Wednesday 10 April 2024

The Back-story behind Anti-Car Policies in the UK, Part Four: The story from 2009 to 2022

This is the fourth (and longest) of a set of six 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.

At the end of my second essay, I broke off the story at the end of 2008. I spent the third essay evaluating the UK government’s COMEAP (Committee on the Medical Effects of Air Pollution) report of 2009. This provided apparent scientific justification for subsequent policies to reduce air pollution by small-sized particulate matter (PM2.5). Yet, I found it very seriously wanting. Indeed, I did not believe its conclusions. Nor did I trust the processes that had led to them.

Today, I will return to the chronological approach, and continue the story from 2009.

2009 to 2015

2009

2009 was the year of the Lisbon Treaty. This gave the EU full legal personality. And greatly increased its powers, both over national governments and their populations. Since then, the European Commission and the EU have become steadily more and more tyrannical.

In 2009, the LAQN (London Air Quality Network) report for 2006/7 identified that the EU limit value for nitrogen oxides (NOx) was being exceeded in many places in London. Curiously, the 2008, 2009 and 2010 reports weren’t published until 2012! Also in 2009, data collection began for the report, which in 2018 would assess how effective the London Low Emissions Zone (LEZ) had been.

I have already covered the COMEAP report of 2009.

2010

In 2010, the EU’s 2008 directive on “ambient air quality and cleaner air for Europe” became UK law. And new Euro 5 vehicle emissions standards were introduced. They limited PM2.5 emissions to just one-tenth of the Euro 3 limits of nine years earlier.

On the other side of the pond, the University College of Los Angeles (UCLA) attempted to fire controversial researcher James Enstrom, claiming his research failed to accord with the department’s “mission.” [[1]]. (His California Cancer Prevention Study of 2005 had come up with a risk coefficient for PM2.5 pollution, that was orders of magnitude lower than most of the other studies. And that was not the only way he had annoyed the establishment.)

The COMEAP follow-up report

The major UK report of 2010 in the air pollution area was the follow-up to the COMEAP report of 2009. It was titled “The Mortality Effects of Long-Term Exposure to Particulate Air Pollution in the United Kingdom.” It was produced on COMEAP’s behalf by the Health Protection Agency (HPA): [[2]]. It used the figures from the earlier COMEAP report to derive estimates of the “burden” of mortality due to PM2.5 levels in the year studied (2008).

It is of interest that, in between the 2009 and 2010 reports, the COMEAP committee had been augmented by four members, from 12 to 16. Among the new members was Professor Frank Kelly, then at King’s College London, and now professor of Community Health and Policy at Imperial College London. It is noteworthy that, earlier in his career, he had been a lecturer at Southampton University, where Stephen Holgate was a professor. Professor Kelly will play a key role in the story that follows.

The headline conclusion of the report was: “An effect on mortality in 2008 of nearly 29,000 deaths in the UK at typical ages and an associated loss of total population life of 340,000 life-years. The burden can also be represented as a loss of life expectancy from birth of approximately six months.” Big scary numbers, heh?

To their credit, the HPA were careful to stress the huge uncertainty in COMEAP’s risk estimate. But given my reservations about the processes which produced that estimate, I am tempted to use a phrase popular among software people: GIGO. Meaning, garbage in, garbage out. If a figure is suspect, then any further calculations making use of that figure are themselves suspect. Including the HPA report. And that goes for all air pollution calculations made since, that use COMEAP’s 2009 risk coefficients.

In any case, even using the HPA’s figures, my 2017 social cost calculations on air pollution from cars came out way lower than would have been necessary to justify the charges imposed by the London ULEZ (Ultra Low Emissions Zone).

And there’s more. Using the HPA’s assumptions, the part of the life expectancy loss that was specifically caused by air pollution from cars came out to be around 25 days. I will repeat here my reaction to this, from my original 2017 paper.

“Which would you prefer? To travel where you want, when you want, in the comfort and privacy of a fast, smooth, quiet, spacious car? Or to be granted an extra 25 days at the end of your life, and in exchange to be forced to spend your travelling life waiting at bus stops in the pouring rain or standing on freezing station platforms, and when you finally do get moving it’s noisy, rattling, uncomfortable, crowded and often slow? I know which I’d pick. Moreover, wouldn’t you spend a lot more than 25 days of your life at those bus stops and on those platforms? (Exercise for the reader: how many days is 5 minutes a day over a lifetime?)”

2011

In 2011, a UK team working on behalf of the Health Effects Institute (HEI) reviewed how much effect the London congestion charging scheme had had on air pollution levels since 2003: [[3]]. Professor Frank Kelly was the lead author. The answer to the question was, in brief, not very much.

And it was worse than that. For here is the “bottom line” from the statement made by the HEI as a whole. “Ultimately, the review committee concluded that the investigators, despite their considerable efforts to study the impact of the London CCS, were unable to demonstrate a clear effect of the CCS either on individual pollutant concentrations or on the oxidative potential of PM10.”

Two things stand out here. One, they chose to study PM10 and other pollutants such as nitrogen oxides, rather than focusing on PM2.5. And two, there was considerable overlap in personnel between this team and COMEAP. Professors Anderson and Derwent, and Dr Armstrong, all took part in both the 2009 report and this study. And Dr Atkinson and Professor Kelly, too, had been on COMEAP at the time of the 2010 report.

