The Air Quality Management Resource Centre at the University
of the West of England (herein AQMRC, UWE) has many years of experience working
directly with and for local government in assisting them with their statutory
Local Air Quality Management (LAQM) duties, appraising Review and Assessment
reports and Further Assessments, and also in disseminating Continuing
Professional Development training on LAQM to local authorities and
environmental consultancies. AQMRC has been involved in the development of LAQM
since its inception and has been central to the development of statutory and
non-statutory guidance, both directly and through consultation responses,
including for the repeal of Further Assessments. Over the last 15 years, AQMRC
has undertaken extensive primary research and published widely on the LAQM
process, its strengths and weaknesses. AQMRC is therefore fully versed on the
role of LAQM and these opinions are based on direct experience and on those
experiences recounted by local authorities with whom we have worked. AQMRC is
also currently assisting the European Commission with the review of the Air
Quality Directive and so is well-placed to recognise the importance of LAQM to
national air quality policy in achieving the EU Limit Values.
Our responses to each of the consultation questions are
presented below. In outline our views
are that:
·
LAQM needs to be reinvigorated and its public
health protection purpose restated and prioritised.
·
The Air Quality Regulations need to be updated
and aligned more explicitly with EU Limit Values.
·
The Air Quality Strategy needs to be reviewed
and updated redefining the contributions of national and local actors.
·
Local Authorities need support and encouragement
to implement Action Plan measures.
·
Review and Assessment, the diagnosis of air
quality problems or improvements, is an essential precondition for effective
and targeted action to improve air quality, and its evaluation. It must therefore
be retained although the current administrative arrangements could be improved.
·
In support of public health improvements,
Government (both national and local) needs to achieve greater internal
coordination of departmental actions and to deploy these interventions more
effectively.
·
Local authority actions can contribute to
meeting EU Limit Values, but the means by which this is reported needs careful
consideration.
AQMRC has published extensively on the LAQM process since
1996 and some of our relevant publications are listed at the end of this
response. These chart the evolution of the process and helped identify many of
the opportunities, concerns and challenges of air quality management in the UK
and further afield.
1. What are your
views on whether we should consolidate EU and National Air Quality Objectives
and how this might best be achieved?
In the considered opinion of the AQMRC, consolidation of the
EU limit values and the national air quality objectives may be an appropriate
strategy, insofar as these then reflect the public health protection evidence. There
are notable differences in the pollutants, averaging periods and timescales for
achievement between the Air Quality England Regulations and the Air Quality
Standards Regulations that would need to be considered, e.g. the 15-minute
objective for SO2 is not reflected in the transposition of the EU
limit values, but has significant health implications and as a result has been
the subject of seven AQMA declarations in England.
There are also discrepancies between the applicability of
the EU limit values and national air quality objectives in terms of relevant
public exposure. Clarification would be required for local authorities on how
to determine relevant exposure, given that the EU Air Quality Directive is less
prescriptive than LAQM guidance on how exposure is related to the different
averaging periods of objectives/limit values, assuming this is not changed in
the Air Quality Directive review.
To ensure a coordinated approach across the UK it is
essential that this process of consolidation should be undertaken in the
context of a revised national air quality strategy.
2. What are your
views on the range of objectives local authorities should work towards and
whether or not these should be reduced?
The range of pollutants that local authorities are required
to work towards, as currently prescribed in the national air quality
objectives, are based on the risk of public health effects. For many local
authorities, most of these pollutants and objectives have effectively been ‘screened
out’ in previous rounds of Review and Assessment, however given that the role
of local authorities is to ensure concentrations of pollutants remain below the
objectives, it is essential that a mechanism is retained to ensure local
assessment of potential new sources and concentrations of all pollutants remain
below health-based thresholds. This currently represents a minimal burden on
local authorities through existing Review and Assessment reporting and there is
therefore no gain to be made in reducing this aspect.
