The Back-story behind Anti-Car Policies in the UK, Part Three: The COMEAP Report of 2009

This is the third in 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 looked at the most significant air pollution episodes, other than leaks of specific chemicals, which have demonstrably had significant negative health effects on large numbers of people. In the second, I told the back-story on air pollution politics, from the beginnings of the green agenda in the early 1970s through to the year 2008.

Today, I will look at a report produced in 2009 by the UK government’s Committee on the Medical Effects of Air Pollution (COMEAP). It constituted a watershed, by laying an apparently scientific foundation for the development of policies to control particulate matter (PM) pollution in the UK.

I do not claim to be an expert on toxicology. I am a mathematically and scientifically trained generalist, who has a nose for hard evidence and data, and a strong sense of rightness and wrongness, both technically and ethically. I am also convinced, by other evidence I have seen, that on a closely related subject, climate change, groupthink among “scientists” and experts has fuelled catastrophic scares that, viewed through the lens of hard evidence, are at the very least grossly exaggerated, and likely totally illusory.

Moreover, I have found myself, over the years, having to become something of a philosopher. And the philosophy of science is one of the areas I have looked at. Indeed, an article I wrote in 2018 describing the scientific method was re-published at “the world’s most viewed web site on global warming and climate change.” [[i]].

This essay will be a little more technical than the others. But I do not apologize for this. The nature of the subject matter means that a dive into science is unavoidable.

What COMEAP did

COMEAP looked at “risk coefficients” which had been estimated in air pollution studies, trying to assess which of these were most appropriate to be used in the UK. The definition of risk coefficient is: “A quantity expressing the increase in risk per unit of exposure or per unit dose.” Thus, at a particular level of air pollution exposure, the risk coefficient gives the relative (or percentage) increase in risk resulting from a one unit rise in the level of exposure. It can be quoted either as a “relative risk” multiplier, or as a percentage change. Thus, a risk coefficient of 6 per cent per unit is equivalent to a relative risk of 1.06 per unit.

It was in 2017 that I first looked at the 2009 COMEAP report: [[ii]]. Its title is “Long-Term Exposure to Air Pollution: Effect on Mortality.” In that exercise, my interest was in calculating the social costs of pollution from cars in London. I did this in order to compare these costs with the fees to be charged by the then forthcoming (starting in 2019) ULEZ (Ultra Low Emission Zone). My resulting paper is here: [[iii]].

I did, at the time, comment on a few oddities in the way the report treated its subject. But I had no notion that there might be anything amiss, either with the process through which the report was produced, or with its conclusions. Now, I already knew about the scientific shenanigans, which had been going on in UK government circles over the climate change issue. Climategate whitewashes, BBC mis-reporting, interfering with the conclusions of an early IPCC (UN Intergovernmental Panel on Climate Change) assessment report, blocking of any possibility of objective cost-benefit analysis on policies, and more. Despite this, I assumed, naïvely, that the apparently separate issue of air pollution ought to have been addressed honestly and without bias.

But since then, I have learned about the conduct of government scientists and advisors involved in assessment of air pollution, including a chairman of COMEAP. This has caused me to take another, far more critical, look at this 2009 COMEAP report. I also examined several later follow-up reports. I shall recount in the next two essays some of the findings and incidents, which led me towards the much more cynical view which I now hold on the matter.

Things that weren’t quite right

Even back in 2017, I had noticed a number of things about the 2009 report which didn’t look right.

Burden of pollution, or rate of change?

First, the focus was not, as I would have expected, on how much damage is caused by a particular level of pollution (the burden). After all, that is what you need in order to work out whether or not the problem is big enough to need action. Instead, the focus was on how the damage changes when you reduce (or increase) the level of pollution. That is, the slope, or rate of change, of the damage function at a particular pollutant concentration.

It seemed, to the mathematician in me, a bit odd to choose to estimate, not the quantity you ought to be wanting to assess across the spectrum of pollutant concentrations, but its first derivative. At the time, I described this as “cart before horse.” Perhaps, I thought, the policy cart (reducing emissions) might have been pushing the evidence horse (finding the actual burden of a given level of air pollution)?

To have assessed the burden, rather than the risk coefficient, may well have been a more difficult set of calculations than the ones they did in 2009. But it was certainly feasible. The subsequent 2010 report, indeed, did it! Also, unless the burden is near perfectly linear in the pollutant concentration over a large range, the risk coefficient will vary depending on what is the concentration at the point of interest.

Expert elicitation

Second, I was flummoxed by the “expert elicitation” exercise, which COMEAP undertook to try to put error bounds around their central estimate. Seven experts waved wet fingers in the air, and estimated how likely they thought it was that the true risk coefficient lay in different ranges. These guesstimates were then pooled, and the results expressed as a 75% confidence range. That is, a range within which there are three chances in four that the value lies. And even this had a factor of 12 between the lower and upper bounds (1 to 12 per cent)! To those used to 95% confidence limits and fairly tight error ranges, this was unimpressive, to say the least. Particularly as evidence given by experts to support the imposition of policies on millions of people.