In 2011 too, government subsidies began for improving the take-up of ultra-low emission vehicles, and to support greener transport schemes.

2012

In 2012, there were two major events in the air pollution area. One, the standards were tightened in the pre-existing London LEZ (for commercial vehicles). Two, the Gothenburg Protocol, first agreed in 1999 to come into force in 2005, was amended and extended. It now set out emissions commitments for individual nations, which were to be reached by 2020. Some of these commitments included ceilings for both stationary and mobile sources. And it set out commitments beyond 2020, too.

The culture of arbitrary, ever tightening, collective “targets” and “limits,” that had been conceived by the EU, adopted by the UN, and supported by national politicians that ought to have known better, was now in full swing. And in Europe, the EU had become its policeman. No wonder momentum among ordinary people started building towards Brexit.

In 2012 also, the UK’s Air Quality Expert Group (AQEG) issued a report: “Fine Particulate Matter (PM2.5) in the United Kingdom.” [[4]]. The group included Professors Dick Derwent and Roy Harrison, both of whom had been involved in the 2009 and 2010 COMEAP reports. This report “challenges the robustness of the evidence for making future policy decisions in respect of PM2.5 in the UK context.” Is that not close to admitting that the 2009 and 2010 reports were wrong? It also says: “Sulphate particles remain important, despite the large reductions in sulphur dioxide emissions since the 1980s.” Yes, indeed. But how important?

2013

A curious row occurred in 2013 over the raw data for the Six Cities and ACS studies. The US House of Representatives subpoenaed the Environmental Protection Authority (EPA) for this data. But they still refused to release it. It was not until the change of administration in 2016 that independent scientists, like James Enstrom, were allowed access to versions of this data.

REVIHAAP and HRAPIE

But the main air pollution story of 2013 came from the WHO and the EU. In that year, they started promoting air pollution as a really big problem, with a project called REVIHAAP. (“Review of Evidence on Health Aspects of Air Pollution.”) The project was jointly funded by the WHO and the EU. For those interested, the full report is available here: [[5]].

The description page says: “The review concludes that a considerable amount of new scientific information on the adverse effects on health of particulate matter, ozone and nitrogen dioxide, observed at levels commonly present in Europe, has been published in recent years. This new evidence supports the scientific conclusions of the WHO air quality guidelines, last updated in 2005, and indicates that the effects in some cases occur at air pollution concentrations lower than those serving to establish these guidelines. It also provides scientific arguments for taking decisive actions to improve air quality and reduce the burden of disease associated with air pollution in Europe.” This is a clear call from the WHO to governments to ramp up interference in the lives of the people they govern, is it not?

There was a sister project called HRAPIE, “Health Risks from Air Pollution in Europe.” [[6]]. This was a review of the views of “expert stakeholders.” The description says: “The main findings of the survey are that the majority of respondents identified the general categories of ‘road traffic’, ‘space heating and air conditioning’, and ‘shipping’ as the top three emission source categories of concern associated with emerging issues for public health.”

It is also worth noting that a very popular response to the “recommendations for policymakers” question was “more funding!”

I found a most interesting presentation about REVIHAAP from a LAQN seminar, here: [[7]]. The general tone of “it’s worse than we thought,” and the incessant harping on about new or serious threats – including from nitrogen dioxide (NO2), remind me very much of the techniques that have been used by alarmists to hype the “climate change” scam. There is also one most interesting statement there. REVIHAAP “provides scientific arguments for the decisive actions to improve air quality and reduce the burden of disease associated with air pollution in Europe.” Policy-based evidence, anyone?

This level of alarm seems odd for its time. Until the Chinese smogs of late 2013, there had been no smogs causing proven serious health damage for several decades. And the recorded Asian hazes were caused by agricultural fires and perhaps by SO2 from burning coal, not by nitrogen oxide emissions, whether from cars or other sources.

But it’s worse. Some of the names I see on the list of those, who were involved in providing the scientific inputs to this project, combine to raise in my mind a big red flag.

The author of the presentation, Dr Michal Krzyzanowski, was Reviewer 3 (the one from the WHO) on the 2009 COMEAP report. And the list of participants on page 4 reads like a WHO’s WHO of government advisors on air pollution toxicology. We have some already familiar names: Anderson, Atkinson, Holgate, Kelly, Derwent, Harrison. We also have Dr Bart Ostro (Reviewer 4) and Professor Philip Hopke (Reviewer 2). We have C. Arden Pope, the lead author of the original ACS study. From COMEAP, we also have Mr J Fintan Hurley, chair of the QUARK quantification sub-group. And Dr Robert Maynard and Dr Heather Walton, both on the COMEAP “secretariat” of government employees who work with the academic experts. Walton is now a member of Kelly’s Environmental Research Group (ERG) at Imperial College. We also have Dr Ian Mudway, who was on the 2011 HEI team. And Professor Jonathan Grigg, who will feature prominently later.

Could all this be, not just groupthink, but groupthink controlled by, and spread by, the WHO? An organization that has openly stated its desire to take control of the whole world, at least in the arena of public health in pandemics? We know that he who pays the piper calls the tune. And the EU was not only a funder of these projects, but has its own groupthink too. Could it be that WHO and EU groupthink and alarmism may have infected the scientists they fund? Who then seek to confirm or amplify the scares, in order to secure further funding?

