Monday 8 April 2024

The Back-story behind Anti-Car Policies in the UK, Part Two: The story up to 2008

This is the second of a set of six planned essays. Together, they will document the back-story behind the anti-car policies, which have plagued the people of the UK, under governments of all parties, for the last 30 years and more.

In the first essay, I examined the facts of air pollution. I looked at the major “smog” and “haze” incidents, for which there is objective evidence of serious harms to human health having been caused by air pollution. I began with the London “Great Smog” of 1952. I then reviewed the other major reported events. I found that virtually all the smog and haze events, which had proven and serious health consequences, involved the presence in the pollution mix of significant quantities of both particulate matter (PM) and sulphur oxides (sulphur dioxide, SO2 and/or sulphur trioxide, SO3). Many also had unusual meteorological conditions: low wind, stagnant air, or even a temperature inversion.

In this, the second essay, I will start to explore the history of the air pollution issue. Today, I will take it from the beginnings of the green agenda in the early 1970s, through to the year 2008.

I chose 2008 as the end point, because 2009 marks a watershed over this issue. In that year, the UK government’s Committee on the Medical Effects of Air Pollution (COMEAP) produced a report. Which laid a “scientific” foundation that enabled government and campaigners to make out that air pollution was a much more serious problem than had previously been thought. I will cover that report in the third essay of the set.

The United Nations

The green agenda began in the early 1970s, and its main driver was the United Nations. Having themselves been fuelled by the green agenda, the anti-car policies we suffer under today also have their roots around that time.

Now, the UN was started with high hopes. At the beginning, it did do some good work. Notably, the UN Declaration of Human Rights was a high-minded aim; though its execution left a lot to be desired. But after that, the UN began to decay.

Today, despite the image it seeks to project of benevolence, incorruptibility and justified authority, the UN is in reality an undemocratic and unaccountable political player. It has been made into a weapon by those that do not have in mind the interests of the ordinary people of the world. It is the driving force behind the deep green agenda, that has sought increasingly to restrict human civilization. And today, it aims to take these agendas so far as to destroy individual freedom and human prosperity.

Maurice Strong

The Canadian former oil baron, Maurice Strong, was the individual that, more than anyone else, perverted the UN into a bureaucracy intent on destroying human civilization, and in particular Western industrial civilization.

Indeed, I rate Strong as the evillest man of the 20th century. Ahead, indeed, of Stalin, Mao, Hitler and Pol Pot. Those four all set out to commit genocides against particular racial, religious, social or economic groups. But Strong set out to commit genocide against our entire civilization. He gave this away in a 1997 magazine interview, in which he said: “Frankly, we may get to the point where the only way of saving the world will be for industrial civilization to collapse.” Over several decades, Strong influenced those around him in the UN, including those at the very top, to move towards provoking that collapse.

The 1970s

Early stirrings

It was in 1971 that the UN started its “Man and the Biosphere” programme. This programme is still going on today! Coincidentally, or perhaps not, this was also the year in which Klaus Schwab’s World Economic Forum (WEF) was founded.

In 1972, the UN held its “Conference on the Human Environment” in Stockholm. And founded the UN Environment Programme, under the directorship of Maurice Strong.

The role of the European élites

While the UN continued to be the driver for much of the green agenda, including the “climate change” scam, the European political élites soon got involved, too. And air pollution was one of the major issues, with which they planned to beat us over the head and take away our prosperity and our freedoms.

This most interesting document [[1]], written in the mid-2000s by Christian Hey, Secretary General of the German Advisory Council on the Environment, relates some of the early history. The European Council and European Commission decided in 1972 to “establish a Community environmental policy.” The moves towards instituting such a policy began in 1973, with the first Environmental Action Programme or EAP. It is interesting to note also that the UK’s Royal College of Physicians (RCP), by its own account, issued its first report on air pollution and health in 1972.

On January 1st, 1973, the UK formally joined what was then known as the “European Communities.” This put us on the road to being ruled over by the unaccountable tyranny, that later became the EU.

Air pollution as a global issue

It was also in 1973 that air pollution started to become a policy issue around the world. Monitoring of two pollutants, ozone and nitrogen dioxide, began in the USA.

Monitoring of PM2.5 (particles of matter 2.5 micrometres or less in diameter) had already begun there back in 1959. These particles are considered important in the toxicology of air pollution, because they are small enough, that they can be expected to get through the body’s defences into the lungs, and potentially cause adverse health effects.

