Defra consultation on the revised Draft National Air Pollution Control Programme – Response from the LGA

The LGA’s recommendations for tackling urgent risks from air pollution based on the themes set out in the revised National Air Pollution Control Programme.

It is worrying that the revision of the National Air Pollution Control Programme has been triggered by the risk that levels of certain types of pollution are close to the ceiling set in national regulations and may be at risk of exceeding agreed upper limits set for 2025 and 2030 (NH3 ammonia, NOx, SOx and PM2.5). We welcome a conversation with Defra on the level of the thresholds, given the impact of air pollution on public health.

The revised National Air Pollution Control Programme recognises the major sources of pollution: agriculture, industry, road transport, domestic appliances and domestic burning. Given the seriousness of the situation, government must act now to tackle these sources of pollution. Councils are a key partner in reducing air pollution, but they are in the impossible position of trying to meet their statutory duties on air quality with few levers over the sources.

Set out below are the Local Government Association’s recommendations for tackling urgent risks from air pollution based on the themes set out in the programme:

Solid fuels and cleaner stoves

We support measures that take harmful solid fuels out of the market and make it easy for residents to choose the cleanest source of fuel. It is good that action has already been taken on the design of stoves and that Defra is looking at new standards for fuels entering the market. Defra could look at further measures to reduce harmful domestic burning, including further restrictions and educational campaigns.

New air quality enforcement powers for local authorities are set out in the Environment Act but are not yet implemented, as further consultation and secondary legislation is required. Defra should provide an updated timetable for the implementation of air quality measures set out in the Environment Act.

The LGA has repeatedly raised concerns about the underfunding of local government’s regulatory services and the challenge of absorbing new regulatory duties without the ability to recruit more staff. New air quality enforcement responsibilities for councils must be supported with additional resources, and we want to work with government on longer term plans that will place regulatory services on a financially stable footing and address the shortage of skilled staff.

The additional measures proposed on solid fuels in the revised NAPCP all relate to extending legislation on the sale of fuel and safe limits of emissions. There is a place for enforcement action in tackling air pollution from solid fuels, but it should be part of a broader package of measures that support manufacturers, retailers, and consumers to switch to cleaner fuels. Defra should consider additional responsibilities for the manufacturers and retailers of solid fuels and appliances and tackle the air borne pollution at source.  Enforcement action should only be needed as a last resort.

Defra’s proposals for additional education for residents on the risk of domestic burning and how to do this cleanly and efficiently are welcome as part of a package of measures. However, this is unlikely to have a significant impact if dirty fuels and stoves are still on the market. 


We support the measures to help local authorities tackle air pollution in the Net Zero Strategy. But Defra should ask DfT to deliver on the commitments set out within it, and review the balance of measures and limit PM2.5 from electric vehicles (EVs) in towns and cities alongside maximising decarbonisation.

The Net Zero Strategy, like the Transport Decarbonisation Plan, should be much clearer about its implied requirements for traffic reductions, particularly in towns and cities. The absence of clarity, unlike in the Scottish plans, as well as the continued lack of progress on creating a fuel duty replacement for EVs – projected by DfT to drive significant traffic increases if unaddressed – pose serious challenges for DfT’s ambitions to reduce PM2.5 emissions from road transport, and for local authorities to drive up walking, cycling and public transport use.

EV sales have grown well above even the most optimistic recent projections. Due to their weight and, through lower running costs, their higher mileage, EVs can emit PM2.5 emissions from tyre and road surface wear that will limit any potential reductions. Local authorities need more support from central government in messaging, policy and funding that traffic must significantly reduce in towns and cities to hit national and local targets on decarbonisation, air quality and congestion. Simply replacing expensive to run internal combustion engines (ICEs) with cheap to run EVs in cities creates more problems than it solves.

Heavy goods vehicles, aviation and diesel trains must also be decarbonised and electrification may not be suitable for all the different challenges and applications of these forms of transport. Discussion is needed with government on accelerating the take up of alternative technologies such as hydrogen.

