Prof Peckham & Dr Mills call latest Tesco air quality report as “Dangerous & Misleading”

Ricardo, a firm commissioned by Redbridge Council earlier this month, have attacked Prof Peckham & Dr Mills report for Reclaim Redbridge at the link below.

Ricardo

Ricardo claim “It is misleading to say that the development would “introduce a fresh cohort of children to

damaging levels of air pollution.”

Today Prof Peckham & Dr Mills go into detail to support this claim: “However, Ricardo fails in one respect which is impossible to ignore: they conflate objective legal limits with health limits. This is a dangerous and misleading approach to public health
that requires specific comment, and which will be the subject of this report.” The full report is at  Goodmayes Ricardo Response

I have cut and pasted the report below, but the full report above is best due to some tables being left out when transferring the paper. 

1. Introduction

 Ricardo Ltd was commissioned by Redbridge Borough Council to produce a report [1] to independently review a previous air quality review produced by CHSS [2]. Before Ricardo published this document, CHSS had published another report [3] to address amendments to the original planning application. For this reason we will not provide a point-by-point rebuttal of Ricardo’s work, since their comments are not addressed to the most recent evidence submitted by us. However, Ricardo fails in one respect which is impossible to ignore: they conflate objective legal limits with health limits.

 This is a dangerous and misleading approach to public health that requires specific comment, and which will be the subject of this report.

 2. Ricardo does not understand the difference between air quality objectives and the harm caused by air pollution

 First of all it is worth noting that in the quote below, Ricardo is referring to the developer’s V5 AQA [4] and not the developer’s latest V6 AQA [5] For the sake of our argument here, this is immaterial since we are passing comment on Ricardo’s interpretation of the data. It does beg the question however, why is Ricardo not commenting on both the latest documents submitted by the developer [5], and the latest rebuttal submitted by us [2]?

 Notwithstanding this, on page 2 of Ricardo’s review [1], Ricardo states the following: “It is misleading to say that the development would “introduce a fresh cohort of children to damaging levels of air pollution.” The new school was specifically included in the assessment (Sensitive Receptor H), and it was shown that levels of air pollutants at the school would comply with the air quality objectives at this location in the opening year of the scheme (2026). The proposed development would therefore not introduce children attending the school to damaging levels of air pollution.” 

In Table 5 of Aether’s original report [4] predictions for 2026 (with development) were given for Sensitive Receptor H. The value given was 34.1 μg/m3 (upper ground floor). From the same table we can see that many of Aether’s original predictions for 2026 were within 10% of the objective and that “Nearby residential receptor” R1 has a prediction of 40.5 μg/m3 . We give these values so that the reader understands the overall pollution context within which Ricardo is making its claims. Ricardo makes the inference that because “it was shown that levels of air pollutants at the school would comply with the air quality objectives” that it follows that “The proposed 2 development would therefore not introduce children attending the school to damaging levels of air pollution”. The clear implication here is that Ricardo believes that air containing poisons in concentrations below air quality objectives cannot be damaging to children. This is a ridiculous position that demonstrates a bewildering ignorance of publicly available facts and cannot go unchecked. There are many studies looking at associations between mortality and mean annual NO2 exposure. Examining a recent meta-analysis looking at associations between NO2 and mortality [6], the majority of the 41 studies showed positive associations, relative risk increases were quantifiable per 10ug/m3 , and pollutant ranges contained inputs below annual objectives.

 In a 2018 Public Health England review [7] of the long-term health effects of NO2 they state that long-term mortality associations have been found in: “cohorts in which the range of outdoor levels reaches as low as 5 µg/m3 annual average NO2 concentration.” It seems clear that there is a dose-response for negative outcomes for NO2 at the annual measurement level, and that this dose-response occurs below objective limits for NO2 . Daily variation also matters: a meta analysis of 204 time-series studies [8] found associations between 24h NO2 and daily mortality and hospital admissions for a variety of morbidity and age groups. A study looking at 18 french cities [9] found that relative risk increases for NO2 at lags of 0-1 days and greater risks associated with cumulative exposures over 0-5 days. 