The scientific cadre in air pollution toxicology is small – smaller than in “climate science.” And many of its members have been working in it for 20 years and more. Could this, perhaps, be like the dynamics through which most climate science has been warped into alarmist activity, that has nothing to do with science? Could air pollution science, too, have become corrupted? Could it have been used simply as a ruse to “justify” bad political policies?

2014

In 2014, the main news on the air pollution front was that the European Commission, the executive of the EU, took the UK to court for exceeding nitrogen oxides (NOx) limits. They found “non-compliances” in London and South Wales in short-term exposures, and in several other areas in longer-term ones.

2015

In 2015, DEFRA (Department for Environment, Food and Rural Affairs) issued a report on NOx pollution, giving a central estimate of 23,500 deaths in the year 2013, and an error range of a factor of 4: [[8]]. It was not clear how much overlap there might be with deaths caused by PM2.5 pollution. They also admitted that the previous estimates for PM2.5 may well have been high.

They also referenced a report by Dr Heather Walton (of the COMEAP Secretariat) and others, which looked at health impacts of nitrogen oxides in London. It was prepared for Transport for London (TfL). It claimed that, using coefficients based on the opinions of the HRAPIE “expert stakeholders,” deaths in London attributable to nitrogen oxides were actually higher than those attributable to PM2.5!

To me, that’s really hard to believe. Where is the historical evidence that nitrogen oxides alone can cause significant bad health effects? And if “expert elicitation” doesn’t work well to determine the confidence limits in an estimate, how can we possibly expect it to work in determining the estimate itself? Nevertheless, this report was probably what caused Euro 5 diesel cars to be included in the ULEZ charging scheme, while Euro 5 petrol cars are exempt.

In that same year, the Volkswagen diesel scandal erupted in the USA. What insiders had known since 2006 – that many diesel cars did not actually meet, in real-world driving, the standards they were supposedly built to – now became public knowledge.

Also in 2015, the Euro 6 vehicle standards came in. Cars built to this standard, even diesels, are (for now) exempted from ULEZ.

The UN’s Sustainable Development Goals

I cannot leave behind the year 2015 without mentioning the agreement of the UN’s “Sustainable Development Goals” in September of that year. The goals themselves are at [[9]]. My own, entirely negative, review of them is here: [[10]]. I described the goals as “a blueprint for the destruction of human civilization as we know it, and for tyranny by a self-appointed global ruling class over every human being alive.”

The goals include a commitment to: “By 2020, halve the number of global deaths and injuries from road traffic accidents.” That didn’t happen, did it? In the UK for one, the numbers pretty much flattened.

And: “By 2030, enhance inclusive and sustainable urbanization and capacity for participatory, integrated and sustainable human settlement planning and management in all countries.” If I read that right, it means force us all into cities. Where we can enjoy “safe, affordable, accessible and sustainable transport systems for all, improving road safety, notably by expanding public transport.” The UN, again and again, shows itself to be hostile to personal choice in the environment in which we live our lives, including transport.

2016 to 2019

The RCP report of 2016

The major event of 2016 in the anti-car policy field was the publication of a report jointly produced by the RCP (Royal College of Physicians) and the RCPCH (Royal College of Paediatrics and Child Health). It was titled “Every breath we take: the lifelong impact of air pollution.” You can find it here: [[11]].

In my 2017 social cost paper, I wrote of this report: “The chair of the RCP’s working group, Stephen Holgate of Southampton University, was also on the panel that produced the COMEAP report back in 2009… And the vice chair, Jonathan Grigg, was quoted in the mayor of London’s press release: ‘To maximise the effectiveness of this initiative, the Government must now act to remove the current toxic fleet of diesel cars, vans and buses from all our roads.’”

We have met Professor Holgate before. Professor Grigg now joins him centre stage. And I should mention Dr Gary Fuller, who was also involved in this report. Fuller is a senior lecturer in air pollution measurement at Imperial College London, and describes himself as “passionate about communicating air pollution science to policymakers and the public.”

I wrote of the RCP report: “Even the title of this report is alarmist. It has a general tone of rampant greenism and nanny-statism. And it includes the phrase ‘climate change’ more than 70 times. This is zealotry, not science.”

Here is the report’s take-home message. “…while recognising that COMEAP’s research on this issue is continuing, this report adopts a combined estimate of effect [of PM2.5 and nitrogen oxides] of around 40,000 deaths annually with an associated annual social cost of £22.6 billion (both with a range for a central estimate of ±25%).”

That figure of 40K deaths per year went viral in the media. Good theatre, eh? But I noticed two odd things about this conclusion. One, the error range is an order of magnitude smaller than the DEFRA figures it was based on. That can’t be right. Two, where are the death certificates? If 40,000 deaths were caused by air pollution in a year, then a significant fraction of them ought to specify “air pollution” as at least a contributor to one of the causes of death. And how many did? As far as I can make out, one. The 40,000 was even described by one expert as a “zombie statistic.” Every time it’s debunked, it comes back again!