Nor was there much correlation between the estimates of different experts, let alone anything like a consensus. Indeed, one expert gave every percentage from 0 to 17 almost the same chance. In other words, he was saying “I have no idea at all what the true risk value may be”. Was he really an expert, then? Another reckoned there was a half chance of the risk coefficient being less than 1 per cent; only one-sixth of the pooled best estimate.

Adjustment for nitrogen oxides

Third, the attempts to combine separate risk estimates for PM_2.5 and nitrogen oxides into a single figure did not appear to me to be very successful. I found myself having to use a value for the overlap factor, that was derived from a much later report, from 2016. And an alarmist one, at that. This subject was to rear its head again, in a big way, in a 2018 COMEAP report.

More things that aren’t quite right

When I re-read the 2009 report with my new, more critical attitude, I found some further oddities.

The UN and its WHO

My first observation was a general one. The report took a lot of account – a lot! – of the recommendations of the United Nations World Health Organization (WHO). Which had “proposed that the relative-risk coefficient for all-causes of mortality for the average exposure level reported in the extension of the ACS study (Pope et al, 2002) should be used.” And COMEAP ended up using precisely this value for their headline estimate. “Our recommendation[s] for the individual coefficient[s] that express the relative risk[s] associated with a  increase in PM_2.5 are: For all-cause mortality: Best estimate 1.06…”

The WHO, being part of the UN, is a political organization. It is both unelected and unaccountable. As everyone should know, the UN has been the driving force behind the green agenda since the early 1970s. Its Rio Earth Summit of 1992 has led to a long series of ever tightening green regulations, that bit by bit have impoverished us and taken away our freedoms. And at its Sustainable Development Summit in 2015, our supposed representatives signed up to the UN’s “Sustainable Development Goals.” Which I have described 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.” [[iv]]

The UN had already become activist in the field of air pollution well before 2009. Notably, in 2005 the WHO updated its air quality guidelines to specify a guideline concentration for PM_2.5 of 10 micrograms per cubic metre. This was an order of magnitude lower than previous limits. Even than the EU’s limit of 25 µg/m³.

The WHO has also acquired a very negative reputation in recent years, as a result of its poor handling of the COVID pandemic, and its subsequent political moves to take unilateral control of world-wide pandemic responses. So, I became suspicious. Might the decision by COMEAP back in 2009, to follow the WHO’s recommendation closely, have been a political one rather than a scientific one? Was the WHO, in actuality, the driver of air pollution policies in the UK?

Long-term or episodic exposures?

My second observation was, this report is looking only at long-term exposure to pollution. In the foreword, they said that their earlier work “has allowed estimates of reducing levels of air pollutants to be included in the Air Quality Strategy for the UK.” And yet, the factual evidence, including that from the Great Smog of 1952, tells us that all the most serious pollution events have involved a large, transient spike in pollutant concentrations. In other words, a large episodic exposure, rather than a smaller long-term one.

This raised in my mind the question, is air quality policy actually being driven by the evidence? Or might a politically desired policy be pushing the experts towards results that support that policy? Could this be a case of, in the words of former MP Peter Lilley, “policy-based evidence?” That would certainly be consistent with the WHO being the policy driver.

PM_2.5 alone, or PM_2.5 with sulphates?

My third observation was that they chose PM_2.5 as “the most satisfactory index of particulate air pollution for quantitative assessments of the effects of policy interventions.” But all the most serious pollution events have involved other pollutants beyond PM_2.5. Indeed, virtually all have involved both PM_2.5 and sulphates.

Yet COMEAP say: “We have looked in detail at the case for treating particulate air pollution measured as ‘sulphate’ differently from PM_2.5 but have not been convinced that the available evidence warrants and enables this.” This rather evasive statement made me concerned that COMEAP might be hiding something.

They even say: “The interpretation of the associations found with sulphur dioxide is not clear cut.” Even though the Health Effects Institute (HEI), in an earlier review, had said that adjustment for sulphur dioxide (SO₂) did reduce the relative risks substantially.

The report also mentions studies from Dublin and Hong Kong, on the effects of sudden reductions in pollutant concentrations on mortality rates. “In the Dublin study, both particles and SO₂ declined; in the Hong Kong study, the main effect was on sulphur dioxide.” Both “confirmed that noteworthy and sustained reductions in death rates can occur soon after a major reduction in air pollution.” This suggests that SO₂ is a major contributor to mortality, and its toxic effects may well be more from short-term episodes than long-term exposures. This does, indeed, tally with the evidence from historical “smogs” and “hazes,” which I looked at in the first essay of this set.

When the risk coefficients from the earlier studies are presented together in a table, they are all over the place. Some, notably James Enstrom’s 2005 California Cancer Prevention Study, give all-cause risk percentages an order of magnitude lower than the 6 per cent recommended. Others give figures almost three times higher. And generally, studies conducted over smaller geographical areas tend to give higher risk coefficients than larger ones. These together suggest that, contrary to COMEAP’s focus on PM_2.5 alone, other local toxic pollutants may well have more effect on mortality than the PM_2.5 which may, or may not, carry them into the lungs.