At even shorter timescales one study that looked at children walking to school [10] estimated that children obtained 20% of their black carbon daily dose (according to U.S EPA regulations) over a time period that accounted for only 6% of the day. To summarise this material: daily changes in NO2 can impact health and roadside exposure can contribute disproportionately to an individual's cumulative daily exposure. 

We will now examine a specific example, which happened in a neighboring borough of Redbridge that highlights the real world consequences of maintaining a view of air pollution focused on objective limits at specific locations rather than human exposure. 

3. The tragic death of Ella Kissi-Debrah

 Ella Kissi-Debrah was a 9 year old girl who died after acute respiratory failure on 15/02/2013, with “Air pollution exposure” listed as a medical cause of death [11]. Ella had severe asthma and lived within 25m of London’s South Circular (A205, Brownhill Rd). Ella went to Holbeach Primary School and the inquest heard that Ella regularly walked along Brownhill Rd to arrive there. The road has a high degree of traffic generated air pollution. 3 Ella was taken to hospital 27 times between 2010 and her death in 2013. Taking 2011 as a representative year for her exposure to air pollution, Figure 1 shows the Lewisham diffusion tube data for 2011 [12] as well as data from the automatic monitoring station [13] at catford (named Automatic 1 below). Ella’s school has a diffusion tube assigned to it called SCH015 seen in the figure and in 2011 had a value of 27.7 μg/m3 . The automatic monitor at Catford had an annual average of 51 μg/m3 in 2011 and had no exceedances of the 200 μg/m3 objective in 2011. Although no measurement was made, it seems unlikely that the objective for NO2 of 40 μg/m3 was exceeded in 2011 directly outside of Ella’s home. Therefore her exposure mainly came from being outside her house in the local area, not all of which exceeds national objectives for annual NO2 . 

For example, the school receptor had an annual mean of 27.7 μg/m3 . It has been established as a medical cause of death, that Ella’s exposure to air pollution was a direct material influence.

 4. A dangerous place for a new primary school 

Now compare the map shown in the last section, with that of the predictions of NO2 for the proposed development in Goodmayes in 2026 (as set out in Aether’s V5 AQA [4] which is the document that Ricardo’s comments pertain). These are plotted in Figure 2. 4 Figure 1 - Diffusion tube NO2 measurements and Catford automatic station NO2 measurement for 2011. Ella’s school is SCH015, and the road she walked along is the A205. 5 Figure 2 - Developer NO2 predictions for 2026 (With Development) scenario. Values shown are in µg/m3 . We can see that air pollution at the school was predicted in Aether’s AQA V5 [4] to be higher than that around Ella’s school shown in the last section. Bearing in mind that the SCHOOL receptor above is on the upper ground floor. We can see many points with high values close to the objective limit, and location R1 above the objective limit. The overall picture is one of a school surrounded by areas where NO2 pollution is high. Any child walking to this school from the surrounding residential area is for certain going to be exposed to damaging levels of air pollution. 

Thus, it is not “misleading to say that the development would “introduce a fresh cohort of children to damaging levels of air pollution.” as Ricardo claims. Rather, it is absolutely reasonable to claim, on the evidence of Aether’s AQA V5 [4] and contemporary medical evidence on the harms of air pollution that the school will introduce a fresh cohort of children to damaging levels of air pollution. Note that we are not using Ella’s death as the main argument for this. Her tragedy serves to illustrate that air pollution is not just damaging to children, but can be fatally so. It also serves to illustrate that exposure outside the home is a major contributing factor. As we have already discussed there is plenty of medical evidence showing the harms of NO2 below objective limits. It would require an extraordinary level of ignorance of the scientific body to make an argument to the contrary. 