Other events of 2016

Another significant event of 2016 was the publication by COMEAP of a report on chronic bronchitis: [[12]]. What it says is not particularly interesting. But the list of participants is thought-provoking indeed. The chair of the working group was Professor Frank Kelly. Professor Jonathan Grigg had been added to the list of participants. And Dr Heather Walton had been promoted from the Secretariat to the main committee.

Meanwhile, the EU had issued its National Emission Ceilings Directive. This “sets UK-wide emission reduction commitments for five damaging air pollutants, as well as obligations for the quantification and reporting of air pollutant emissions.”

In the same year, 2016, the UK government instituted a new “National Productivity Investment Fund,” which was committed to reducing emissions. And a plan was put forward to implement Clean Air Zones in “relevant local authorities in England” and in Wales. In these zones, so they said, “there will be a need to understand quickly and easily whether a given vehicle will be able to enter free of charge.”

2017

In 2017, the UK government issued two revised air quality plans. These were produced, so it seems, in response to High Court judgements. The Guardian reported on the second of these judgements here: [[13]]. The cases had been brought by an extreme activist lawfare NGO called “Client Earth.”

The first was a Draft UK Air Quality Plan for “tackling” (that word again) nitrogen dioxide: [[14]]. This lays the foundation for Clean Air Zones, charging entry fees for non-compliant cars and vans. It explicitly plans ULEZ, from the “T-charge” implemented in 2017, via the launch of ULEZ in 2019, to its extension to the North and South Circular Roads, that was to happen in 2021. So, this was something agreed on by both the Tories, in national power, and Labour, represented by mayor of London Sadiq Khan. It also introduces “low emission neighbourhoods.” And it demands “putting a significant shift towards walking, cycling and public transport use in the forthcoming Mayor’s Transport Strategy.”

It also talks of “tougher, legally binding ceilings for emissions for 2020 and 2030.” Without having asked the people, or even having a public debate! And: “In future we will need a wider range of approaches to tackling harmful air pollution.” Furthermore, it says: “The limit values are based on the World Health Organization’s (WHO’s) air quality guidelines.” But the given rationale for restricting nitrogen oxide emissions in 2017 was to meet the EU’s limits, which are considerably higher than the WHO’s. This is zealotry, not democracy.

The second, two months later, was a plan for “tackling” roadside levels of nitrogen dioxide in towns and cities: [[15]]. It is softer in tone than the earlier draft. Under “Impact on individuals,” it says: “This package of measures will support delivery of our obligations on air quality in the shortest time possible. We are clear, however, that this must be done in a way that does not unfairly penalise ordinary working families who bought diesel vehicles in good faith.” They also required local authorities to use “measures… carefully targeted to minimise their impact on local residents and businesses.”

But since 2017, the government have reneged on these commitments, again and again. ULEZ expansion to Outer London, Oxford traffic filters, and more.

One other notable event in 2017 was a letter written to then prime minister Theresa May by a pressure group calling itself “Doctors against Diesel.” [[16]]. This lamented that the draft air quality plan “failed to tackle emissions at source.” And that it had no new Clean Air Zones, and discouraged charging zones. The principal signatory was Professor Jonathan Grigg, and Professor Stephen Holgate was also a signatory. On the list also is Professor Chris Griffiths of Queen Mary University, who was also involved in the 2016 RCP report, and will appear again later in the story.

The COMEAP NO2 report 2018

In 2018, COMEAP issued another report: [[17]]. It is titled: “Associations of long-term average concentrations of nitrogen dioxide with mortality.” This aimed to derive “a new single-pollutant summary estimate” for NO2. It seems odd, to me at least, that DEFRA and others had been pushing draconian NOx reduction policies, when COMEAP had not even completed their studies of what the effects of any such reductions would be likely to be. By this time, Professor Frank Kelly was chair of COMEAP. The committee now had 20 members.

The report shows evidence of its rather confused genesis. “Policy needs have determined the focus on NO2 in this report.” “There is now stronger evidence associating health effects with outdoor concentrations of NO2.” Well, maybe; but the only evidence cited is the WHO’s REVIHAAP and HRAPIE. Not to be trusted, in my book. “We have decided against formally deriving an NO2 coefficient adjusted for effects associated with PM2.5.” But isn’t that exactly what any policy assessment needs? Maybe it was too hard to do in the timescales? Instead, they chose “to propose a reduced coefficient which may be used to quantify the mortality benefits of reductions in concentrations of NO2 alone, where this is necessary.”

Now with this report, for the first time, COMEAP could not reach agreement on its conclusions. The majority view included the following: “There is a case for an NO2 contribution of unknown size.” “If NO2 itself has a role in the associations found in studies of long-term exposure, this may reflect the aggregate effects from short-term exposures rather than additional effects of long-term exposure to NO2 itself.”

Yet, they went ahead, and gave “a summary coefficient … of the association with mortality of 1.023 per 10 µg/m3 of NO2 as an annual average.” And: “A reduced coefficient within the range of 1.006 to 1.013 per unit… for estimating the effects attributable to NO2 alone.” But: “There was substantial heterogeneity between the estimates from different studies.”

So, the NO2 contribution, if there was one, was of “unknown size.” Yet they multiplied it by some magic number, and came up with 1.023? Madness. And definitely not science.

It looks to me as if, this time round, COMEAP faced all the same issues they had faced in 2009, and more besides. They couldn’t just rely on the authority of the WHO this time round. So, the majority, led by Professor Kelly, ignored the uncertainties in their rush to produce numbers that would “justify” policies for draconian reductions in nitrogen oxide emissions.

