The Air Quality Targets (Fine Particulate Matter) (Wales) Regulations 2026: integrated impact assessment sections 1 and 8

Title of proposal

The Air Quality Targets (Fine Particulate Matter) (Wales) Regulations 2026 

Official(s) completing the Integrated Impact Assessment (name(s) and name of team)

John Griffiths, Senior Air Quality Targets Policy Manager - Air Quality, Evidence, Monitoring and Assessment Branch

Department

CCRA Local Government, Housing, Climate Change and Rural Affairs Group

Head of Division/SRO (name)

Philip Bowen, Deputy Director, Environmental Protection Division

Claire Bennett, Director Climate Change and Environmental Sustainability

Tracey Burke, Director General Local Government, Housing, Climate Change and Rural Affairs

Cabinet Secretary/Minister responsible

Huw Irranca-Davies MS, Deputy First Minister and Cabinet Secretary for Climate Change and Rural Affairs

Start Date

May 2024

In narrative form, please describe the issue and the action proposed by the Welsh Government. How have you applied / will you apply the five ways of working in the Well-being of Future Generations (Wales) Act 2015 to the proposed action, throughout the policy and delivery cycle?

The World Health Organisation has described air pollution as the world’s largest single environmental health risk. It is a particular risk to vulnerable groups such as the elderly, young children, and individuals with pre-existing health conditions. In addition, poor air quality can adversely affect wildlife through widespread changes to species distribution and the quality of habitats. Fine particulate matter (PM2.5) is the air pollutant which causes the greatest harm to the health of the Welsh population. 

The Environment (Air Quality and Soundscapes) (Wales) Act 2024 (‘the Act’) builds on our commitments in the Clean Air Plan for Wales: Healthy Air, Healthy Wales, enhances existing legislation and will deliver air quality improvements in Wales. The Act introduced a national air quality target setting framework, which strengthens Welsh Ministers’ powers and enables the introduction of long-term targets for identified pollutant risks. The framework requires Welsh Ministers to set targets for pollutants, including the setting of a target for fine particulate matter (PM2.5) by February 2027.  The targets for PM2.5, subject to the outcomes of this public consultation and the approval of Welsh Ministers following the Senedd elections in May 2026, will be set in regulations which will be made in 2026-2027.  

The primary aim is to reduce concentrations of PM2.5 in ambient air to improve environmental and public health in Wales.  

The text below explains how the setting of PM2.5 targets delivers on the sustainable development principles inherent to the Well-being of Future Generations (Wales) Act 2015 with a focus on the five ways of working.  

Long term trends, challenges and opportunities

In Wales, the long-term mortality burden attributable to air pollution exposure is an estimated effect equivalent range of between 1,000 and 1,400 deaths (at typical ages) each year (Public Health Wales). Burden range does not reflect ‘actual’ deaths from air pollution exposure. It is an estimate of the ‘equivalent’ reduced life expectancy, when summed, which everyone experiences because of air pollution exposure.

Prevention

Setting targets to reduce PM2.5 is a preventative and long-term action, which will reduce impacts of air pollution on public health and the natural environment through the implementation of potential cross-sector measures and future policy choices. It will have immediate positive impacts, as well as longer term positive impacts as actions taken towards meeting the targets are implemented.

The purpose of setting new air quality targets is to reduce the harm caused by exposure to poor air quality to human health, nature and the environment. Alongside providing a ‘minimum’ level of air quality across Wales, we also want targets to drive long-term continuous improvement to reduce average population exposure to pollution whilst maximising the associated benefits. 

Integration

Current and future actions to meet the new targets for PM2.5 are and will be integrated with our cross-Government strategies and plans, including the Programme for Government, the Net Zero Wales Plan, and the Wales Transport Strategy. Actions taken to improve air quality also align with key areas of the Environment (Wales) Act 2016 and priorities in our statutory Natural Resources Policy and Planning Policy Wales. 

Collaboration

Solutions to improving the air environment can be complex, requiring collaborative actions across society, including national and local governments, businesses and the public. 