5. References [1] Ricardo Ltd, ‘Review of University of Kent report “Air Quality Review for 4309/19 - Development Site At Tesco Extra 822 High Road, High Road, Chadwell Heath, Romford”’, 2, Feb. 2021. [2] Centre for Health Services Studies, University of Kent, ‘Air Quality Review for 4309/19 - Development Site At Tesco Extra 822 High Road, High Road, Chadwell Heath, Romford’, Jul. 2020 [Online]. Available: https://docs.google.com/document/d/e/2PACX-1vQKR35yObiugCbV_kKBTcjcrMWQjh5 CFh3fGMlnOFdowkACPz0UjtiFPxk3GqfsbXppVJ6mAk2peQuk/pub [3] Centre for Health Services Studies, University of Kent, ‘Air Quality Review (V2) for Amended Scheme; Proposed Redevelopment at 822 High Road, Goodmayes (LPA ref: 4309/19).’, Sep. 2020 [Online]. Available: https://docs.google.com/document/d/e/2PACX-1vTxY9w4rqzCLo5AtRtsICEfHbDD03i7u 0On_Xj5o_boN7L9Eb-7JcsDWQwVC7Vx9nKVZJDVIr387VEV/pub [4] Aether Ltd, ‘Goodmayes Environmental Statement Technical Appendix C: Air Quality’, Oct. 2019 [Online]. Available: https://planningdocs.redbridge.gov.uk/NorthgatePublicDocs/00685291.pdf [5] ‘Aether Ltd’, ‘ES Technical Appendix C1 Air Quality Assessment V6: for Amended Scheme: Proposed Redevelopment at 822 High Road, Goodmayes’, Aug. 2020 [Online]. Available: https://planningdocs.redbridge.gov.uk/NorthgatePublicDocs/00728205.pdf [6] P. Huangfu and R. Atkinson, ‘Long-term exposure to NO2 and O3 and all-cause and respiratory mortality: A systematic review and meta-analysis’, Environ. Int., vol. 144, p. 105998, Nov. 2020, doi: 10.1016/j.envint.2020.105998. [7] Committee on the Medical Effects of Air Pollutants, ‘Associations of long-term average concentrations of nitrogen dioxide with mortality’, Public Health England, Aug. 2018 [Online]. Available: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment _data/file/734799/COMEAP_NO2_Report.pdf [8] I. C. Mills, R. W. Atkinson, S. Kang, H. Walton, and H. R. Anderson, ‘Quantitative systematic review of the associations between short-term exposure to nitrogen dioxide and mortality and hospital admissions’, BMJ Open, vol. 5, no. 5, p. e006946, May 2015, doi: 10.1136/bmjopen-2014-006946. [9] M. Corso, M. Blanchard, S. Medina, and V. Wagner, ‘Short-Term Associations of Nitrogen Dioxide (NO2) on Mortality in 18 French Cities, 2010–2014’, Atmosphere, vol. 11, no. 11, p. 1198, Nov. 2020, doi: 10.3390/atmos11111198. [10]M. Alvarez-Pedrerol et al., ‘Impact of commuting exposure to traffic-related air pollution on cognitive development in children walking to school’, Environ. Pollut., vol. 231, pp. 837–844, Dec. 2017, doi: 10.1016/j.envpol.2017.08.075. [11]‘Record of Inquest - Ella Roberta Adoo Kissi-Debrah’, Nov. 2020 [Online]. Available: https://www.innersouthlondoncoroner.org.uk/assets/attach/86/mnizari_16-12-2020_10-2 8-00.pdf [12]AECOM, ‘London Borough of Lewisham Nitrogen Dioxide Diffusion Tube Survey 2011’, Apr. 2012 [Online]. Available: https://lewisham.gov.uk/-/media/files/imported/2011-20no2-20diffusion-20tube-20annual20report.ashx [13]London Borough of Lewisham, ‘2012 Air Quality Updating and Screening Assessment for London Borough of Lewisham’, 2012 [Online]. Available: https://lewisham.gov.uk/-/media/files/imported/updatingandscreeningassessmentmay201 2.ashx