The dissenting view

The dissenting group consisted of Professors Anderson and Atkinson and Dr Maynard. They criticized “the inadequate consideration of uncertainties.” They said: “In our view there is insufficient evidence to infer a causal association between long-term average ambient NO2 concentrations and risk of death.” If this is so, then there is no scientific basis at all for any policy to force reductions in NO2 emissions.

Moreover, they said: “COMEAP should resist the temptation to produce ‘headline’ results justified by an obligation to inform public debate when the evidence base for such calculations is limited, highly uncertain and complex.” This, I think, is the nub of the dispute. And I have no doubt at all that the dissenters are right. Such a “headline” is almost bound to lead to policies that are wrong, costly, and overall bad for the people.

The dissenters “very much disagree with estimating the burden down to concentrations lower than those contributing to the original risk estimates.” They accepted the coefficient of 1.023, not as an association with mortality from NO2 alone, but from a mixture of NO2 and a whole range of other pollutants that are always found with it; a lot of which are already accounted for as PM2.5. They said that the “high level of heterogeneity between the NO2 coefficients reported in individual studies … makes extrapolation to UK cities … subject to uncertainty.”

If I read their views right, they are saying that scientists simply don’t know enough with certainty about the risk of mortality from NO2 to draw any quantitative conclusions. I think they’re absolutely right about this. The evidence they examined does not support any method of accurately calculating the (putative) benefits in reduced mortality of NO2 reductions. Given this, it tells us nothing about the size of any such benefits. That leads me, as one who clings to the true precautionary principle and rejects the perverted version, to conclude that no policies at all to reduce NO2 emissions can possibly be justified by this evidence.

Other events of 2018

Two other events in 2018 were significant to the air pollution issue. One, the UK government founded an organization called “UK Research and Innovation.” [[18]]. They say: “We invest £8 billion of taxpayers’ money each year into research and innovation and the people who make it happen.” As of 2020, UKRI had over 7,000 staff.

Two, Professor Chris Griffiths, one of the signatories of the “Doctors against Diesel” letter, was about to publish a study, which investigated the impact of London’s LEZ on air quality and children’s respiratory health. Good for him, you will say. Now we can have some real data to chew over! Griffiths was the corresponding author; but the authors list also contains several names we already know. Mudway. Fuller. Grigg. Kelly. Here is the paper as published in the Lancet: [[19]]. The data had been collected between 2009 and 2013; a period which included the tightening of LEZ emission controls in 2012.

It is at around this time that some of the mainstream media started taking an interest in what had been going on over air pollution. In August 2023, the Telegraph revealed [[20]] that Shirley Rodrigues, deputy London mayor, had urged Professor Griffiths in 2018 to change the conclusions of his paper before publication. Professor Griffiths, to his credit, refused to do so. Perhaps, after his earlier vocal support for the anti-car cause, he had realized that his own research did not justify that position. Could it be “when the facts change, I change my mind?”

Ms Rodrigues complained: “It reads like Lez (low emissions zones) or similar have no impact at all.” The Griffiths paper does indeed say: “We found no evidence of a reduction in the proportion of children with small lungs over this period, despite small improvements in air quality in highly polluted urban areas during the implementation of London's LEZ.”

Now, this was a proper landmark. A real-world study had looked at the actual effects on health of a London air pollution limiting scheme. It had come up with no hard evidence of any health improvements due to the LEZ. And yet, political forces backing the “clean air” agenda had tried to suppress the scientific conclusions. That is suggestive, no?

2019

Not very much happened in 2019 on the UK air pollution front. Most green political activity was concentrated on the ridiculous scam of the so-called “climate emergency.” For those not already aware of that saga, I have documented it here: [[21]].

The one significant event on the anti-car front was that in April, the ULEZ came in to force in central London only. It replaced the previous toxicity “T-charge.”

2020

2020 was, of course, the year of the COVID panic. It was also a busy year for anti-car extremists in the UK.

Perhaps the most significant event of the year took place behind the scenes. The UK government’s “Green Book,” which is supposed to set out procedures for the cost versus benefit analysis of government projects, was updated. Projects deemed to be “strategic,” including “net zero” and “clean air,” in effect became exempt from all requirement for cost-benefit analysis. It is no coincidence, I think, that the review that initiated these changes began in March, right after Rishi Sunak was appointed as chancellor in place of Sajid Javid.

In July, the government held a “consultation” on the issue of “de-carbonizing transport.” I spent almost a month writing a 56-page, reasoned response, with many good arguments why nothing needed to be done at all, and everyone should be left free to choose whatever form or forms of transport best suit them and their circumstances. But all the points I, and others of like mind, made were totally ignored. This showed that the whole “consultation” was just a rubber-stamping exercise for the deep green political agenda. A rubber stamp, which they then used to pull the date of the ban on petrol and diesel vehicles forward from 2040 to 2030.