The idea that “all PM_2.5 is equal” in toxicity does not seem to me to be anywhere near proven. Indeed, historical evidence, notably that from the 1952 Great Smog of London, strongly suggests that PM_2.5 and sulphates together are far more toxic than either of them alone.

There are several working papers included in the report, the first four of which treat the subject of sulphates. Working Papers 1 and 2 did not draw any conclusions. Working Paper 3 reviews much relevant literature, but the impression it gave me was that the author considered the state of knowledge on the matter to be simply not good enough to reach any objective conclusion on the interactions between PM_2.5 and sulphur compounds. That is not a good reflection on the science of toxicology, considering how much importance was now being given to a problem which had been known about since 1953!

Working Paper 4, however, concluded that: “There is reasonably consistent evidence that sulphate concentration in particulate matter is positively associated with adverse health effects in short-term exposure studies… and long-term exposure studies.” “This suggests that sources of particles that are related to sulphur-containing fuel combustion may have adverse health effects.” Of course, we already know that this is so – and the evidence goes right back to the Great Smog of 1952. Not to mention the ban on coal with a high sulphur content in Dublin, and the introduction of ultra-low sulphur diesel in the UK.

So, could COMEAP’s failure to consider adjusting for sulphates, perhaps, be a cop-out? A political ruse, to make the effects of PM_2.5 alone seem worse than they really are?

Confidence intervals

My fourth observation was that the recommended coefficient value is followed by “with 95% confidence interval (CI) 1.02 to 1.11.” These are exactly the error bounds given by Pope et al, and thus recommended by the WHO. This is curious, considering that the expert elicitation exercise had produced only a “75% plausibility interval” from 1.01 to 1.12 (1 to 12 per cent). I am surprised that no-one on the committee caught this one out. Or perhaps someone did, and was ignored or shouted down.

A flashback to 2006

My fifth observation relates to a copy of a COMEAP interim report dating from early 2006, which is included in the 2009 report. It contains a number of interesting statements. “The identity of the individual components of the ambient aerosol that affect health remain unknown.” “It is not possible to distinguish with confidence between the effects of the different components of the mixture.” “In the absence of clear evidence to the contrary, therefore, we consider that the coefficient should apply equally to all components of the mixture, including sulphates.” “PM_2.5 is our chosen index of pollution.” “Calculations should focus on the benefits likely to be delivered by changes in PM_2.5 rather than on estimating the total impact on health of current PM_2.5.”

This tells me that the general direction of this 2009 COMEAP report had already been set as early as the beginning of 2006. That they had already made the decision not to look in detail at the effects of combinations of PM_2.5 and sulphates. And that the decision to look at the effects of reductions, rather than doing a burden calculation in order to work out the magnitude of the problem, had already been taken. That makes me suspicious that the entire process might not have been honest.

A possibility of groupthink?

Now, the majority of COMEAP participants are academics, and the rest are government employees. In such environments, it is very easy for “groupthink” to arise among committee members, and among groups of co-workers. Particularly if some participants, and most of all if they are senior, have activist views, and may be able to influence others towards their points of view. It is also likely that, particularly in the early days, the small number of people working on the subject of air pollution toxicology (most of them in the USA) would have led them, too, to become prone to groupthink.

Indeed, such groupthink has been very much in evidence among those working on a subject not so far removed, climate change. And this has led to activist “scientists,” such as Michael Mann, fudging the scientific evidence in order to favour their desired policies.

Among the COMEAP experts who produced this 2009 report was Professor Stephen Holgate of Southampton University. Holgate was later chair of a working group, which in 2016 produced for the Royal College of Physicians an extremely alarmist report on air pollution. He was knighted in 2020 for “services to medical research.” He is also a “Clean Air Champion” for the Clean Air Programme, which by its own description is “proactively tackling the air quality challenges facing us all today.” There is no doubt on where Professor Holgate sits with regard to the politics of air pollution. I cannot judge whether he influenced other COMEAP members towards his own positions, but would guess that is not unlikely.

Peer review

Now, there was a peer review, which took place on an earlier (2007) draft of this report. The reviewers’ comments are in the report. The peer reviewers made some excellent comments. For example, Reviewer 1 asked: “If there really is a direct effect of SO₂, what will be the effect of ignoring this when estimating the impact of reducing PM_2.5?” And: “The evidence as presented… certainly supports an effect of PM_2.5 on mortality, but I do not see how it supports translation specifically of the ACS coefficients.”

Reviewer 2 said: “I would suggest one be very careful using the guesses of experts as the basis of policy decisions.” “How can one really think ammonium sulphate or ammonium nitrate will start a catastrophic chain of events leading to death?” And: “There needs to be more creative thinking as to the causal factors in particles or the whole aerosol with an emphasis on those constituents that are likely to drive reactions.” I could not find anything in the final report that specifically addressed these questions.

Reviewer 3, who was from the WHO, heaped praise on the report. And said: “The conclusions of the report are fully in line with the assessments conducted by the expert groups convened by WHO.” If the WHO was driving the process, that’s what you’d expect.