Also in 1973, the UN’s International Maritime Organization held an International Convention for the Prevention of Pollution from Ships.

In the remainder of the 1970s, the main focus in the scientific area of air pollution and health was monitoring. The mortality data collection for what later became the California Cancer Prevention Study began in 1973, thus allowing comparison of PM2.5 levels with actual mortality. And data collection for what became the Six Cities Study began in 1974.

The 1980s and up to Rio

The politicization of air pollution

In contrast to the 1970s, links between air pollution and health became in the 1980s more and more a political matter. And it was the European Community that did this. They changed their Environmental Action Programmes to be more directed towards control of emissions. And their desire to create the Internal Market or Single Market led to pressures to “harmonize” product regulations and environmental emissions standards between countries.

It was during the 1980s, too, that the idea of ambitious “clean air” policies, requiring reductions of emissions from cars as well as from other emissions sources, was first mooted. It was the Germans that were primarily responsible for this. So, policies designed to appease green interests in Germany were to be imposed, not just on Germans, but on people in other European countries, too – whether they wanted them or not.

This meant, of course, abandoning all idea of democracy or self-determination for the people, in the UK and in other EC countries. Did it not? If people in the UK had become aware of that at the time, I suspect Brexit would have happened a lot earlier than it eventually did.

It is ironic that the rise of those green interests in Germany, and so of “clean air” policies, had come out of the so-called Waldsterben, or forest die-back, that had become a big issue there in the early 1980s. By the early 1990s, though, it had become apparent that Waldsterben was not in any way a new problem. That it had had a variety of causes, including (and perhaps mainly) bark beetles. And that air pollution, except maybe a little from sulphur dioxide from communist industries, was not a big factor. Yet nothing was done to reverse, or even to soften, these policies, even though all rationale for them had been lost. This was atrocious conduct, typical of the arrogant attitude of the political élites towards the people of Europe.

Interestingly, the UN’s 1987 report “Our Common Future” did not have much to say about cars. It railed against “acid rain” from industry, but did not seem to see cars as a big contributor to any such thing. It certainly showed no sign of any policy being mooted at that time at the UN level, to force people in developed countries out of our cars.

The proliferation of green-ism

Towards the end of the 1980s and into the early 1990s, the European Commission became far more active in environmental matters. The primary driver of this was the “global warming” narrative, which had begun to attract much attention among the green-minded, and the Commission saw this as a way to increase its profile in so-called “régime building.” But it was applied to other perceived or potential environmental issues too.

One result was the proliferation of green “non-governmental organizations,” lobbying hard for green regulations at the expense of ordinary people. Another was the use of “economic instruments” or “fiscal instruments” – such as new taxes – in order to bring about environmentalist goals. A third was medium and long-term objectives for reducing pollution, or in bureaucrat-speak, “target-oriented approaches towards structural change.” This led to the appalling culture of arbitrary, collective “targets” and “limits,” to which, despite Brexit, we are still subjected today. And those “targets” and “limits,” far from being realistic goalposts, were designed to be tightened again and again as time went on.

Moreover, the next EAP, to begin in 1992, would include, in Christian Hey’s words, “structural change in favour of public transport.”

With hindsight, we can now see that the evil genie was out of the bottle. Even before the Rio conference started, the European and UK political élites had set in motion policies which, unless halted quickly, would inevitably lead to the mess we find ourselves in today. Did you vote for the “structural change” we were being subjected to? I sure as hell didn’t.

The philosopher in me has formed an idea of what has been, and still is, going on. We human beings have an innate urge to take control of our surroundings. It is a major, and vital, part of our nature. It is why we build buildings, take part in economic activity, and engineer solutions to make the world a better place for us to live. But the political élites that were setting the green agendas had perverted this urge into a desire to control us, the honest, productive human beings of the world.

Rio to the millennium

Perversion of the precautionary principle – Part 1

The precautionary principle, in the form in which I was taught it, says: “Look before you leap.” That is, don’t act unless and until you are pretty sure that the benefits of action are not outweighed by the costs or damage caused by that action. It can even be construed as: “First, do no harm.”

But the UK Tory party, for one, had by 1992 already formed a perverted view of the precautionary principle. In their 1992 election manifesto, they described it as: “the need to act, where there is significant risk of damage, before the scientific evidence is conclusive.” That is a far cry from “Look before you leap!” Indeed, it is not at all far away from its opposite.