All this took place against the background of the unfolding of other parts of the green and globalist agenda. It was in 2020 that we first heard about the “Great Reset.” It was described as: “a new equilibrium among political, economic, social and environmental systems toward common goals.” In which the future is: “a globalized world… best managed by a coalition of multinational corporations, governments (including through the UN system) and select civil society organizations.” Obviously, we ordinary, honest, productive human beings have no place in such a world, except perhaps as slaves. 2020 was also the year in which the Tories unveiled their “Ten Point Plan” for a “green industrial revolution.” I have written about this here: [[22]]. One of its main thrusts was “accelerating the shift to zero emission vehicles.”

On air pollution more specifically, COMEAP issued a summary of their recommendations for the quantification of the health effects of various air pollutants: [[23]]. Dr Heather Walton chaired the working group that produced this. Of course, these recommendations were based on their earlier reports, whose reliability was suspect. They also noted that DEFRA had “chosen to risk over-estimation of benefits associated with interventions, rather than risk under-estimating them.” Thus, creating a further systemic bias in favour of policy action. As if the perverted form of the precautionary principle wasn’t biased enough already.

COMEAP also issued a report on health effects of non-exhaust pollution associated with road traffic: [[24]]. The chair of this working group was Professor Frank Kelly. Major conclusions were: “Adverse health effects are associated with proximity to traffic, traffic intensity or concentrations of traffic-related air pollutants.” “Particles from these sources could pose a hazard to health. However, it is not clear whether real-world concentrations of non-exhaust PM from road transport would have significant effects.”

In other news, a “Clean Air Programme,” managed by UKRI, was instituted. And a “Clean Air Day” was instituted, yearly in June. This is promoted by what looks like a highly activist group, “Action for Clean Air.” [[25]]. Its web page says: “The World Health Organisation and the UK Government recognise that air pollution is the largest environmental health risk we face today.” Yeah, right. You expect people to believe either of those two organizations?

2021

In 2021, the WHO issued new Air Quality Guidelines: [[26]]. The guideline for PM2.5, already low at 10 µg/m3, was reduced further to 5 µg/m3. This limit is so low, that researchers have pointed out that in many parts of the world, PM2.5 levels would exceed it even if there were no anthropogenic emissions at all! [[27]]. Even for those who are not yet cynical over the matter, this calls seriously into question the WHO’s motives in setting these guidelines.

In October, the London ULEZ charges were extended out to the North and South Circular Roads. Thus, making the region within about 5 miles of central London effectively into a “no go area” for those drivers, who cannot afford either to pay the fees or upgrade their cars.

The first Clean Air Zones were implemented in 2021, in Bath, Birmingham and Portsmouth.

A détour to reality

In November, a paper (Ma et al.) was published by three researchers from Imperial College London: [[28]]. Its title was, “Has the ultra-low emission zone in London improved air quality?” Its take home message was: “Aggregating the responses across London, we find an average reduction of less than 3% for NO2 concentrations, and insignificant effects on … PM2.5 concentrations.” That is, over the period from 39 months before the start of ULEZ in April 2019, to 9 months after it. It also said: “The ULEZ caused only small improvements in air quality in the context of a longer-term downward trend in London’s air pollution levels.”

But this was not to the taste of deputy London mayor Shirley Rodriguez. As revealed in 2023 by the Independent [[29]], Rodriguez asked Prof Frank Kelly, head of Imperial College’s “Environmental Research Group”, to issue a statement that contradicted the findings of the study. The very same Professor Kelly who has already appeared in this story several times, including as chair of COMEAP. Unlike Professor Griffiths, Kelly chose to co-operate with this political whitewashing exercise. More than any other incident, this was the one which caused me to re-examine COMEAP’s reports and processes with a far more critical eye.

Clean Air Champions

Also in 2021, a list of “Clean Air Champions” within UKRI’s Clean Air Programme was announced: [[30]]. The first name on the list? Professor Stephen Holgate, no less. And the second was Dr Gary Fuller, who had also been involved in the highly alarmist RCP report.

The About page for the Clean Air Programme regurgitates the 40,000 deaths nonsense from the RCP report. And it reveals that UKRI funds it through a “Strategic Priorities Fund.” The word “strategic” is interesting – is this why there hasn’t been any cost-benefit analysis?

The home page is even more interesting. “Our community of engaged researchers and scientists enable the UK to address these challenges and effect change where it is needed, whether through policy, behavioural change, or legislation.” Nasty stuff: they’ll be setting the “nudge unit” on us pretty soon! … Oops, Surrey County Council is already doing that. As you’ll see in the next essay.

Environment Act 2021

And then there was… this: [[31]]. “A Bill to make provision about targets, plans and policies for improving the natural environment; for statements and reports about environmental protection; for the Office for Environmental Protection; about waste and resource efficiency; about air quality; for the recall of products that fail to meet environmental standards; about water; about nature and biodiversity; for conservation covenants; about the regulation of chemicals; and for connected purposes.”

There is an overview of the act’s provisions here: [[32]]. I suggest you take a sick-bag with you. “The most ambitious environmental programme of any country on earth…” “The Act requires the Sectary of State to set at least one long term target in each of the four key priority areas: air quality; biodiversity; water; and waste. This will be achieved by a set of measures targeted at UK businesses and supply chains.” “The Act set a legally binding duty on the government to bring forward at least two new air quality targets by 31 October 2022.” This is exactly the kind of crap that so many of us voted for Brexit in order to get away from!