Reviewer 4, too, was very positive. He had taken part in a similar review panel in the USA, which included both Dockery and Pope, senior authors on the ACS studies. And he seemed to be urging, if anything, an even higher number. Though he did mention studies which “suggest that the more recent exposures are biologically relevant.” So, perhaps episodic exposure really is more important than long-term exposure?

Checking against UK data

The statement, which led to my final observation, raised a worry. “It would therefore be very presumptuous of us to use UK historical mortality data to make strong judgements on the plausibility or otherwise of possible coefficients for the effect of PM_2.5 on mortality, based on informal assessments with no adjustment for confounding factors.”

My immediate reaction was along the lines that the most “presumptuous” thing any scientist can possibly do is to fail to check the predictions of his hypothesis against reality. Instead of basing their calculations on UK data, what COMEAP seem to have done is pick their desired risk coefficient, then check that it is “plausible” in terms of historical UK data. This seems to me, not so much cart before horse, as base over apex.

Working Paper 9 concluded that, using the WHO value of the risk coefficient for PM_2.5, the observed past decline in PM_2.5, after adjusting for smoking, accounted for only about a quarter of the observed decline in mortality. That would suggest, to me at least, that the observed decline in mortality might well have been more due to reductions in other pollutants – such as SO₂? – than to reductions in PM_2.5.

To sum up

I first read COMEAP’s 2009 report back in 2017, without trying to judge its rightness or wrongness. On a second reading, far more critical than before, I now have extremely low confidence, verging on none at all, in the objectivity or accuracy of its results.

That the focus was on effects of pollution reductions, rather than gauging the scale of the pollution problem as a whole, worried me from the start. The expert elicitation exercise to determine confidence intervals gave me no confidence at all. That the direction of the report, and what it would study, had been set as early as the beginning of 2006, got me concerned about the integrity of the scientific process which led to its results. And that the whole exercise ended up slavishly following the WHO’s recommendations – even in the confidence intervals! – raised a red flag for me.

That the report concentrated on long-term exposure, when historical evidence suggests that the major, proven negative health effects from air pollution have come from episodic exposure, struck me as obtuse. Moreover, the probably significant role of sulphur compounds in combination with PM_2.5 in causing health damage was not properly addressed, even when brought up by two of the peer reviewers. This damaged further my confidence in the integrity of the processes. That they did not take UK data, and use that to calculate a risk coefficient for PM_2.5 adjusted for other pollutants, struck me as odd – though, perhaps, it was considered too difficult. And the presence on the committee of at least one activist on the issue did not inspire me with confidence in its impartiality.

In conclusion

All of these pieces of evidence combined to lead me to my conclusion. This report was not an honest attempt to inform policy assessments by quantifying the risks arising from PM_2.5 pollution in the UK. It was far more like an exercise in creating “evidence” to suit previously determined policies. It was simply an excuse – a 180+ page excuse – for falling into line behind the WHO’s position on the matter. It was not science, but politics.

On this evidence, I must conclude that some, at least, of those paid out of tax money, that took part in the processes that led to this report, were behaving as enemies of the people they were supposed to be serving.

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[[i]] https://wattsupwiththat.com/2018/01/11/on-science-and-nonscience/

[[ii]] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/304667/COMEAP_long_term_exposure_to_air_pollution.pdf

[[iii]]  https://wattsupwiththat.com/2017/08/11/the-social-costs-of-air-pollution-from-cars-in-the-uk/

[[iv]] https://libertarianism.uk/2022/07/31/on-the-uns-sustainable-development-goals/

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 20^th 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 1^st, 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 PM_2.5 (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 PM_2.5 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 PM_2.5 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 PM_2.5 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 (NO_x) 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 PM_2.5 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 PM_2.5 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 PM_2.5 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 PM_2.5).

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.

---

[[1]] https://aei.pitt.edu/98675/1/environ_policies...pdf

[[2]] https://researchbriefings.files.parliament.uk/documents/SN00420/SN00420.pdf

[[3]] https://www.sehn.org/sehn/wingspread-conference-on-the-precautionary-principle 

[[4]] https://libertarianism.uk/2023/04/14/climate-crisis-what-climate-crisis-part-four-the-back-story-since-1992/

[[5]] https://webarchive.nationalarchives.gov.uk/20190701152341/https://www.hse.gov.uk/aboutus/meetings/committees/ilgra/pppa.htm

[[6]] https://uk-air.defra.gov.uk/assets/documents/reports/aqeg/fullreport.pdf

The Back-story behind Anti-Car Policies in the UK, Part One: Air Pollution Episodes

In the summer of 2017, I did some calculations comparing the social cost of particulate matter (PM) and nitrogen oxide (NO_x) emissions from cars to the charges to be levied by the then forthcoming London Ultra Low Emissions Zone (ULEZ). The article is here: [[1]]. I concluded that the ULEZ charges were out of all proportion to the social costs of the pollution, which I had calculated using the UK government’s own recommended figures. In summary, ULEZ was even back then, and still is, a total rip-off.

At the time, I – naïvely, perhaps – did not consider the possibility that the UK government’s figures themselves might have been products of a process that was not entirely scientific or honest. So, I let the subject of air pollution lie for a while. I turned my attention to other aspects of the struggle between, on the one side, we human beings, and on the other, the political élites that claim they have a right to rule over us.