At Rio, John Major and cohorts signed up to the “Rio Declaration on Environment and Development.” And, in particular, to Principle 15: “In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”

Now, I find that idea rather bizarre. For, if you don’t have a high degree of scientific certainty about the size and likelihood of a problem, how can you possibly assess whether or not a proposed counter-measure is cost-effective? Yet, with a recklessness typical of dishonest, unaccountable politicians, they signed us up to it anyway.

That was an egregious violation of the true precautionary principle. And it marked the first of the three steps, in which the ruling classes perverted it into a tool for tyranny.

Political pressure against drivers

Before the ink was even dry on the Rio agreements, government regulation of air pollution from cars began to increase greatly.

In 1992, the EU (as it was soon to become) issued its first vehicle emissions standards. In the UK, catalytic converters were required in petrol engines. The London Air Quality Network (LAQN) was formed, to monitor various pollutants. This was later extended into the UK-wide Automated Urban/Rural Network (AURN). And the “Advisory Group on Medical Aspects of Air Pollution Episodes,” forerunner of COMEAP, issued its first report.

In 1993, the Clean Air Act regulated the content of motor fuels. John Selwyn Gummer, an extreme green Tory, became environment secretary. And the anti-car spin machine went into overdrive. Our TV screens showed (staged) pictures of rural roads chock-a-block with cars. Of traffic jams in foggy weather, complete with smoking exhaust-pipes. Of the aftermaths of accidents. It was hard, even back then, to avoid thinking that we drivers were being set up.

Air pollution and mortality

In the USA, the “Six Cities” study was published in 1993. This set out to “estimate the effects of air pollution on mortality, while controlling for individual risk factors.” The lead author was Douglas Dockery. Other authors included C. Arden Pope and Frank Speizer. The timing suggests, to me, that there may well have been political interests driving this work.

The paper found: “After adjusting for smoking and other risk factors, we observed statistically significant and robust associations between air pollution and mortality.” And: “Air pollution was positively associated with death from lung cancer and cardiopulmonary disease but not with death from other causes considered together.”

James Enstrom

At some time between 1992 and 1994, a US epidemiologist, James Enstrom, who had been working on projects funded by the American Cancer Society (ACS), had his funding from that source terminated. Enstrom was later to become a controversial figure, mainly through his 2003 paper on passive smoking and his 2005 California Cancer Prevention Study.

Road traffic targets

In 1994, a first attempt was made to set binding targets for road traffic levels in the UK. This was initiated by a Welsh nationalist MP, with a bill that had actually been written by Friends of the Earth and the Green Party!

With hindsight, we can see that the culture of collective “targets” and “limits” on everything, so beloved of the EU, had already been imported into the UK. Such a collectivist culture inevitably leads to inequity. For when the “limits” or “targets” are exceeded, who will be expected to make sacrifices and to foot the bill? Yes, you’ve guessed it: the ordinary people. The élites will just carry on doing what they want to do, totally ignoring their own hypocrisy.

“Air quality” becomes a buzz-word

The UK Environment Act 1995 brought in a requirement for government to prepare a National Air Quality Strategy. And across the pond, an American Cancer Society study, now generally known as the “ACS original study,” came up with a revised estimate for the impact of air pollution on mortality. It was lower than almost all the earlier estimates. Though it used a different set of data, this study was by no means independent of the Six Cities study, since the lead author was Pope, and Dockery and Speizer were among the co-authors.

In 1996, the EU issued its Ambient Air Quality Directive. This was described as “formulating an ambitious work programme for several decades, while delegating many decisions and tasks to member states, bureaucratic networks or to civil society and business.” That doesn’t sound cheap for the people, does it? Nor democratic, either.

1997 brought the publication of the first UK National Air Quality Strategy, and the start of DEFRA’s (the Department for Environment, Food and Rural Affairs) “air quality grant” scheme.

More road traffic reductions – and a small back-track

1997 also brought in the UK a Road Traffic Reduction Act. A brief account of this can be found here: [[2]]. This act, in essence, enabled local authorities to set local targets for reductions in road traffic, and the national government to set regional targets. Once national targets had been removed from the bill, the Tories, still in power at the time, supported it.

After Labour and Tony Blair knocked the Tories out of power, as the paper referenced above observes: “the transport policy of the incoming Labour Government became more engaged with the notion of lessening dependence on the car.”