As described in the response to Q1 above, there are
pollutants that are included in the air quality objectives but that are not
represented in the EU limit values. It is clear that where there are local exceedences,
or near exceedences of these objectives, these pollutants should be retained.
There are also pollutants reflected in the limit values that
are not currently included in the air quality objectives for which local
authorities should give consideration, e.g. PM2.5. Particularly
given potential increases in these pollutants resulting from local biomass
combustion consideration should be given as to how these are passed on to LAs.
As mentioned in the response to Q1 above, any change to the
air quality objectives that local authorities are required to work towards
achieving should be preceded by a revised national air quality strategy for the
UK which clearly sets out the national context of any required local actions.
3. What contribution
can local authorities make in reducing emissions and/or concentrations from PM2.5
pollution? Please provide examples, where appropriate.
Typically, any local authority measure that is targeting PM10
or NO2 from traffic will also be relevant to PM2.5. However, given the point made in Q2 above
regarding potential new sources for this pollutant, it may be appropriate for
local authorities to have some explicit responsibility for managing local
contributions to PM2.5, particularly given that there is no safe
health threshold for fine particles.
4. Which option will
best help to support Aim 1?
In the opinion of AQMRC, none of the proposed options would
be recommended to support Aim 1. However, an adaptation of Option 2 would
enable the consolidation of EU limit values and national air quality
objectives, while still retaining the ability for local authorities to identify
any local sources that may give rise to pollutants outside of this remit. As
previously stated, any amendment to the Regulations would necessitate the
revision of the national air quality strategy for the UK.
5. What are your
views on how cooperation between different tiers of local authorities can be
supported?
A statutory duty to improve air quality on all local governments,
regardless of tier, is necessary particularly for those departments whose
policies may influence air quality to ensure that these policies and practice
do not worsen air quality where there is an exceedence, and for these
departments to take responsibility for ensuring that they actively reduce
pollutants to below the exceedence thresholds. These statutory duties must be clear,
achievable and enforceable, and must be upheld by national departments, e.g.
DfT, and not contradicted by other political imperatives. In order to ensure
roles and responsibilities are explicit, a revised national air quality
strategy is required.
6. Do you have
evidence of where joint working has been effective and what has helped to
achieve this or where it has been less effective in supporting action to
improve air quality?
Extensive research undertaken by AQMRC (Olowoporoku et al., 2010; Olowoporoku
et al., 2011; Olowoporoku et al., 2012) has found a large
degree of disjuncture between Environmental Health and Transport departments’
attitudes to air quality management, with many Transport departments treating
air quality as a tick box exercise in LTPs in practice, severely undermining the
effectiveness of this approach to improving local air quality.
7. Do you think there
is a need to review the allocation of responsibility for air quality between
District and County authorities?
As discussed under the response to Q5 above, both County and
District level authorities should have a statutory duty to improve air quality,
preferably at a strategic level to ensure there is political buy-in from
Members. The problem is less to do with the division of tasks between tiers,
but the divisions of responsibilities between transport and environment
departments (and therefore a factor that is also applicable within Unitary authorities).
All departments that implement policies
that may influence air quality must be made responsible for ensuring not only that
these policies do not worsen air quality or introduce new exposure to areas
with exceedences, but that they actively contribute to improving air quality.
As discussed in response to Q5 above, this should be ensured through the
publication of a revised national air quality strategy.
8. Which option will
best help to support Aim 2?
Of the proposed options, the AQMRC consider Option 2 to be preferable
for supporting Aim 2. However, it is
recognised that the roles and responsibilities of national government
departments regarding air quality management need to be explicit and
communicated clearly to their respective departments at a local level. This may require alignment with EU limit
values, which should be achieved through the publication of a revised national
air quality strategy.
9. What are your
views on the current air quality reporting requirements for local authorities
and how they could be simplified?
