Cynulliad Cenedlaethol Cymru

National Assembly for Wales

Y Pwyllgor Newid Hinsawdd, Amgylchedd a Materion Gwledig

Climate Change, Environment and Rural Affairs Committee

Ansawdd Aer

Air Quality

NHAMG (5) AA09


Ymateb gan Plantlife Cymru

Evidence from Plantlife Cymru


Introduction to Plantlife 

Plantlife isthe British conservation charity thatworks nationally and internationallyto save threatened wild flowers,plants and fungi, thanksto our 11,000 membersand supporters. We ownnearly 4,500 acres ofnature reserve across England,Scotland and Wales whereyou can find over80% of the UK’swild flowers. 

Plantlife Cymru,as the operating arm ofPlantlife in Wales, hasbeen active in takingaction and speaking out forwild plants, fungi, lichensand bryophytes for over20 years. We havebeen instrumental in therecovery of Fen Orchidsat Kenfig to theimproved populations on TreeLungwort in our AtlanticWoodlands. Increasingly our workinvolves people in creatinga greater understanding of howplant life underpins all biodiversityin Wales.

Oneof Plantlife’s main objectivesis to reduce theimpact of air pollutionon wild plants andfungi through atmospheric nitrogen deposition. Air pollutionis now one ofthe primary causes ofwildlife loss and environmentaldegradation in Wales. Unprecedentedconcentrations of nitrogen have builtup in the atmosphere,due to ammonia (NH3)and nitrogen oxide (NOx)emissions from intensive farming practicesand fossil fuels. 

Excess nitrogenin the atmosphere is depositedinto nature, disrupting ecosystems and makingit impossible for manyspecies to survive; more thantwothirds of wildflowers, as well asmany lichens and otherfungi, cannot tolerate high nitrogenlevels.

In Wales, 89% of sensitive wildlife habitat is suffering from excessive nitrogen levels, from Powys and Pembrokeshire to the peaks of Snowdonia. While NOx emissions have been cut significantly and are a continued focus of air quality strategies, ammonia has flown under the radar for too long. Despite its impacts on public health and wildlife, up to 95% of ammonia emissions – from farm animals and fertilisers – are unregulated in Wales. 

Our2018 report calling forurgent action on ammoniaemissions and wildlife in Wales,along with further informationabout our work inthis area, is availablehere: 

Wewelcome the opportunity to submitcomments to CCERA’s Inquiryinto Air Quality andwe would be pleasedto discuss the issuesraised with the Committeein more detail asappropriate.

What regulatory gaps or issues will need to be addressed after the UK leaves the EU? How should these be addressed and what will be the main challenges?


1.1.            EU Directives and otherEuropean policy and legislationhave provided the driversfor monitoring, reporting and enforcementaction on air pollutionand its impacts onsensitive wildlife sites. Forexample, the EU HabitatsDirective requires Member Statesto assess and reporton the condition of SpecialAreas of Conservation (SACs), includinglevels of atmospheric nitrogen deposition. The protectionafforded to SACs bythe Habitats Directive has helpedprotect many of Wales’smost important wildlife sites andhas provided a frameworkfor the Welsh Government,its agencies and localplanning authorities to rejectproposals for damaging development or totake enforcement action wherenecessary.


1.2.            The Welsh Government must takethe opportunity of itsClean Air Plan anda Clean Air Actto maintain and strengthen domestic legal requirementsto reduce air pollutionand to protect sensitivewildlife habitats from furtherdamage. This should includemechanisms for monitoring, reporting, spatial planningand enforcement, along witha requirement to provideadequate funding for theseto be delivered by nationaland local government. 


1.3.            Targets agreed under theEU National Emissions Ceiling Directivefor reductions by 2030go above and beyondthe 2020 targets requiredby the UK’s internationalcommitments outside the EU.Ambitious statutory targets for2030 and beyond mustbe set by theWelsh Government in theClean Air Act, includingfor ammonia emissions. 