1998 brought a Road Traffic Reduction (National Targets) Act. This set separate targets for reducing traffic in England, Scotland and Wales. As plans for implementation progressed, it became apparent that this approach simply wasn’t going to work. In essence, traffic levels could not be reduced without trashing the economy. Over the following decade or so, it was, in effect, replaced by plans to control the side-effects of traffic, like congestion and pollution.

It pains me to say anything nice about Labour, or any other political party for that matter. But they do seem, first, to have looked on this occasion for practical solutions rather than one-size-fits-all mandates. And second, to have concentrated on congestion, ameliorating which clearly does bring benefits in time savings to the people, rather than air pollution, where the overall cost versus benefit picture was (and still is) highly dubious.

Perversion of the precautionary principle – Part 2

Meanwhile, across the pond, work continued on one of the most dishonest frauds that activist political governments have ever perpetrated against the people they are supposed to serve. Namely, the perversion of the precautionary principle into a tool for tyranny.

In early 1998, the Wingspread Conference on the Precautionary Principle was held in the USA. It was hosted by Samuel Curtis Johnson, long-time chairman of S. C. Johnson & Son, Inc., a founder of the World Business Council for Sustainable Development (WBCSD), and described by Fortune magazine as “corporate America's leading environmentalist.” It was convened by a shadowy organization called the Science and Environmental Health Network (SEHN), only founded in 1994. This was the second of the three major steps, in which the principle was perverted, in effect, from “Look before you leap” to “If in doubt about a risk, government must act to prevent it.”

The SEHN’s (much later) account of the conference is here: [[3]]. It says: “The key element of the principle is that it incites us to take anticipatory action in the absence of scientific certainty. At the conclusion of the three-day conference, the diverse group issued a statement calling for government, corporations, communities and scientists to implement the ‘precautionary principle’ in making decisions.”

I have written about Wingspread here: [[4]]. My summary was: “They inverted the burden of proof. They rejected the presumption of innocence. They required the accused (that’s us) to prove a negative. They mandated ‘precautionary’ action, however much pain it would cause. And they threw out all consideration of objective cost-benefit or risk-benefit analysis.”

The EU, UK and UN join forces

In 1998 also, the EU issued a new directive on fuel standards. And COMEAP addressed for the first time the issue of links between air pollution and health.

In 1999, the UK signed up to the Gothenburg Protocol, a “Protocol to Abate Acidification, Eutrophication and Ground-level Ozone.” This was the work of the United Nations Economic Commission for Europe (UNECE), and marks the point at which the UN added its shoulder to the EU’s push for ambitious “clean air” policies. It set, for the first time, UN controls on emissions of pollutants, as opposed to concentrations, which had been used up to that time. This seems odd to me, as it is concentrations, not emissions, which determine health effects. Perhaps the switch was made to establish a political path towards UN control of emissions? This protocol came into effect in 2005.

Also in 1999, leaded petrol was phased out in the UK.

The state of play at the millennium

With hindsight, we can see that as at the millennium, commitments and regulations and “targets” and “limits,” which would surely cost everyone dearly later, were being made at an ever-increasing pace. And yet, the scientific basis on which all this was being done was hardly understood at all.

Almost all the work had been done in the USA, by – so it appears – a very small clique of “experts,” often working together on multiple occasions. The results were, as yet, crude and uncertain. Even COMEAP was years away from being able to try to assess accurately the size of even the PM2.5 part of the air pollution problem. Moreover, the stage was being set to allow the political élites to ignore any ideas of risk-benefit or cost-benefit analysis, and just to go ahead and do to us what they wanted to do anyway.

The élites had let their green enthusiasm run away with them, and the people – that’s us – were soon going to be expected to pay a hefty price.

The Noughties up to 2008

At this point, the story becomes sufficiently complex, that I feel a need to go back to a chronological approach.

2000 to 2002

In 2000, Air Quality Regulations were imposed in the constituent countries of the UK, which required local authorities to undertake reviews and assessments in their areas against centrally mandated air quality standards. And the Transport Act 2000 introduced the concepts of road pricing schemes and workplace parking levies.

In the same year, the Health Effects Institute (HEI), a US non-profit mainly funded by the EPA, was allowed access to the raw data, by now held by the EPA, which underlay the Six Cities and ACS original studies. They reported that they had validated the original studies. But no independent scientists were allowed access to the data. There were certainly those who thought that this exercise was something of a whitewash.