DfT, Defra and HMT should rebalance policy set out in the Net Zero Plan to recognise the importance of local authorities’ role in supporting modal shift away from cars as well as the shift from ICEs to EVs. Long-term funding, i.e. beyond this Parliament, is needed to enable local authorities to develop and deliver Local Transport Plans alongside Local Plans that encourage and incentivises transport systems and development that increases emission free walking and cycling and journeys by public transport, and results in fewer private cars and car journeys.

The Net Zero Strategy is already a false baseline for projected emissions reductions. For example, the £3bn National Bus Strategy has emerged as a £1.1bn scheme that partially funded less than half of bidding areas. This will hold back the electrification of bus fleets and improvements in services that will help to reduce car trips and ownership rates that would contribute to PM2.5 and NOx reductions, especially in towns and cities.

DfT should consider the value of its extensive investments as set out in the Net Zero plan to be suboptimal when delivered in one year funding agreements and via multiple competitive funding pots. If it can only provide one-year funding agreements on walking and cycling, it should consider agreeing these amounts before the financial year begins rather than leaving the announcement to July. Long-term funding to deliver outcomes around air quality, decarbonisation and accessibility would enable local authorities to focus on local solutions to local circumstances, and bring expertise in-house to develop and deliver effectively and efficiently the pipeline of transport schemes required.

Defra should clarify with DfT the status of each commitment in the Net Zero Strategy.


The additional actions that could reduce ammonia from agriculture are sketched out loosely with no timeframe. It is not clear whether these would be delivered through policy, incentives or grants. This section lacks ambition and the accountability for action is unclear.

Councils, in having air quality duties, and as planning authorities, and as soon to have lead responsibility for developing Local Nature Recovery Strategies will be important partners in creating approaches to land-use that balance the economic production and environmental impact. It is important the Environment Agency and Natural England properly engage with councils on these matters.

Net Zero

The Governments Net Zero Strategy and Heat and Building Strategy ambitions to electrify heat and transition electricity generation away from fossil fuels to 100% renewable energy will, if achievable, significantly reduce NOx emissions from fossil fuel space heating. However, there are significant risks in achieving electrification of heat including cost of both installation and operation of electric heating systems, skills and labour shortages both in terms of site preparation (energy efficiency retrofit) and heat pump installation, technology infancy, insufficient renewable energy generation and insufficient grid capacity for transmission and distribution. This with a backdrop of increasing energy prices and a cost-of-living crisis which is likely to drive households towards the cheapest space heating options which could be solid fuel in the short term.

Governments Net Zero Strategy needs an implementation plan that takes a systems approach to addressing these significant barriers. Local government wants to work with central government to address these barriers particularly with homes energy efficiency retrofit and tackling the skills shortage.

Our asks of Government are to:

  • bring forward the £3.8 billion Social Housing Decarbonisation Fund to help the rollout of an ambitious national retrofit programme across all tenures that will create jobs, support local economies, cut fuel bills, and help tackle fuel poverty
  • bring forward the implementation of the Future Homes and Future Buildings Standards to ensure that developers do not build to older efficiency standards for longer than necessary
  • empower the local planning system to ensure that developers build new homes that are energy efficient and net zero. Support area wide planning for regional delivery of energy, transport systems and building retrofit
  • develop a communication and incentivisation programme with Local Government to engage with social housing landlords and tenants, private rented sector landlords and tenants and owner occupiers on the need for fabric energy efficiency retrofit and the transition to heat pumps
  • encourage owners of properties to invest in systems that will reduce their emissions such as solar panels and hydrogen boilers or ground source heat pumps. We need measures to incentivise and encourage take-up from those already considering a switch, and make these products more affordable. For example, by tackling the long payback periods.

Thank you for the opportunity to comment on the revised Draft National Air Pollution Control Programme and I look forward to hearing about the next steps.

Yours sincerely,

Councillor David Renard

Chair, Environment, Economy, Housing and Transport Board, Local Government Association