To seek to improve the “natural” environment is all very well and good. But not if the costs to us human beings are greater than the benefits. It is as if the madmen currently in charge of the “ship of state” have set something they call “the natural environment” up on a pedestal, like a deity. And they want to force us to worship it. While, at the same time, they are trashing our environment – the environment we human beings need in order to live happy, fulfilling lives. A vital part of which is the freedom to make our own choices and decisions, in transport and in all other areas of life; provided, of course, that we take full responsibility for the effects of our actions on others around us.

So, where are the proposals for improving the human environment? Where are the “targets, plans and policies” towards what we human beings really need? World-wide peace? Objective justice? Upholding our human rights and fundamental freedoms? Maximum freedom to make our own choices and decisions? Prosperity for all who earn it, and continuing human progress? Now, that would be an “environment bill” worth having.

But what we have is completely the opposite. Those that promote, support, make or enforce bad green policies like these are showing themselves for what they are – enemies of humanity. I call foul on this anti-human bill, and on all those involved with it.

UK Air Quality Report

Lastly for 2021, in September 2022 DEFRA issued a “UK Air Quality Report” for that year: [[33]]. The only “exceedance” of the PM or NOx limits (presumably, the same limits previously set by the EU) was in annual mean of NO2, in 10 regions out of 43. But looking at the figures more closely, the problems are restricted to three places: London, Glasgow and South Wales. For most pollutants, the comparison of actual concentrations with EU limits is actually not that bad. And that’s if you accept the EU limits as valid in the first place. When have any of us been allowed to vote for or against such limits?

The report mentions that the 2018 National Emissions Regulations set emissions reductions commitments all the way out to 2030. But these were forced on us by an EU directive – exactly the kind of crap so many of us voted for Brexit to get away from! We’re still waiting for the “bonfire of the regulations” that we voted for.

And yet, the maximum annual mean for PM2.5 is now planned to be down to 10 µg/m3, the 2005 WHO “guideline,” by 2040. We badly need to get away from the WHO, too – and not just for pandemic reasons. We need WHOexit, if not also UNexit as a whole.

The Chemical Hazards and Poisons Report 2022

In 2022, there was so much going on in the general political arena, that my eye was “off the ball” on air pollution for most of the year. But one interesting, and very strange, document did come inside my radar range. This was a report from the UK Health Security Agency (HSA), titled “Chemical Hazards and Poisons Report,” and dated June 2022: [[34]].

The sub-title is “Reducing health harms associated with air pollution.” The document is described on the introductory web page as follows: “This special edition provides an overview of the UKHSA Cleaner Air Programme and describes recent work to build the evidence-base, improve awareness and understanding, and influence and support stakeholders to take action to improve air quality and health.”

About

The section “About the UK Health Security Agency” (at the end) describes the remit of the agency. “UKHSA is responsible for protecting every member of every community from the impact of infectious diseases, chemical, biological, radiological and nuclear incidents and other health threats.”

I also found out that the HSA was only formed in 2021, out of the “health protection” part of the failed former Public Health England (PHE).

Foreword

The Foreword is written by David Rhodes, Director of Environmental Public Health Transformation at the HSA. Transformation? That sounds like United-Nations-speak to me. And it’s undemocratic. I, for one, do not need or want to be “transformed.” And I know I’m not alone in this. But we have never had any chance to say “no” to UN-imposed policies.

It gets worse. David Rhodes is a member of the Sustainable Development Special Interest Group at the Faculty of Public Health (FPH) of the Royal College of Physicians (RCP). The FPH [[35]] is “a membership organisation for over 5,000 health care professionals” and a registered charity. The RCP, of course, showed its alarmism in the 2016 report, produced by a working party chaired by Professor Stephen Holgate, whom we met earlier.

Here’s an example of the kind of stuff the FPH and Rhodes get involved with: [[36]]. ULEZ consultation submitted. Non-proliferation fossil fuel treaty. Advocacy working group. Engaging with COP27. Climate Change and Litigation Toolkit. Greener NHS.

On this evidence, these are a bunch of rabid, activist green fanatics. And a director-level government employee hobnobs with them? That isn’t in the interests of us the people, is it?

Clean Air Programme

The rest of the document covers a series of subjects. The first chapter is about the Clean Air Programme. The Clean Air programme is led by the Met Office [[37]] and NERC [[38]]. NERC, the Natural Environment Research Council, is part of UKRI (UK Research and Innovation), which funds the Clean Air Programme through a “Strategic Priorities Fund.” It describes itself as “the driving force of investment in environmental science.” And the Met Office needs no introduction, particularly to those who follow the “climate change” issue. Its blaring protestations of “the hottest day, or week, or month EVAH!” come so often, that the only sane response to them is laughter. They almost always prove to have been wrong. And even if they are right, that signifies nothing. The world has been warming for at least 350 years.

One of the authors of this chapter is Dr Karen Exley, who not only was on the working party for the 2016 RCP report, but has also been on the Secretariat of the Committee on Medical Effects of Air Pollution (COMEAP) for pretty much all its work since 2010. Exley is at the University of Leicester, where her bio describes her as “national lead for UKHSA’s strategic priority programme on Cleaner air.” [[39]].

Some interesting tidbits are provided about the Air Quality and Public Health (AQPH) group within the HSA. “The AQPH team has a unique role sitting at the interface between academia and policy, where it is well positioned to achieve the long term aims of the programme.”