In 2001, the Euro 3 vehicle emissions standards came into force. And the EU issued its National Emissions Ceiling directive. This set binding emissions ceilings for each country, which were to be achieved by 2010, and not exceeded thereafter. In the UK, COMEAP issued a report, which aimed to provide some provisional estimates of the effects of long-term exposure to particulate matter in the UK. But there were huge uncertainties. One of which was how best to separate out toxicity estimates for PM2.5 from confounding factors like tobacco smoking and sulphur dioxide pollution. In this exercise, they used data from the ACS original study and the HEI reanalysis.

Also in 2001, the Labour government – Tony Blair, Gordon Brown and their scientific adviser David King – decided to offer incentives to drivers to buy diesel cars. They did this, supposedly, because diesel engines emit less carbon dioxide (CO2) per mile than petrol ones, so were expected to cause less putative “global warming!”

In retrospect, this turns out to have been an extremely bad decision. For diesel engines emit far more nitrogen oxides (NOx) per mile than petrol ones. And these gases are said to be toxic, although exactly how toxic is not at all clear. This has now put large numbers of people, who happen to drive diesel cars or vans, in danger of losing their mobility altogether.

In 2002, the 2001 EU directive was introduced in the UK as the National Emission Ceilings Regulations. And an updated version of the ACS study was published, with Pope again as lead author. This is now known as “ACS 2.” It was the risk coefficients from this study that COMEAP was eventually to adopt as applicable to the UK.

Perversion of the precautionary principle – Part 3

2002 was also the year in which the perversion of the precautionary principle, which had begun with the Rio Declaration and extended by the Wingspread Statement, was not only explicitly incorporated into UK government policy, but strengthened too. The Interdepartmental Liaison Group for Risk Assessment, a working party originally set up in 1994, produced a report called: “The Precautionary Principle: Policy and Application”: [[5]].

They saw the purpose of the principle as “to create an impetus to take a decision notwithstanding scientific uncertainty about the nature and extent of the risk.” They saw it as to be applied whenever “it is impossible to assess the risk with sufficient confidence to inform decision-making.” They wanted to invoke it “even if the likelihood of harm is remote.” They said, too, that “the precautionary principle carries a general presumption that the burden of proof shifts away from the regulator having to demonstrate potential for harm towards the hazard creator having to demonstrate an acceptable level of safety.” And they misused an aphorism attributed to Carl Sagan, saying: “‘Absence of evidence of risk’ should never be confused with, or taken as, ‘evidence of absence of risk’.”

This goes further even than the Wingspread Statement did. It doesn’t just invert the burden of proof and require us, the accused, to prove a negative. But it enables them to take “precautionary” action against any risk, even one that is minuscule or very unlikely, instead of requiring an objective risk analysis accurate enough to support good decision making. Moreover, they want the decision to be taken before all the evidence has been mulled over. And even if there’s no evidence at all that our activity causes any harm to anyone, they wouldn’t accept that as evidence!

In essence, the UK government decreed, in contradiction to the norm of presumption of innocence, that absence of evidence of guilt is not evidence of absence of guilt. They decided to re-write the precautionary principle to say, in effect: “If in doubt about a risk, government must act to prevent it.” Regardless of how much harm, or costs, their action causes to the people they are supposed to be serving. This, again, is atrocious conduct.

2003

In 2003, then London mayor “Red Ken” Livingstone introduced a “Congestion Charge” in Central London.

In the same year, a feasibility study was done for what became the London Low Emissions Zone (LEZ). This planned to levy a daily charge on commercial vehicles (lorries, buses, coaches, and minibuses, vans and ambulances over a certain weight) which did not meet a particular standard for PM2.5 emissions. It was envisaged that the standards to be met would be progressively tightened once the scheme was operating. Notice that these charges were implemented long before COMEAP, or anyone else, had made – or even tried to make – any accurate estimates of the benefits that would result from reduced air pollution. The LEZ scheme can, therefore, not possibly have been any more than a money-grab.

It is interesting to note who was the chair of the 2003 feasibility study: Paul Watkiss. Watkiss is associated with Oxford University, and since 2006 has been director of a “Climate Change Consultancy.” He was to be one of the economists who in 2007-9 was to be involved in the UK government’s machinations that led to the dropping of the “social cost of carbon” approach to assessing the impacts of CO2 emissions. This move, in effect, made it impossible to do a proper cost versus benefit analysis on anything involving CO2 emissions.

