The Air We Don’t Measure: Folkestone & Hythe’s DCs PM2.5 Blind Spot and Wood-Burner Pollution

The council’s latest Air-Quality Report 2025 measures nitrogen dioxide to the decimal point — but sidesteps the particles most linked to early deaths. Meanwhile, Hythe is singled out for wood-burner pollution, yet the council’s own report doesn’t even utter the words “wood burner”.

What The Council Measures – And What It Doesn’t

Folkestone & Hythe’s 2025 Air Quality Annual Status Report (ASR) is unambiguous about its focus: nitrogen dioxide (NO₂). In 2024 the council ran 18 diffusion tubes for NO₂ only, with the highest annual mean recorded at 19.3 µg/m³ on Black Bull Road (A259) — comfortably below the 40 µg/m³ limit. There have never been any Air Quality Management Areas declared in the district.

But the same document makes a critical admission: “There is not currently any monitoring of PM₁₀ or PM₂.₅ within the district.” Instead of measuring real local concentrations, the council relies on national background maps and a Public Health Outcomes Framework statistic showing 4.7% of deaths attributable to PM₂.₅ locally — a figure below England’s average but still a meaningful burden of disease.

The ASR also says an Air Quality Strategy is “in the latter stages of development” with a planned publication of September 2025 — delayed due to staff absences. However we are now in November and still not Air Quality Strategy which means the district remains effectively PM-blind.

The Wood Burner Gap – And Hythe’s Problem

Residents will search the ASR in vain for a plain-English assessment of wood-burning stoves. The report discusses Smoke Control Areas in general terms and notes 129 smoke complaints in 2024 with no formal notices issued, but it neither evaluates domestic solid-fuel burning nor quantifies its PM₂.₅ contribution. There are no SCAs anywhere in the district.

That silence jars with independent reporting. In April 2025, Shepway Vox highlighted that Hythe tops charts for wood-burner pollution, calling out the district for “green hypocrisy.” Whatever one thinks of the tone, the story forces precisely the conversation the council’s own report avoids.

This Isn’t A New Warning – It’s A Long Running One

Back in September 2019, former Green Cllr Lesley Whybrow formally asked the council about PM₂.₅ and PM₁₀ monitoring. The official response: Folkestone & Hythe did not monitor particulates and saw no need because there was no AQMA. Six years on, the 2025 ASR confirms the position is unchanged: still no PM monitoring. That’s a continuity problem the council can’t pin on predecessors; it spans administrations.

Equality DutyMeets Air Quality – But Misses Respiratory Health

The council’s Equality & Diversity Annual Report 2024–25 (Draft) to go before Cabinet next week, sets out demographics, engagement and objectives. What it does not do is treat air quality or respiratory exposure as an equality issue in its “understanding our communities” material. There is no clear thread on how pollution hits children, older people, those with long-term conditions, or low-income households — all groups the ASR itself names as more vulnerable. In short: the equality paperwork doesn’t connect to the district’s air-pollution risks.

Asthma In Folkestone & Hythe – What The Rates Us, And Why Particulates (PM₂.₅/PM₁₀) matter

Children. OHID’s “East Kent Health & Care Partnership at-a-glance” snapshot classifies emergency hospital admissions for asthma in under-19s in Folkestone & Hythe as ‘Similar’ to England in recent years (2021/22–2022/23). It’s not the worst in Kent, but it isn’t better than average either — which is the point: “no AQMA” and “no exceedances” on NO₂ do not mean the asthma burden is low or solved.

Adults. Nationally, adult (19+) emergency admissions for asthma rose 17% to ~85 per 100,000 in 2023/24, with wide regional variation (East of England lowest at ~66 per 100,000). That national swing matters locally because service demand and risk track regional patterns. And in primary care, asthma register prevalence is about 6.5% nationally (QOF 2023/24); in the Kent & Medway ICB that covers Folkestone & Hythe it’s around 5.6% — roughly 1 in 18 patients.

The particulate gap — still unfilled. The Council’s own 2025 ASR confirms it does not monitor PM10 or PM2.5 (only NO₂ via diffusion tubes). That is not a minor technicality: asthma exacerbations are strongly associated with particulate exposure as well as NO₂.

The monitoring gap has been known for years: the Council told a full meeting on 24 July 2019 that it did not monitor PM2.5 or PM10 because there was no AQMA; local campaigners — including former Green Cllr Lesley Whybrow — have repeatedly pressed the case in public forums since, and local reporting flagged the absence of PM monitoring again in April 2021. Yet the 2025 ASR still has no PM data.

The causal link (PM2.5/PM10 ↔ asthma).

• NICE NG70 makes clear that fine particles (PM2.5), coarse particles (PM10), and NO₂ are all important contributors to ill-health from road traffic pollution, with evidence of both short- and long-term effects. 