Are the Welsh Government’s proposals for a Clean Air Act appropriate? How could they be improved? What can be learned from legislative approaches elsewhere?


1.4.            Plantlife supports many ofthe proposals for a Clean Air Act.However, the Act shouldalso tackle the problemof ammonia emissions from agriculture,which are damaging to publichealth and the naturalenvironment. 


1.5.            Of the trends inair pollutant emissions in thefigure on page 12of the consultation, ammonia standsout as the exception.Almost no progress has beenmade in reducing emissions since 1990and recent years showa steady increase in emissions.The NECD target for2020 will be missedacross the UK andthe 2030 target willalso be missed withoutregulatory action. 


1.6.            In order to reduceammonia emissions effectively, the CleanAir Act for Walesshould introduce new targetsand powers to requireaction by the agriculturalsector and other sources.Voluntary measures by thefarming industry have beenineffective and an integratedregulatory approach is required.Only the most intensivepig and poultry farmsrequire an environmental permit, accountingfor an estimated 5% ofWelsh ammonia emissions. The remaining95% of ammonia emissionsare currently unregulated. 


1.7.            Medium and long termtargets should be setfor all major airpollutants, including ammonia. The WHOGuidelines standards for airquality do not includeammonia as it isnot appropriate to measureambient levels of thispollutant. However, targets shouldbe set for annualemissions and for reductionof the damaging impacts ofconcentrated emissions on sensitivespecies and habitats.  


1.8.            New regulation to requireaction to reduce ammoniaemissions should include: 

-       a reduction in thethreshold for EIA andenvironmental permits for intensivepig and poultry units; 

-       a requirement for environmentalpermitting of beef anddairy herds; 

-       requirements for moreefficient management, storage andapplication of manure, slurryand other fertilisers; 

-       a responsibility for planningauthorities to look atthe cumulative effects ofnew applications on localair quality.

1.9.            Legislation and regulation of agriculturalactivities should be closelyintegrated with regulatory measures to cutwater pollution and greenhousegas emissions. All agriculturalregulation should form partof a package ofadvice, support and incentivesfor farm businesses in thenew land management scheme toensure a swift transitionto sustainable farming acrossWales. 


1.10.        Legislative approaches to ammoniaemissions reduction have beenimplemented in several countries,including Denmark and theNetherlands. Plantlife supports the commitmentsin Defra’s Clean AirStrategy 2019 relating to ammoniaemissions from agriculture and othersources. 


What are your views on the regulatory proposals in relation to the Local Air Quality Management regime? What are the main challenges in relation the proposed approach?


1.11.        As part of LAQMmonitoring and assessment, it isimportant to measure alldamaging pollutants and allimpacts. The LAQM shouldnot only focus onthe public health risksfrom air pollution but alsothe risks to wildspecies, natural ecosystems and habitatswhich are vulnerable to damagingatmospheric nitrogen deposition, often frompoint sources of NOxand ammonia emissions. 


1.12.        Air quality is a rural and urbanissue, affecting people andwildlife, and the proposedintegrated approach to localair quality management must reflectthat. There are significantrural ‘hotspots’ across Waleswhere, for example, a clusterof intensive livestock units isdeveloped close to areasof sensitive wildlife habitat. The integratedapproach must include a suite of actionsto reduce agricultural ammonia emissionsand the impact ofnitrogen deposition (from ammoniaand NOx) on thenatural environment. For example,this will enable localplanning authorities to planstrategically for better airquality and to assesslocal development plans andindividual planning applications within anintegrated and comprehensive framework. 



What are your views on the regulatory proposals relating to domestic combustion

(including fireworks/bonfires), road vehicle idling and Clean Air Zones/Low Emission Zones?


1.13.        No comments 


What are the main challenges in introducing a legislative framework for air quality as set out in the consultation document?


1.14.        No comments