Background

Climate change

In the years since 2017, I have gained a clearer picture of the science, or lack of it, behind the “global warming” or “climate change” narrative. And of the political machinations which have been going on to maintain that narrative, to conceal the costs associated with it, and to prevent the truth being brought out into the open. I also found that, among the perpetrators of these machinations, the UK government has been one of the most prominent. In that, indeed, it has been second only to the United Nations, for 50+ years the main driver of the green agenda.

That work generated a set of five essays, published in the spring of 2023: [[2]], [[3]], [[4]], [[5]], [[6]]. (I give these links for reference only. My argument here is independent of them).

In the first essay, I exposed the lack of hard evidence for the idea that there is a problem with the climate. And the lack of hard evidence that any such problem, even if it did exist, would have been caused by human emissions of greenhouse gases. Or that it would be a crisis. Or that cutting carbon dioxide emissions would do any good for the climate at all.

In the remaining four essays, I uncovered the back-story behind this narrative and the policies it has spawned. These included: Dishonest and tyrannical behaviour by the UK government and their hangers-on against the people they are supposed to serve. Co-operation by our supposed representatives with the anti-human deep green agenda, that has been driven by the United Nations for more than 50 years. The inversion and perversion of the “precautionary principle” into a tool for tyranny, and the consequent sidelining of objective risk analysis. Corruption of science. Persistent moving of the goalposts, always in the direction of increasing restriction. And the shenanigans, through which our enemies have made it all but impossible to do objective cost-benefit analysis of these policies.

Anti-car policies

Meanwhile, anti-car policies have proceeded apace. In particular, the ULEZ was expanded from its original scope in central London, first in 2021 to inner London, then to the boroughs of outer London, including many places which are all but rural. The latest expansion, in August 2023, is still the subject of protests and other ructions. There are also now “default” 20mph speed limits throughout Wales. Local councils are producing “transport plans,” which will place serious obstacles in the way of drivers, both in terms of exorbitant costs and of loss of ease and convenience. These obstacles are likely to force many older or poorer drivers out of their cars, meaning that the hardest hit will lose their mobility entirely. And there is a “Vision Zero” road safety campaign in my area, that is horribly reminiscent of the “Net Zero” shenanigans of the last few years.

I realized that there could be some merit in doing for the anti-car agendas the same exercise that I had earlier done for the climate agenda. So today, I will start to document the back-story behind the anti-car policies, which have plagued the people of the UK, under governments of all parties, for 30 years and more.

I have previously published parts of this back-story, but have never before tried to assemble the whole of it in one place. My exposition will inevitably, therefore, be long. To mitigate this, I plan to split it into six essays. This, the first, will look at the facts on the issue variously dubbed “air pollution” or “clean air,” which is being used as one of the major excuses for anti-car policies. The second will cover the history behind these policies, up to 2008. The third will cover the UK government report of 2009, which tried to make a scientific justification for air pollution reduction policies. The fourth and fifth will cover the history from 2009 to the present, and schemes currently in progress, with particular reference to my local area. And the last will summarize what I found, and present my conclusions.

Smogs and Hazes

There are generally regarded as being two types of major air pollution episode, other than those caused by a specific chemical leak. These are “smogs” and “hazes.” Smogs generally occur in Western and Asian cities, in relatively cold climates. They also take place mainly in early winter. But hazes occur over larger areas, and are found almost exclusively in the warmth of south and south-east Asia.

I tried to classify the major episodes of air pollution, which have had significant, proven adverse health consequences to human beings, into one of these types. I found that most could be classified as either smog or haze. But a few may have elements of both.

I shall start with smogs, since these were historically the first to draw attention.

The Great Smog of 1952

The start point of the story is the London “Great Smog” of December 1952. During a cold, windless winter week-end, unusual amounts of air pollutants concentrated in the atmosphere in and around London. The weather conditions included a temperature inversion, in which a layer of warm air traps a much colder layer beneath it, which has the effect of holding pollutants within the cold layer close to the ground. This produced a fog, in which visibility and air quality were both very poor for several days in a row.

This was not different in kind to the “pea-souper” fogs, to which Londoners were well accustomed. But this one was unusually serious in its effects.

The 1953 report

A 1953 report by the UK government Committee on Air Pollution [[7]] addressed the pollution issues which led to the smog. Here are some of its salient points:

[Page 6]. “The problem of air pollution… is also a problem of great complexity.” “The harmful and dangerous ‘smog’ occurs only when smoke and oxides of sulphur and perhaps other deleterious substances are present in the fog in quantity.” “Both medical opinion and chemical investigation indicate that the deleterious effects of the oxides of sulphur are greatly enhanced by the presence of smoke particles…”

On page 10, the pollutants were identified as: “Solid: Particles of carbon or soot causing black smoke, and particles of coal, coke, smoke, and ash carried forward as dust and grit in the chimney gases. Liquid or semi-solid carbonaceous matter: Particles of tarry matter causing yellowish brown smoke. Unburnt and partially burnt gases: Hydrocarbons and carbon monoxide. Sulphur oxides: Sulphur dioxide gas and sulphur trioxide mist, which with water give sulphurous and sulphuric acids.” Interestingly, there was no mention of nitrogen oxides.