• UK-based time-series work shows higher NO₂ and PM2.5 are associated with higher asthma admissions, reinforcing the local relevance of measuring particulates, not just NO₂.

• COMEAP/UKHSA have repeatedly updated the evidence on PM2.5 harms (no safe threshold; updated concentration-response functions), underlining why PM monitoring must sit alongside NO₂ tubes if we are serious about respiratory health.

So what does this mean here? Even if NO₂ levels are “compliant,” you can’t claim clean air for asthma-vulnerable residents without PM2.5/PM10 data. That is precisely the blind spot: a district with “average” asthma admissions and zero local PM monitoring cannot demonstrate whether daily or seasonal particulate spikes are driving exacerbations in hotspots (busy corridors, wood-burner clusters, construction and resuspension dust, tourism traffic to the coast). The Council’s own ASR shows progress on NO₂ and promises an Air Quality Strategy in September 2025, but particulates remain unmeasured.

EV Roll Out: Good For Tailpipes, Not A Silver Bullet For Particles

To its credit, the council has gone big on charging: 103 public EV charge points across 26 car parks, installed with KCC and Connected Kerb as part of the “Kent 600” programme (201–600 countywide). That network was declared complete by February 2023 and has since been repeatedly celebrated.

But EVs mainly cut tailpipe NOₓ — the pollutant the council already measures and says is compliant. They do far less to reduce non-exhaust particles from tyres, brakes and road dust, which dominate PM₂.₅/PM₁₀ on many urban streets. The evidence base is not niche:

• UKHSA’s 2023 guidance (p:31) stresses non-exhaust sources (tyres, brakes, resuspension) and the need to mitigate them through urban planning and transport policy.

• Air Quality News has repeatedly reported that tyre wear can exceed exhaust emissions and that policymakers are playing catch-up on PM from EVs (heavier vehicles can mean more tyre wear without careful design/standards).

The council itself lists EV infrastructure as a measure to reduce PM₂.₅ in its ASR. Without local PM monitoring, that reads more like assumption than evidence.

The Layperson’s Bottom Line

• The council is measuring the pollutant (NO₂) that already meets legal limits, while not measuring the particles (PM₂.₅/PM₁₀) most associated with heart and lung disease.

  Folkestone_and_Hythe_ASR_2025

  Folkestone_and_Hythe_ASR_2025

• Its flagship air-quality document doesn’t analyse wood-burning stoves, even as external reporting singles out Hythe for wood-burner pollution. 

• Cllr Lesley Whybrow asked for action on particulates in 2019. In 2025, the ASR still says no PM monitoring. That’s a six-year gap between concern and delivery.

• EV chargers are welcome but don’t remove tyre/brake dust — the council’s own health narrative should reflect that, and its equality reporting should recognise who bears that burden

What Needs To Change – Practical, Testable Steps

• Start measuring PM₂.₅ and PM₁₀ now
  Install at least one reference-grade monitor in Hythe and one in central Folkestone (near traffic canyons and residential streets) and publish hourly data on the website. Stop relying solely on background maps. 

• Publish the Air Quality Strategy on time — with PM targets
  The promised September 2025 strategy – still not published – must include PM reduction targets, not just NO₂ narratives, and a monitoring expansion plan financed and scheduled. 

• Get honest about wood burning
  Produce a domestic burning evidence review for the district, consult on Smoke Control Areas, and explain how 129 smoke complaints resulted in zero notices — is the policy, the triage or the enforcement at fault? 

• Make air quality part of the equality duty
  Add a health inequalities section to the Equality & Diversity Report that tracks respiratory admissions, asthma prevalence, COPD, and overlays them with traffic density and deprivation. Name actions for schools, older residents and low-income renters (e.g., filters, retrofit, route planning). 

• Re-frame EV policy around particles
  Keep the chargers, but couple them with measures that cut non-exhaust PM: lower speeds on pinch-points, bus priority, street cleaning for dust, weight-based parking bands, and procurement of low-tyre-wear tyres. Cite UKHSA guidance when you do it.

Conclusion

Until the council stops congratulating itself for compliant NO₂ while ignoring the particles that kill, it isn’t leading on clean air — it’s managing the optics. Six years after a Green councillor first flagged PM₂.₅ and PM₁₀, the Green-led council still isn’t measuring them, still dodges wood-smoke, and still leans on EV headlines to fill the gap. Hythe’s wood-burner hotspot and the tyre-dust reality make that omission indefensible. Publish the strategy, fund reference-grade PM monitors, enforce smoke rules — or admit “clean air” is a slogan, not a policy.

The Shepway Vox Team

Journalism for the People NOT the Powerful