These “long term aims” include: “Improving awareness.” “Understanding and encouraging behavioural change at all levels.” “Influencing and supporting stakeholders to take action to reduce the burden of health of air pollution and address health inequalities.” Is this serving the people, as government ought to? No; this is deep green activism. They take our money, and use it to work against our interests. That is very bad faith, and I call foul on it.

Mortality burden estimates

The section “Updated mortality burden estimates attributed to air pollution” is authored by Exley, Dr Heather Walton whom we met in the previous essay, and two others, Ms Alison Gowers and Dr Christina Mitsakou, both of whom have been in the Secretariat on several COMEAP publications. Now, it looks as if these are all but permanent positions. For the document says that the UKHSA AQPH team “provides the scientific secretariat for” COMEAP. And that “Based on COMEAP’s advice the UKHSA has updated mortality burden estimates due to air pollution.” So, this is what the HPA, that played a significant part in the 2009 and 2010 COMEAP reports, has morphed into.

It reports that COMEAP had recently increased its risk coefficient for long-term exposure to PM2.5 from 1.06 to 1.08. COMEAP also recommends that “quantification can be carried out to very low PM2.5 concentrations by assuming a log-linear shape for the concentration response function.” (Where is the research that justifies these assumptions?) As a result, the estimated mortality burden of air pollution appears to have gone up between 2013 and 2019! Even though actual pollution concentrations went down over that period. What a cunning way to try to make out a case that “it’s worse than we thought.” And why should anyone want to extrapolate to concentrations lower than anything we’ve seen in more than 200 years?

It looks as if all the protestations of Professors Anderson and Atkinson and Dr Maynard have been ignored. Not only that, but they have increased their risk coefficient, without giving any justification! Strange, given that DEFRA had said in 2015 that even the 1.06 value was probably an over-estimate.

To me at least, COMEAP is no longer credible as a source of scientific advice. All its past work should be independently, objectively, honestly and critically reviewed, with proper cost-benefit analyses from the point of view of the people. And any policies its work spawned, that are found not to be a nett benefit to the people, should be struck down.

Air pollution targets

Gowers, Mitsakou and Professor Frank Kelly wrote the section on “Setting air pollution targets under the Environment Act 2021.” Kelly is the former chairman of COMEAP, who co-operated with London deputy mayor Shirley Rodrigues in trying to whitewash research done by some of his very own fellows at Imperial College London.

This section includes: “COMEAP advised that the recent evidence suggests that continuing to reduce PM2.5 concentrations as much as possible would benefit public health.” And: “COMEAP’s view was that reducing exposure of the whole population would achieve the greatest overall public health benefit.” Oh, how great that sounds! But at what cost?

“Important points from the advice were that, in order to maximise benefits to public health, the targets should include a focus on: (1) Reducing long-term average concentrations of PM2.5. (2) Reducing exposure of the whole population. (3) Continuing to reduce exposures even where concentrations comply with a ‘limit value’ type target.” Aha, that must be why they want to extrapolate down to lower and lower concentrations. If we let them do that, they will never lack an opportunity to “justify” a new, tighter “target” or “limit.”

Well, there you have it. Exposed in black and white for all to see. This is not about solving a health problem – even if current levels of air pollution actually did constitute such a thing. It is about screwing us human beings. Screwing each and every one of us. Screwing us harder and harder. And carrying on screwing us again and again and again. I am reminded of George Orwell’s famous “boot stamping on a human face – forever.” But this is more like “a boot stamping on a human face harder and harder – forever.”

Air quality in Wales

The section “Air quality in Wales: an update on policy and practice” talks of “the need to embed the positive changes in travel behaviours that resulted from COVID-19 to support longer term ambitions to reduce air pollution.” Odd, that. I, for one, went almost everywhere by car during COVID. Like many others, I did not use public transport due to the infection risk. Even though I had already had, and recovered from, COVID before the first lockdown.

It talks of “new targets for particulate matter which account for WHO guidelines.” This is yet another case of shifting goalposts, prompted by the UN’s World Health Organization. It talks also of “a pledge to cut the default speed limit from 30mph to 20mph where people live, work and play.” Well, now our Welsh friends know where that idea came from!

Some other sections

The section “Air quality research in the … Health Protection Research Units” is authored by, among others, Exley and Rhodes. A section on “The effect of fragrant products” is co-authored by Professor Anna Hansell, whose bio at the University of Leicester (the same place as Exley) lists her as the current chair of COMEAP. Exley is also a co-author of the section on “UKHSA involvement in UKRI Clean Air Programme research networks.”

Global Action Plan

But the proverbial “cake” is taken by the section titled “Health professionals are vital in the battle against air pollution.” The author is “Director of Clean Air” for an outfit called Global Action Plan: [[40]]. This is “an environmental charity working towards a green and thriving planet, where everyone can enjoy happy and healthy lives within the Earth’s limits.” And they “mobilise people and organisations to take action on the systems that harm us and our planet.” What is anyone in government, which is supposed to be serving us the people and bringing a nett benefit to us, doing consorting with megalomaniacs like these?

Well, there you have it. The cat is out of the bag. Now we can all understand, from their very own words, what kind of zealots we are up against. Which seems as good a juncture as any to end this particular essay.


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