The Mepa communications office's reaction (Air Pollution Targets And Their Achievement, May 29) to the report in The Times about Malta falling short of air pollutant targets (May 25) fails to convince because it attempts to paint too rosy a picture when there are, not one, but at least half a dozen elephants in the room which are conveniently omitted from the reply.

The main thrust of the letter is that "... air quality problems would be eliminated once the Air Quality Plan is effectively implemented". This is a pious hope. Innumerable reports are drawn up but end up as purely cosmetic exercises because they are rarely followed up.

The biggest elephant in the room currently is our polluting public transport and heavy transport. With a deft play of words, the letter bypasses the most toxic of all emissions - particulate pollution from so many diesel-driven vehicles. The Air Quality Report also misleadingly states that Malta's public transport reform will result in the replacement of our (heavily polluting) bus fleet with buses "conforming to minimum standards applicable in European Directives and Regulations". This is simply not true.

There is, in fact, no intention to buy new, EU-compliant, environment-friendly buses conforming to Euro V. The stated plan is to invest in second-hand buses "up to 15 years old" which only conform to Euro III standard. Such vehicles are already environmentally obsolete by today's EU standards and, as they get older in a few years' time, they will spew out dangerous emissions all over again and we will be back where we are now.

Something is also wrong when we are told that fixed monitoring stations in Msida, Żejtun, Kordin and Għarb "only registered levels in excess of EU annual limit values for nitrogen dioxide in Msida" while omitting the most dangerous pollutant from diesel engines: particulates and benzene.

These sampling points are also not necessarily representative owing to Malta's unique situation. Malta is overcrowded and densely urbanised with mostly narrow roads so that pollution at street level is amplified. Most people inevitably live close to streets which carry heavy traffic. It is now scientifically proven that people living in, or near, such streets are at especially high risk of dying prematurely from lung or heart disease or cancer and, besides sustaining permanent lung damage, children are rendered more prone to asthma attacks. Given the peculiar circumstance in Malta, monitoring certain densely built-up and congested sites such as major roads in Ħamrun, Birkirkara, Fgura or St Julians would permit a more realistic assessment.

The air quality report makes some sound recommendations but omits fundamental measures which might encourage healthy mobility such as adapting or re-engineering roads in built-up and residential areas in such a way as to make them pedestrian-friendly. There is little about discouraging car use and encouraging zero carbon options such as walking or cycling for short journeys.

Vague non-specific proposals as "promoting cleaner vehicle technologies" are of little use when there is barely a mention of low-carbon electric cars, hybrid cars, healthy zero-carbon transport as the bicycle or strong fiscal incentives aimed at persuading people to buy smaller (or hybrid or electric) cars. Neither is any thought given to innovative approaches such a harbour transport ferry network which could take an enormous public transport load (and its attendant pollution) off the roads around the harbour area. Altogether, the plan is insufficiently holistic to be of much use. The devil is in the detail and the list of possibilities is endless.

In this context one fundamental fact must be considered: there is no "safe" level at which pollution, including diesel particulates, does no harm. This pollution is harmful at any level above zero. The object of measures aimed at improving air quality should, therefore, primarily be health considerations. Just striving to reach EU targets, possibly with non-representative data, disregards Mepa's duty to realistically protect the health of the nation.