Partners who have a shared interest in this proposal include relevant departments within Welsh Government; UK Government; Local Authorities in Wales; Non-Governmental Organisations; Public Health Wales; Natural Resources Wales; NHS Health Boards; Transport for Wales; including the voluntary and private sectors. Collaboration aims to ensure actions are implemented and well-being objectives are met.

Involvement

We have involved internal and external stakeholders across Government and sectors, including the public, NGOs and independent air quality experts, in developing the proposals. We will continue to involve these stakeholders through the public consultation and the implementation process to draw on their wealth of knowledge and understanding of what is needed in different places by different groups of people.

Impact

What are the main arguments for and against the proposal? Please refer to evidence; acknowledge significant gaps in our knowledge and describe any plans to fill them.

For

Reducing PM2.5 to meet these ambitious targets will have a significant benefit on health and associated health inequalities.  Analysis commissioned by the Welsh Government suggests that air quality targets would benefit citizens living in the most populous regions of Wales especially, with the highest proportion of children and Black Asian and Minority Ethnic residents, as well as people living in the most and least deprived areas. The targets will reduce the impact of air pollution on ecosystems and will contribute to the delivery of climate change objectives.

Against

The chosen level of target ambition will influence the costs involved and the extent of adjustments both organisations and individuals will need to make. 

Costs for individual households

It is considered that individual households will bear costs (e.g. indirect costs passed on by companies through higher prices, cost of energy-efficient equipment and Electric Vehicles [EV] etc.).

However, there are ways in which the Welsh Government helps to mitigate higher costs for individual households:

• The Welsh Government provides financial assistance for energy efficient equipment through the Warm Homes Nest Scheme which offers free home energy efficiency improvements; and
• The Green Homes Wales Initiative which provides interest-free loans for home upgrades like heat pumps and solar panels, these range from £1,000 to £25,000.  

In relation to transport, there is also governmental financial assistance: the Welsh Government, in partnership with the UK Government, offers various grants for installing EV charging points, including grants for households with on-street parking or for those who are renters/flat owners, as well as support for businesses (small to medium-sized businesses and larger organisations) through the Workplace Charging Scheme and EV Infrastructure Grants. The schemes aim to cover a percentage of the costs for charging points and associated infrastructure, up to specific maximum amounts per property or site. 

Furthermore, all senior citizens and disabled people receive free bus travel throughout Wales.

8.1    How have people most likely to be affected by the proposal been involved in developing it?

The Welsh Government’s proposals for the Act were consulted on from 13 January to 7 April 2021 in the White Paper on a Clean Air (Wales) Bill, which included the proposed target setting framework and specific duties to set a target for PM2.5. 

We received 119 contributions to the consultation, including opinions provided at the White Paper event held on 11 March 2021 which was held virtually due to COVID restrictions.  The Summary of Responses shows a range of views were expressed, respondents were generally supportive of the proposals for legislation. 

Discussions with stakeholders continued during 2022 and beyond, in a process of more targeted engagement, this included, for example, the Children's Right Advisory Group, Healthy Air Cymru and the Cross-Party Group on the Clean Air Act, and Senedd Cymru’s own consultation on the Environment (Air Quality and Soundscapes) (Wales) Bill.

The people most likely to be positively affected by the proposal are vulnerable groups (including children, older adults and people with pre-existing heart or lung conditions).  In addition to consulting the public, we are consulting Public Health Wales; Healthy Air Cymru; Health Boards; NHS Trusts; and a range of other bodies concerned with public health.  

To safeguard and promote the interests of people with protected characteristics, we are consulting the Equality and Human Rights Commission, including a range of third sector organisations. 

To safeguard and promote the interest of children and young people, we are consulting the Youth Parliament and the Children’s Commissioner for Wales.      

8.2 What are the most significant impacts, positive and negative?

Positive impacts

The overarching aim of setting targets for PM2.5 is to contribute to improvements in air quality in Wales, reducing the impacts of air pollution on human health, the economy, biodiversity and the natural environment (Science Direct).  