[Pages 15-16]. “The London ‘smog’ was accompanied by an immediate and sudden rise in both illness and mortality. The number of deaths over and above those expected in the first three weeks of December indicate that some 4,000 people died as a result of the smog.”

[Page 17]. According to hospital data, “respiratory disease was nearly quadrupled,” and “heart disease figures rose to three times the normal numbers.”

The report included two graphs. The first [Page 18] showed deaths versus levels of sulphur dioxide and smoke for the period around the Great Smog:

Figure 1

Now, I would read that graph as showing a good correlation, and perhaps suggesting a possible causation worth investigating, between sulphur dioxide (SO₂) levels and deaths a day or two later. The correlation between “smoke” (particulate matter or PM, as it is now known) and deaths is far less strong.

The second graph [Page 19] showed deaths and SO₂ levels over a period of months surrounding the smog event:

Figure 2

That graph, too, suggests a degree of correlation between SO₂ pollution and deaths in both winters. From all this, it was estimated that as many as 12,000 people may have died from, or had their lives shortened by, the effects of the Great Smog. The main culprit for the smog, so it seems, was sulphur dioxide (SO₂). Its effects were enhanced by the presence of solid carbonaceous particles. Both are produced by the burning of coal, and to a lesser extent the burning of oil.

However, pollution from SO₂ was not the only deadly issue around the time. There was a flood in Eastern England in early February 1953, and though some of the deaths from this flood took place in places like Canning Town, these were not considered part of London at the time. So, the large number of London deaths in the first half of February was, presumably, not – even in part – due to the flood.

Nor, according to the above graph, was it directly due to the level of SO₂ at the time (around weeks 32-33). Moreover, the SO₂ peak in early March does not seem to have had any significant effect on mortality. So, the report’s initial assertion, that both particulate matter and sulphur oxides must be present to produce a dangerous smog, seems justified.

Conclusions of the report

I will quote some of the main conclusions of the report. [Pages 29-30]. “Complete cure of both solid and gaseous pollution, if indeed it be ever attainable, is bound to take many years, but means of averting at least the worst evils of air pollution by smoke and grit are within practicable reach. It is simply a question of balancing the cost and inconvenience of enforcing a more scientific use of our fuels against all the advantages to be gained in health, convenience and economy from a clear atmosphere. This problem, with all that is involved in a real attack on the menace of air pollution, is one which must be faced.”

I can agree with the second sentence above, except the word “simply.” But it seems worrying to me that even back in 1953, there was already growing in government minds a grandiose idea of complete cures for environmental problems, to be reached through an attack on them.

And the final sentences [page 30] are even more concerning, ending with a plea for “general acceptance of the fact that the cure will require heavy expenditure and full co-operation of all persons and all interests.” With hindsight, this can be seen as a warning for the future, that even in 1953 the recently elected Tory government already had plans for large-scale and costly political interventions in the name of “clean air.”

Consequent political action

Back then, coal was the primary fuel both for heating and for power generation. The reason why so much sulphur dioxide was emitted from coal-burning in the UK was that the government had decided to export most of the higher-grade coal, in order to re-fill its coffers after the war. The people, and the power generators, were left with low-grade coal, with a high sulphur content. So, the Great Smog was, with hindsight, a disaster waiting to happen. A disaster whose ultimate cause, if I may be cynical, was government putting its own interests ahead of the interests of the people it was supposed to be serving.

The result was political action, and the Clean Air Act 1956, which led to a number of follow-ups. Over a decade and more, levels of air pollution, particularly sulphur dioxide, were significantly reduced. Precisely how much benefit that achieved, through lowering deaths and illnesses due to SO₂ pollution, is a question to which I have not been able to find any clear answer. Nor, indeed, could I find any estimate of how much more costly it made the lives of the people of the UK. But the effects of the original Clean Air Act and its successors, overall, are today considered by most people to have been positive.

The importance of the Great Smog is that it established for the first time, in the minds of government and its bureaucrats, if not also of many of the general public, the idea that “public health” issues due to air pollution were something in which government has a right to interfere. At the time, of course, all this had little or nothing to do with cars, which were still not ubiquitous even in London. There were only two and a half million cars in the whole UK. But in hindsight, the Clean Air Act 1956 was to be the thin end of an extremely large wedge.

London pollution levels prior to 1952

We don’t have any reports of huge negative effects from individual smog events in London prior to 1952. But we do have this data: [[8]]. Average PM levels in London peaked in the 1890s, at around 620 µg/m³ (micrograms per cubic metre). The average PM level in 1952 was 200 of these units, and in 2016 was 16. This represents a drop by a factor of 12.5 since the year of the Great Smog, and of almost 40 since the 19^th-century peak.

The same page also gives data on some of the health effects. “Air pollution deaths throughout this period rose steeply; in London, mortality from bronchitis increased from 25 deaths per 100,000 inhabitants in 1840 to 300 deaths per 100,000 in 1890. At its peak, 1-in-350 people died from bronchitis.”

