Press release: 25 November 2021

New data shows Greater Manchester logged illegal pollution despite lockdowns

New figures released by the UK Government and analysed by environmental law charity ClientEarth reveal that Greater Manchester was one in a handful of regions in the UK that still charted air pollution levels above legal limits through 2020, despite several nationwide lockdowns.

The news comes as ClientEarth and law firm Hausfeld are asking people whose health has been harmed by illegal pollution to come forward to join a new legal action.

The figures show that in 2020, toxic nitrogen dioxide (NO2) pollution in Greater Manchester was above the legal limit – a limit that should have been met in 2010. Out of 43 air pollution reporting zones in the UK, Greater Manchester is one of five – alongside the West Midlands (which includes Birmingham), Greater London, South Wales and Bristol – that exceeded it.

According to Transport for Greater Manchester, 1,200 premature deaths are linked to air pollution in the region annually. Dirty air is associated with a huge range of health issues including asthma, heart attacks, strokes and low infant birthweight.

Katie Nield, clean air lawyer at ClientEarth, said: “Last year, most of the UK recorded levels below the air pollution legal limits largely due to the restrictions caused by the Covid-19 pandemic, but Greater Manchester was one of the few exceptions. The region has a serious air pollution problem and its leaders cannot delay the implementation of the Clean Air Zone any longer.”

Road transport is the biggest source of NO2 in towns and cities across the UK, contributing to up to 80% of illegal air pollution. The UK Government’s annual report on air quality largely attributes the low number of zones exceeding the legal limit in 2020 to the Covid-19 restrictions, which substantially reduced traffic activity on many roads – particularly during the first lockdown. However, by October 2020, traffic in major cities across England had returned to close to pre-pandemic levels.

Meanwhile the Greater Manchester authorities had pushed back plans for a Clean Air Zone (CAZ) to tackle air pollution to May 2022, almost three years after originally being directed by ministers to implement the scheme. Analysis by the Greater Manchester Combined Authority has shown a CAZ to be the most effective way to quickly reduce illegal and harmful levels of air pollution in the city. But the region’s upcoming CAZ will not include private cars – the biggest source of air pollution in the region.

Other English cities like Birmingham and Bath have already followed through with their plans and introduced a CAZ earlier this year. Last month, London expanded its Ultra Low Emission Zone (ULEZ). The original ULEZ was shown to have brought pollution levels down by 37% in its first year of operation.

ClientEarth says it is vital that people are supported during the transition.

Nield said: “Our national government needs to pull its weight and assist Greater Manchester in quickly providing the help and support that people and businesses desperately need to move to cleaner forms of transport.”

People in towns and cities across the country – including in Greater Manchester – have little choice but to breathe illegally polluted air. Many people’s health will have already suffered as a result of government failures to tackle the problem. ClientEarth and law firm Hausfeld are exploring a possible new kind of legal action against the UK Government to help people get the chance to push for change. People who think their health has been harmed by illegal pollution can express their interest online. Those wishing to learn more about the upcoming air pollution legal action can join a webinar hosted by ClientEarth and Hausfeld on 29 November.

Nield said: “This is a powerful new legal avenue to give people in places like Greater Manchester the chance to push for change and get compensated for the harm they have suffered.”


Notes to editors:

For the purposes of air quality reporting, the UK is split up into ‘zones’. In order to meet legal levels, a zone must have an annual average nitrogen dioxide (NO2) level of 40µg/m3 or below. In 2020, the zones that were reported as over this legal limit were:

  • Greater London
  • West Midlands Urban Area (includes Birmingham)
  • Greater Manchester Urban Area
  • Bristol Urban Area
  • South Wales

Top 10 zones ranked by their reported annual mean NO2 concentration for 2020

Zone name

Exceedance of NO2 legal limit in 2020?

Annual mean NO2 concentration in 2020 (µg/m3)

West Midlands Urban Area



Greater London Urban Area



South Wales



Greater Manchester Urban Area



Bristol Urban Area



Nottingham Urban Area



Southampton Urban Area



South East



West Yorkshire Urban Area



Air pollution tops the list of environment health hazards in the UK and is estimated to cause the equivalent of up to 40,000 early deaths a year nationally.

There is a growing body of evidence suggesting that there may be no safe level for NO2 (this is already accepted for fine particulate matter), with a recent study showing health impacts at levels below existing legal limits for NO2.

In September, the World Health Organization published its new guidelines on air pollution, reflecting the best available science on the health threats posed by toxic air. The organisation recommends that the concentrations of NO2 not exceed an annual mean concentration of 10 µg/m3 – the UK’s legal limit is four times higher.

ClientEarth has previously brought and won three cases in front of the courts in the UK – on these three occasions, the courts have found the UK Government to be breaching the law on NO2 pollution and have ordered ministers to produce new, compliant air quality plans to tackle the problem.

About ClientEarth

ClientEarth is a non-profit organisation that uses the law to create systemic change that protects the Earth for – and with – its inhabitants. We are tackling climate change, protecting nature and stopping pollution, with partners and citizens around the globe. We hold industry and governments to account, and defend everyone’s right to a healthy world. From our offices in Europe, Asia and the USA we shape, implement and enforce the law, to build a future for our planet in which people and nature can thrive together.