As set out below, the proposals to set targets for PM2.5 have taken the seven well-being goals in the WFGA into account: 

Well-being goals

A resilient Wales

Improvements in the air environment have a direct, significant and positive impact locally, regionally and nationally on the Welsh environment and ecosystem functionality. 

A Prosperous Wales

A healthy workforce and clean air environment would contribute to prosperity through an increased productive workforce. Improvements in health reduce medical and healthcare costs. The options considered to deliver the PM2.5 concentration reductions have all been assessed to have positive benefit-cost ratio (BCR) ranging between 3.6 and 4.3, meaning that benefits of the targets and actions taken to achieve these are estimated to surpass the costs that would be incurred by public and private stakeholders in Wales.  Reducing annual mean concentrations of PM2.5 in ambient air in Wales will reduce hospital admissions and pressure on healthcare services.

A Wales of vibrant culture and thriving Welsh Language

We are committed to having air quality which supports the people of Wales and visitors to enjoy a wide range of recreational activities across Wales. Protection of natural ecosystems and biodiversity would enhance the cultural capital of Wales, outdoor recreation etc. We will treat English and Welsh equally when delivering communications activities relating to PM2.5 targets.  

A Healthier Wales

The World Health Organisation has described air pollution as the world’s largest single environmental health risk. Pollutants such as fine particulate matter (PM2.5) are a cause of some health problems and can make others worse. Breathing in these pollutants over several years can increase health risks from heart and lung diseases, and lung cancer. There is also evidence that other body organs may also be affected, possibly contributing to incidence of dementia, low birth weight and diabetes. Symptoms arising from shorter-term exposure can include eye, nose and throat irritation. Action taken to implement the targets will result in an improvement in air quality with consequent improvements in public health. As set out in the Ricardo report ‘Evidence to support the development of PM2.5 target proposals in Wales’, reductions in concentrations are expected to lead to reductions in the number of productivity days lost due to ailments associated with air pollution (savings range from £50 million to £110 million).

A more equal Wales

Reduction of air pollution will have a direct and significant impact on improving health and welfare for everyone, with the greatest impact likely to be felt by those who disproportionately experience greater impacts from air pollution due to health, environmental or socioeconomic reasons. 

A Wales of cohesive communities

Actions to improve air quality will have greater impact when integrated with other actions to improve the quality of life, health and well-being, the environment and opportunities for prosperity.  Reducing concentrations of PM2.5 can contribute to people of all backgrounds having full access to life opportunities.  

A globally responsible Wales

Air pollution is a major global environmental problem affecting everyone, it does not respect national and international borders. The targets’ proposals demonstrate Welsh Ministers are taking strong positive action on air quality in Wales to meet national and international ethical and legal obligations. This action consolidates Wales’s standing in the international community as a country dedicated to sustainability and environmental action. Many of the measures taken to improve PM2.5 concentrations are likely to reduce greenhouse gas emissions and reduce the harmful effects of climate change. 

Negative impacts

It is unlikely ambitious national air quality targets set for PM2.5 could be achieved without additional action beyond the existing policies, measures and natural technology turnover which are planned and committed to date. Actions required of Welsh Government, public bodies, businesses and individuals are expected to include both changes to behaviour and technology, with implications in terms of lifestyle and economic cost.  It is essential to balance the health benefits against the necessary actions and their economic implications. We consider the proposed targets to strike the optimal balance between maximizing health outcomes and minimizing impacts on people’s daily lives. The benefits of the targets and actions taken to achieve these are estimated to surpass the costs that would be incurred by public and private stakeholders in Wales.

8.3 In light of the impacts identified, how will the proposal: 

• maximise contribution to our well-being objectives and the seven well-being goals; and/or,

• avoid, reduce or mitigate any negative impacts?

What action can the Welsh Government take to promote biodiversity, children’s rights, equalities, the Welsh language or another of the areas covered by your impact assessments?

What action can the Welsh Government take to strengthen its contribution to a particular goal or to contribute to additional goals?

What action can the Welsh Government take to avoid, reduce or mitigate a negative impact?

If no action is to be taken to avoid, remedy or mitigate a negative impact then please explain why.