Back in 1952, there was no understanding of the particle sizes in the different components of particulate matter. Today, however, since smaller particles can more easily find their way into the lungs, we distinguish between PM₁₀ (particles less than 10 microns or 10 micrometres), PM_2.5 (less than 2.5 microns) and PM₁ (less than 1 micron). PM_2.5 is considered to be the maximum size limit for particles to be easily taken into the lungs.

Other significant smogs

The Great Smog was not the first smog. But it was by far the most serious in its proven effects on the population. Here are a few other smogs, which have had bad enough health effects to acquire their own monikers.

Meuse Valley fog 1930

This was a fog in the Belgian part of the Meuse Valley, which occurred in early December 1930 and killed over 60 people. It was accompanied by a temperature inversion. It was diagnosed as probably due to emissions of gases containing fluorine, such as hydrogen fluoride, from nearby factories. Fluorine is very reactive and highly toxic: not nice stuff to be breathing. Its emissions have been controlled since the 1950s, and it is not put forward as a serious pollutant today.

St. Louis smog 1939

At the end of November 1939, St. Louis, Missouri underwent a severe smog episode. This was diagnosed as due to the burning of low-grade, bituminous coal: combined with a temperature inversion.

This suggests that the Great Smog in London, 13 years later, was very likely due to the same causes.

Donora smog 1948

This was a very local smog, confined to one mill town in Pennsylvania. But it nevertheless killed 20 people. This seems to have been caused by emissions of hydrogen fluoride and SO₂ from local factories. Combined with, you’ve guessed it, a temperature inversion.

Interestingly, the proportion of the 12,000 of London’s then 8.3 million population estimated to have been killed or otherwise harmed by the London smog is very close to the proportion of Donora’s population killed in the 1948 smog, about one in 700.

Yokkaichi asthma

Between 1960 and 1972, an industrial area in southern Japan was affected by outbreaks of serious respiratory problems. This was generally blamed on local industrial emissions of SO₂; although some researchers have suggested it may have been more due to sulphur trioxide (SO₃), which with water forms sulphuric acid.

New York City smog 1966

This occurred in late November in the New York metropolitan area, and in parts of New Jersey and Connecticut. It was blamed on emissions of smoke, SO₂ and carbon monoxide, and made worse by a large mass of stagnant air, and a temperature inversion. (Again).

This smog was responsible for kick-starting controls on air pollution in the USA, including the 1967 Air Quality Act and the 1970 Clean Air Act. The former greatly expanded the federal government’s reach in the area of pollution. And the latter led to programs and bureaucracies which have continued to this day, including the Environmental Protection Agency (EPA). It is interesting that these phrases “air quality” and “clean air” are still used today in accusing us of “sins of emission!”

Harbin smog 2013

This occurred in Harbin and surrounding areas in North-East China in late October 2013. It was said to be due to a combination of unseasonably warm temperatures and very little wind. PM levels were very high, and the pollution was blamed on farmers burning crop waste, together with the start-up of the coal-fired communist district heating system for the winter.

Eastern China smog 2013

This smog occurred further south than, and more than a month after, the Harbin smog. It was blamed on coal burning and factory emissions, both of which produce SO₂ and nitrates. There was also a lack of air flow, which kept pollution trapped low to the ground. Uniquely, this smog and its effects covered a far wider area than just one city or even one province.

Great Smog of Delhi 2016

In November 2016, there began in Delhi and surroundings a “Great Smog,” which went on for almost three months. Delhi’s air quality problems reach a large peak each year in November and December, two of the four coolest months in the year.

The main cause of this particular smog, and likely of the recurrent air quality problems, seems to be the burning of stubble by farmers in neighbouring provinces. Stubble burning produces, not only PM and SO₂, but also nitrogen oxides (NO_x). The BBC reports, here: [[9]]. Other pollution causes have been suggested, including vehicle emissions. But these do not explain the seasonality of the regular air quality issues.

A local example

I myself can attest that the burning of stubble can produce high levels of pollution. This was a common practice among UK farmers in my youth. Most kinds of stubble burning were banned in the UK in 1993, but I do recall a particular incident in – if I remember right – about 2000. Some local crop fields had been purchased, to be turned into a garden centre. Presumably, the area burned was too small to fall foul of the regulations at that time. But I remember that the air was extremely unpleasant to breathe, and the stink lasted five days.

Hazes

Hazes, in contrast to smogs, tend to occur in some of the warmest parts of the world. Hazes have been recorded in south-east Asia since about 1972. In recent decades, these have become an almost yearly event, with the worst conditions being reported in 1997 and 2015.

The 1997 haze was diagnosed as caused by “slash-and-burn” agricultural fires in Indonesia. This is a traditional agricultural practice in the region. On top of this, considerable areas of land in Indonesia consist of dried-out peat forests, which when burned produce pollution with a high sulphur content. It seems that this practice was responsible in large part for the later hazes, too.

