. Therefore, a plan with which we will not know whether we have achieved legal compliance until 2027 cannot be considered satisfactory.
The modelling provided by the GMCA also suggests that even if the plan is delivered, there will be 70 remaining sites where NO2 levels are “compliant but marginal” - ie. over 35µg/m3, and therefore still dangerously high. This cannot be considered sufficient to meet the requirement of ensuring that compliance is not only possible but likely. Furthermore, by their own assessment, “depot electrification has always been an identified risk to the deliverability of the GM CAP” and this is demonstrated in the latest delay. The heavy reliance on bus electrification means this risk remains, calling into question whether compliance can be considered likely.
For these reasons we believe that the plan to deliver bus and taxi upgrades needs to begin as quickly as possible, but that we will also require further measures to reduce the use of high polluting private and commercial vehicles.
The health case for stronger action
The responsible authorities must reduce exposure as much as possible whilst they are trying to achieve the final objective of meeting the limit values.
In their response to the GMCAP consultation in December 2020, Asthma + Lung UK reported that Greater Manchester has “one of the highest rates in the country for emergency admissions in children with lower respiratory tract infections.” Both Salford and Manchester are in the top 10 local authorities for emergency admissions and death rates for lung conditions.
And evidence shows that the most vulnerable people and those living in disadvantaged areas are at greater risk from air pollution, making this an urgent health inequalities issue.
We would also urge the Government to show national leadership on air pollution, delivering a Clean Air Act that is fit for the 21st century and bringing the UK legal limits in line with the World Health Organization guidelines.
In addition, the Government needs to provide local authorities with the powers and resources to enable all citizens to breathe clean air wherever they live or work.”