There are some established policy measures and sources of guidance52-54 on how to intervene in pollution problems and their impact on health. Different measures and approaches are more or less appropriate to the particular pollutants and sources involved, with significant differences, for example, between point pollution sources, and those that are more diffuse. For air quality specifically, the National Institute for Health and Care Excellence have recently published guidance on ‘what works’ in air quality management, particularly in terms of reducing health impacts.54
Guidance on addressing pollution inequalities and their relationship with health inequalities is though less well developed. It cannot necessarily be presumed that generic actions to address pollution problems will automatically reduce inequalities and improve the situation most substantially for those most exposed.55 Whilst this logic may well hold in some circumstances56, there is also evidence (as reviewed above) that air quality management strategies in the UK have not been as pro-equity as might be expected and that in relative terms deprived communities have
benefitted less from improvements in air quality than others.25 If then it is accepted that pollution inequalities should be specifically targeted and reduced, it follows that there is a need to have policies and measures to identify and act on these
inequalities. Key examples of such measures include:
Appraisal of the impacts of planning decisions, government policies and
strategies to explicitly include implications for environmental inequalities. This is to ensure that decisions are taken with full awareness of their potentially unequal consequences.24 Established assessment methodologies applied in England often either require or provide scope for assessing ‘distributional effects’, but are typically poor at specifically identifying environmental inequalities57, and beyond a few examples58,59 (see Box 2) are not generally carried out very thoroughly. Given the nature of the current evidence base, such appraisal needs to extend beyond the protected social characteristics identified in the 2010 Equality Act, to include socio- economic status.
Application of impact assessment methods in land use and other decision processes to explicitly address the cumulative effects of multiple decision processes, such as the cumulative effects on a community of a series of transport infrastructure and industrial developments. This is important given that, as noted above, pollution sources often accumulate in deprived areas where people’s health tends to be significantly worse. It is unfair to add further burdens on those already taking more than their ‘fair share’ and suffering additional health consequences, and impact assessments should clearly identify where this is taking place.
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Targeting of investment in local pollution management measures specifically on more deprived communities where health indicators are most
problematic.52 The identification of ‘pollution-poverty’ hotspots has been suggested as one way of implementing targeting19, and in particular where environmental quality standards are breached, offer the strongest support for claims of
environmental injustice.25
Actively supporting innovative community based approaches to identifying and addressing local pollution problems (see Box 3) recognising that deprived communities will typically have fewer resources and less capacity to participate and have influence on decision-making than others. The Environment Agency has some experience of advocating for and experimenting with participatory approaches to working with deprived communities.16 ‘Good neighbour agreements’ have also provided the basis for negotiating performance standards between industries and communities in some localities, although with varied outcomes.60,61
Ensuring that socially disadvantaged groups are properly included in bio- medical studies. Whilst the weight of evidence from environmental justice research shows socially disadvantaged groups are often more exposed to environmental pollution, some of these groups (for example ethnic minorities, homeless) have been found to be under-represented in biomedical studies thus potentially biasing
understandings of health outcomes.62
In following and selecting from such approaches, two further considerations are important. First, it makes much sense to seek synergies with wider policies focused on addressing health inequalities.2,52,63,64 The greening of deprived areas is a good example, given that green spaces can be of direct and indirect benefit to physical and mental health65 and tree and vegetation planting can play a role both in
improving general environmental quality and in scavenging air pollutants before they reach sensitive lungs. Investment in sustainable transport modes is another good example of where there can be strong policy synergies.
Second, it is a generally accepted principle that those who are suffering from
pollution inequalities should not be made responsible for addressing them - making the polluted rather than the polluters pay - and are not unfairly penalised by the implementation of pollution reduction policies. Policy responses focused principally on personal protective measures are problematic in these terms66, as can be policies focused on economic penalties and/or with cost implications that have
disproportionate impact on those with low incomes.67 Progressive approaches can ameliorate such effects, including, for example, focusing car scrappage schemes more substantially on low-income households.68
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Box 2 Heathrow expansion and Equality Impact Assessment
In 2008 campaigners protesting against proposals to further expand Heathrow airport argued that a proper assessment and consultation on the ‘equality’ implications of the development had not been carried out, and lodged legal proceedings against the Department of Transport. Their case rested on the
obligation on all public authorities, under the Race Relations (amendment) Act 2000, to ensure that their policies do not have disproportionate impacts on ethnic minority groups. The response was an initial ‘Equality Impact Assessment’ screening which concluded that a full assessment should be undertaken because of the high
proportion of black and Asian minority ethnic (BAME) groups near to the airport. The full assessment, undertaken for various potential airport expansion options,
concluded that:
“Each development option could result in both positive and negative noise, air quality and economic impacts on equality priority groups. BAME groups, children, young people, older people, women / carers, disabled people and those with low incomes are likely to be differentially affected by the
development proposals. Additionally, BAME groups, children, older people and those on low incomes could also be affected due to their disproportional representation in particular areas around the airport.”