The fires were unusually widespread in 1997, due to El Niño causing the dry season (which lasts usually from April to September or October) to be exceptionally dry. The fires produced particulate matter, which spread over a large swathe of south and south-east Asia, going as far afield as Thailand, Singapore, the Philippines and Sri Lanka. The negative health effects of this mixture were significant.

Causes of smogs and hazes

The above suggests that there are two sets of causes, which have been shown to produce air pollution leading to proven, measurable, significantly negative health effects.

PM and SO₂

The first of these causes is industrial pollution that includes both particulate matter and sulphur oxides. Sometimes, it may also include nitrogen oxides; but it is not clear that these are necessary to produce serious health effects. PM and SO₂ together have been the main culprits in the cold weather smogs. And these serious smogs have always taken place in conditions of stagnant air and low wind, and generally in the presence of a temperature inversion, too.

Burning of coal containing sulphur compounds is the major activity that has produced this pollution mix, both in Western countries and in China. The bad health effects are worst when there is lack of wind, or a temperature inversion. With the exception of the East China smog of 2013, the worst of the effects of these smogs seem to be limited to a relatively small area, such as a single city, at any one time.

Burning of vegetation

The second cause is burning of vegetation on the large scale, as part of agricultural practices. This is the major cause of the south-east Asian hazes. It also, in my view, was probably the main cause of the Harbin smog of 2013. For if the communal heating system had been the culprit, we would have expected to see such smogs happening in most years, not just this one.

Whether burning off old stubble, or slash-and-burn for new crops, the burning of vegetation produces pollution containing particulate matter and sulphur compounds. In the case of stubble burning, significant amounts of nitrogen oxides may be given off, too.

The 2016 Great Smog of Delhi covered a wide area, and the weather while cold for the location was not cold in temperate-zone terms. It could well be that this particular incident was down to a combination of the two causes.

Which pollutants are the toxic ones?

I will repeat parts of two key sentences from the 1953 report on the Great Smog in London. “The harmful and dangerous ‘smog’ occurs only when smoke and oxides of sulphur and perhaps other deleterious substances are present in the fog in quantity.” And: “Both medical opinion and chemical investigation indicate that the deleterious effects of the oxides of sulphur are greatly enhanced by the presence of smoke particles…”

The first sentence is clear. You need both PM and sulphur oxides to produce a dangerous smog. So, PM alone is not necessarily a problem. And the second tells us that sulphur oxides alone constitute a far lesser problem than sulphur oxides plus PM. (Perhaps this may account for the SO₂ peak in early March 1953 failing to produce a corresponding increase in deaths.) So, neither one nor the other produces a serious smog, but a combination of both. This conclusion is borne out by my analysis above of individual smogs and hazes. So far, so good.

But what did the report mean by “perhaps other deleterious substances?” This might, for example, refer to highly toxic divalent metals such as lead, cadmium or perhaps mercury, which can easily react with sulphate ions even in small concentrations. Lead is often present in PM, and could react with sulphuric acid to produce particles of lead sulphate small enough to find their way into the lungs. Such a mechanism might perhaps explain why PM_2.5 and sulphates together are more toxic than either alone. Cadmium also is present in PM, particularly in wood smoke.

Alternatively, the report might refer to oxidants produced by a reaction involving sulphates or perhaps nitrates. These are some of the matters, which would later be looked into by COMEAP (Committee on the Medical Effects of Air Pollution).

To sum up

I have looked at the evidence around those air pollution episodes, both smogs and hazes, which have demonstrably caused significant adverse health effects. The main diagnosis in the government’s report on the London Smog of 1952, that both particulate matter and sulphates are necessary in quantity in order to produce bad health effects, seems to have been borne out by the evidence.

Smogs and hazes seem generally to be caused by a combination of particulate matter and sulphur oxides. The latter may come either from industrial emissions, or from the burning of stubble or other vegetation with a high sulphur content. Indeed, all the serious smogs and hazes I looked at had both these pollutants present in large quantities. Many had unusual meteorological conditions, too: stagnant air, low wind, or even a temperature inversion.

But I get a feeling that the whole story may prove to be a bit more complicated than that.

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[[1]] https://wattsupwiththat.com/2017/08/11/the-social-costs-of-air-pollution-from-cars-in-the-uk/

[[2]]  https://wattsupwiththat.com/2023/03/15/climate-crisis-what-climate-crisis-part-one-the-evidence/

[[3]] https://libertarianism.uk/2023/04/12/climate-crisis-what-climate-crisis-part-two-where-we-are-in-the-uk-today/

[[4]] https://libertarianism.uk/2023/04/13/climate-crisis-what-climate-crisis-part-three-the-back-story-up-to-1992/

[[5]] https://libertarianism.uk/2023/04/14/climate-crisis-what-climate-crisis-part-four-the-back-story-since-1992/

[[6]] https://libertarianism.uk/2023/04/15/climate-crisis-what-climate-crisis-part-five-the-case-of-the-missing-cost-benefit-analysis/

[[7]] https://archive.org/details/b32170129/

[[8]] https://ourworldindata.org/london-air-pollution

[[9]] https://www.bbc.co.uk/news/world-asia-india-45890916