Watkiss has also worked more recently with the Climate Change Committee (CCC), towards “aggregate estimates of the costs of adaptation” to changes in the climate. It does concern me that, so it seems, even now these costs are not well understood. How can you possibly start any project, most of all one using other people’s money, without an idea of how much it is likely to cost?

It is also worth recording that 2003 marked the debut of the “Green Book,” a set of procedures meant to guide cost versus benefit analyses carried out by the UK government.

2005

In 2005, Paul Watkiss was part of a team analyzing the EU’s proposed Clean Air for Europe (CAFE) programme, which became an EU directive in 2008. (Notice the change of the branding from “air quality” to “clean air!”) It is interesting to note that several on this same team later became members of COMEAP.

Also in 2005, the UN’s World Health Organization (WHO) updated its “air quality guidelines,” which included a guideline for PM2.5 that was an order of magnitude lower than previous limits, even than the EU’s. And London mayor Livingstone founded C40, “a global network of mayors taking urgent action to confront the climate crisis and create a future where everyone can thrive.”

Meanwhile, across the pond, James Enstrom and his team published the California Cancer Prevention Study. This found the risks of mortality from PM2.5 pollution in the group studied to be at least an order of magnitude lower than other studies were finding at the time.

Now, Enstrom was already in the bad books of the establishment for his 2003 publication in the Lancet, which concluded: “The results do not support a causal relation between environmental tobacco smoke and tobacco related mortality, although they do not rule out a small effect. The association between exposure to environmental tobacco smoke and coronary heart disease and lung cancer may be considerably weaker than generally believed.” Soon after, the ACS accused him of “denying that passive smoking was harmful” – hardly a scientific rebuttal of his paper! And this 2005 paper did not endear him to the activists, either.

2006 to 2008

In 2006, the Euro 4 vehicle standards came in. Petrol vehicles meeting this standard are today exempt from ULEZ. Things were not so good on the diesel front, though. The LAQN’s report for 2006 and 2007 – which, curiously, wasn’t published until 2009 – stated that the EU limit value for NO2 was being “consistently exceeded at background sites in inner London and at roadside sites throughout London.” And insiders at the European Federation for Transport and Environment had found out that, in the “real world” as opposed to laboratory testing, emissions of nitrogen oxides from diesel engines were much higher than the limits the cars were supposedly built to meet. But this was not to become known to the general public until nine years later, with the “Volkswagen diesel scandal.”

One intervention in 2006, which did seem to produce positive results, was stricter controls over the sulphur content of marine fuels. And in 2007, “sulphur content of liquid fuels” legislation was passed in the UK and other countries, based on an EU directive. The introduction of “ultra-low sulphur” diesel, in the words of a 2016 report, “caused an almost-immediate decrease of up to 60% in the level of sub-micrometre particle pollution in the air that we breathe.” (These particles are PM1 size, even smaller than most PM2.5).

Looking back at UK fuel prices over the years, the price difference per litre between diesel and petrol did go up for a couple of years from 2007, but was all but gone by 2010. This suggests that – for once – an environmentalist measure did actually achieve a result, without causing people great pain. It would be interesting to know how big, if at all, was the corresponding drop in the recorded number of deaths due to causes which are, or may be, attributable to air pollution from cars!

It was in 2007 also that the London Congestion Charge area was extended westwards, to almost twice its original size.

The UK government and its advisors were also active in the air pollution area in 2007. Updated Air Quality Strategies were produced for the constituent countries of the UK. And the Air Quality Expert Group (AQEG) produced a report on “Air quality and climate change,” here: [[6]]. Reading the summary conclusions, the interaction between policies designed to “mitigate” one or the other is a complex subject!

It is also interesting to see that there was considerable overlap between the personnel in AQEG and COMEAP. This is understandable, if the skills needed are in limited supply. But it is also concerning, when looked at in the light of potential for groupthink, and vulnerability to influence by activist members. The same year also saw the production by COMEAP of a draft, which later became their major 2009 report.

In 2008, the EU issued yet another omnibus directive, on Ambient Air Quality and Cleaner Air for Europe. And the London LEZ went into operation.

That’s it for the back-story up to and including 2008.


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