The ways in which the PM2.5 target regulations will contribute to the Welsh Government’s seven well-being goals are outlined above. The regulations will also maximise our contribution to the Welsh Government’s well-being objectives.

In particular, the Annual Mean Concentration Target sets a concentration limit to be achieved by 31 December 2035.  This provides equity with a focus on reducing concentrations where they are highest and providing a minimum standard of air quality across the country.  The Population Exposure Reduction Target sets a reduction in average population exposure aimed at driving continuous improvement in areas of public exposure across the country. The new draft regulations are a key step in meeting our aim to improve air quality and reduce the impacts of air pollution on human health, biodiversity, the natural environment and our economy.  This is particularly significant in terms of PM2.5 given that there is no threshold below which exposure to PM2.5 is safe.  

For these reasons, the new draft regulations need to be seen in a broad context, and not in isolation. They:

• are a crucial part of a package of measures set out in our Clean Air Plan to reduce airborne pollution and improve the air environment in Wales; and they
• complement and build upon existing legislation.  

The target regulations provide a framework for action that will have the effect of reducing airborne pollution. Once the draft regulations are made and implemented, Welsh Ministers will be under a duty to put in place arrangements for monitoring progress in relation to meeting targets.  

Analyses undertaken by technical consultants

During 2022-2024, technical consultants undertook modelling which included sets of measures/different combinations of measures with assessments of potential reductions in pollutant concentrations including PM2.5.  The modelling showed how pollutants disperse in the atmosphere, forecasted future pollution levels and demonstrated how combinations of measures could potentially reduce concentrations of pollutants in the atmosphere.  

The modelling and technical analyses of feasible target levels and dates across different air quality scenarios for PM2.5 found that although the level of action (medium, high, speculative) impacted concentration levels across Wales, the distribution of benefits remained largely the same after the level of action in each air quality scenario as it was before. Technical analyses considered income deprivation, proportion of children, proportion of elderly residents, proportion of Black Asian and Minority Ethnic residents for all assessed pathways. This showed that the distribution of benefits was similar across demographics, irrespective of the pathway of measures implemented.

However, technical analyses revealed that the biggest reduction in PM2.5 will occur in the most populous regions of Wales, the most and least deprived areas of Wales and in areas with the highest proportion of children.  Technical analyses also showed for each scenario that the level of PM2.5 pollutant reduction tends to increase as the proportion of Black Asian and Minority Ethnic population increases. 

This analysis highlights the importance of taking action to reduce concentrations of PM2.5 in ambient air across Wales.      

The ‘Impact of target proposals’ section of the consultation document explains the health benefits to emerge from the proposals while the ‘Economic assessment of the proposals’ section explains the economic productivity benefits.  These benefits extend across society, including across the sectors of the economy.  Improved health leads to higher output per worker and reduces pressure on NHS Wales.  This results in more funding for public services for the benefit of society.  This also leads to individuals leading happier, more fulfilled lives.   

8.4 How will the impact of the proposal be monitored and evaluated as it progresses and when it concludes?  

What plans are in place for post implementation review and evaluation?

Monitoring and Evaluation

The targets set under the Act must be reviewed within 5 years from the date on which the targets are set.  There is also a duty on Welsh Ministers to make arrangements for obtaining data about air quality in Wales for the purpose of monitoring progress in achieving the targets. This data must also be published. Welsh Ministers must report on targets, laying and publishing a report confirming whether a target has been met.  Additionally, when the date for achieving the target has been reached and the specified standard for the target has been achieved, the Welsh Ministers will be under a duty to maintain the specified standard and to put in place reporting arrangements. These provisions embed accountability and transparency into the target-setting framework.  

The achievement of the target will be demonstrated through PM2.5 measurements obtained from “representative monitoring” stations across Wales and will be specified in the statutory instrument. Details of required number of monitors, location, location types, instrument specifications and data capture objectives will be stated. Progress toward meeting the targets will be assessed annually using predefined metrics and data trends. Additional monitoring stations will be added to the existing monitoring network sites in Wales, to improve geographical/spatial coverage and to ensure reporting integrity.