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ClientEarth Communications

30th November 2020

Air pollution

Greater Manchester: tell your councils it’s high time they take air pollution seriously

Illegal and harmful levels of air pollution are damaging people’s health, reducing their quality of life and cutting lives short across the UK.

The most recent data shows that there are illegal levels of nitrogen dioxide pollution in each of the Greater Manchester local authority areas – Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside, Trafford, and Wigan.

Road transport is the main source of illegal levels of air pollution in Greater Manchester and private cars are the largest single contributor, followed by vans.

Illegal levels of this toxic pollutant will persist in the region until 2027 unless urgent action is taken, according to analysis by the local authorities.

Yet despite these alarming findings, the Greater Manchester authorities have missed multiple government-imposed deadlines to propose a plan to tackle air pollution in the region. They should have put forward a final plan by the end of 2018.

Almost two years later, the councils of Greater Manchester have finally come up with proposals, which are the subject of a public consultation closing on Thursday 3 December. But these proposals fall a long way short of what is needed to protect your health, so it’s important you have a say.

Why do Greater Manchester’s proposals not go far enough?

Analysis from the UK government and local authorities across the country shows that Clean Air Zones (CAZs) are one of the most effective ways to quickly reduce illegal air pollution.

In its plans, Greater Manchester has chosen what is called a “class C” Clean Air Zone. This type of CAZ aims to discourage the use of the most polluting vans, HGVs, buses, coaches and taxis, by applying a charge to vehicles that do not meet the minimum emissions standards if they enter or drive within the area. The authorities are also proposing a number of financial support packages to help people and businesses make the shift away from using the most polluting vans, taxis, HGVs, buses and coaches.

We are worried because the councils’ proposed CAZ remains blind to the biggest source of air pollution: private cars. By excluding cars from their CAZ plans, it is clear that the councils haven’t grasped the full extent of the air pollution crisis.

The CAZ plans also exempt the most polluting vans until 2023. Vans are the second largest contributor to illegal levels of air pollution in the region, so this exemption would further delay much needed progress to clean up the air across the region and protect people’s health.

Finally, the councils are suggesting that the CAZ would only be up and running from Spring 2022. Action has already been too slow. People have been left waiting and paying the price with their health. Further delay is simply not acceptable, particularly when other local authorities, such as Birmingham and Bath, are set to introduce CAZ schemes in 2021.

How can you have a say?

You can have your say and tell the councils that their plan is simply not good enough. Go to the consultation page and fill out the online questionnaire. You can also email your responses directly to

To make things easier for you, we have prepared some suggested answers to the most important questions. You are welcome to use these in your responses and adapt as necessary.

Question 1: The proposed Clean Air Zone Boundary would follow the existing administrative boundary of Greater Manchester as closely as possible. Do you have any comments on the proposed boundary?

Suggested answer:

  • Each of Greater Manchester’s local authority areas have illegal and harmful levels of air pollution.
  • The Clean Air Zone needs to cover the whole region in order to protect people’s health and rid the area of illegally dirty air in the shortest possible time.

Question 2: The Clean Air Zone would operate 24 hours a day, seven days a week, signage would be used to clearly identify the Clean Air Zone, and the daily charges would apply from midnight to midnight. Do you have any comments on these proposals?

Suggested answer:

  • Given the health impacts of air pollution, even at levels below existing legal limits, I support the proposal for the Clean Air Zone to operate 24 hours a day and seven days a week. This will help ensure that people’s health is protected around the clock.

Question 3a: Please tell us what you think of the proposed daily charges for each of the vehicles? Do you have a comment on the proposed charges?

Suggested answer:

  • It’s important that the charges are set at the right level to deter the use of vehicles that do not meet the emissions standards in order for the Clean Air Zone to be effective at reducing pollution quickly and protecting people’s health.
  • The Greater Manchester authorities should keep this under review and make any changes needed to ensure that the Clean Air Zone delivers the necessary reductions in air pollution.

Question 5: Greater Manchester are proposing temporary local exemptions from Clean Air Zone charges until 31 December 2022 to give certain vehicles more time to upgrade. These include wheelchair accessible hackney carriage / private hire vehicles, and vans. To what extent do you agree or disagree with the permanent local exemptions proposed by Greater Manchester?

Suggested response: Strongly disagree

Question 5a: Why do you say this?

Suggested response:

  • Vans are the second biggest source of illegal levels of air pollution in the region. I do not support these exemptions, as they would mean slower reductions in harmful and illegal air pollution. Rather than delaying improvements, the authorities should instead be focusing on working with government to provide help and support for drivers and fleet managers to clean up or upgrade their vehicles.

Question 12: To what extent do you agree or disagree that air quality needs to be improved in Greater Manchester?

Suggested response: Strongly agree

Question 13: Having read through the proposals, how confident are you that the Greater Manchester Clean Air Plan would bring roadside nitrogen dioxide (NO2) levels within legal limits in the shortest possible time?

Suggested answer: Very unconfident

Question 13a: Do you have any other comments on the proposals for the Clean Air Plan as set out in the consultation document?

Suggested points to raise:

  • I think that Greater Manchester urgently needs a Clean Air Zone in order to protect people from harmful and illegal levels of air pollution, but I don’t believe the consultation proposals go far enough.
  • Cars are the biggest contributor to illegal pollution across Greater Manchester. However, the Clean Air Zone option being consulted on would do nothing to tackle pollution from the dirtiest of those vehicles.
  • A class D Clean Air Zone, which includes private cars, would lead to quicker reductions in toxic pollution. To put the people’s health first and live up to their legal duties to reduce illegal pollution as quickly as possible, leaders need to commit to putting a class D Clean Air Zone in place as soon as possible.
  • This should be alongside increased help and support for people and businesses to move to cleaner forms of transport now.
  • It cannot be right for the Clean Air Zone to be delayed until Spring 2022, or for the most polluting vans and other vehicles to be exempt until 2023. The Councils should be acting as quickly as they can to rid the region of illegal and harmful pollution.
  • It is already ten years after legal limits should have been met and people should not have to continue to pay the price of any further delays with their health. Rather than get left behind, Greater Manchester needs follow the lead of authorities in Birmingham and Bath and introduce a Clean Air Zone as soon as possible in 2021.
  • The Covid-19 pandemic has highlighted the importance of protecting people’s health. Initial studies are suggesting that air pollution could increase vulnerability to the most severe impacts of Covid-19. People recovering from the disease may join those in our society who were already more vulnerable to the impacts of air pollution – highlighting that clean air is crucial for living well now, and in the future.

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