While it is recognised that there is scope for reducing the
reporting burden on local authorities, it is a mistake to presume that local
authorities’ Review and Assessment activities are the limiting factor in
implementing local air quality Action Plans. There are many factors that
undermine the effectiveness and efficiency of Action Planning and limited
resources are only a small part. Other more influential factors include the
lack of a statutory requirement to achieve the air quality objectives (which is
not considered in this consultation document, but which undermines political
will to rate air quality in relation to other political pressures e.g. economic
development) and that the responsibility for LAQM is housed in Environmental
Health departments rather than with those that have an ability to manage the
pollution source.
It is vital to retain a statutory requirement for local
reporting on air quality in order to ensure continued monitoring at a local
level. Without local monitoring, there is no accurate measurement of local
concentrations, and no continual trend data against which to assess the
implementation of local measures to reduce pollution or to assess the public
health impact. It has already been shown that the national monitoring and
modelling as reported to the European Commission is unable to adequately
capture the local hotspots that local authority monitoring has identified
rendering local monitoring essential. Detailed and up-to-date air quality
information is also the most important tool in a local authorities’ armoury
when it comes to challenging new polluting developments. Without the information provided by regular
review and assessments it would be very hard to argue for appropriate mitigation
measures to be incorporated in developments and air quality would be likely to
worsen as a result.
It is recognised that in reducing the burden on local
authorities and ensuring efficient use of limited resources, reporting could be
simplified, and the proposed single annual technical progress report is recommended,
supported by a short, non-technical summary aimed at the public (see response
to Q10 below).
10. Do you think
there is a need for a more public facing local air quality report which
provides an annual review of action taken to improve air quality?
The technical report should not be ‘dumbed down’, but we
recognise the importance of public engagement and local authorities should
produce a separate short, non-technical public communication document that
notifies members of the public (particularly vulnerable groups, and those who
may be responsible for the highest emissions) about the quality of local air
and the potential health impacts, linked to public health data for their local
areas.
11. Do you think
there is a need for a better line of sight between local reporting on air
quality and what we report to the EU about local action?
Action taken at a local level should be reported to the EU,
but so should locally-measured concentrations. This recommendation accords with
the European Stakeholder Engagement Group recommendation to align local and
national reporting, a review of which was undertaken by UWE as part of a consortium
assisting the European Commission with the Air Quality Directive review. There
also needs to be a clear identification of responsibilities at a national level
and departmentally at a local level, which should be made explicit in a revised
national air quality strategy.
12. Do you think the
current arrangements for AQMAs should be retained or should they be removed
and/or local authorities given more flexibility in applying them?
AQMAs must be retained as basis for development control. In
many local authorities, AQMAs act as the trigger for identification of
developments that may require an air quality assessment and provide some degree
of protection against developments that may worsen air quality or introduce exposure
at these locations. If anything, AQMAs should be more standardised rather than
the ad hoc approach that currently
exists whereby one authority may only include the relevant exposure (not even
the area of technical exceedence in some cases), and a neighbouring authority
may have declared a whole borough/district AQMA.
Additionally, the declaration of an AQMA is often major
signifier of institutional recognition that an air quality problem exists. At the point of declaration it often becomes
much easier for cross-departmental communication, and appropriate allocation of
resources to occur.
This may even be an opportunity to radically rethink how
AQMAs are identified. Given the availability of public health data by postcode
it should be possible to identify postcodes where vulnerability to poor air
quality is relatively high in relation to measured/modelled concentrations of
pollutants. These areas should be targeted for improvements to air quality in
order to provide the greatest public health impact.
13. Which option will
best help to support Aim 3?
AQMRC considers that Option 2 is the preferred proposed
option to best support Aim 3. Option 3 would not be appropriate in achieving
this aim as a statutory duty to maintain local reporting is essential to ensure
the continuation of local monitoring in order to accurately assess
concentrations of pollutants for the purposes of public health assessment and
progress against measures to improve local air quality.
14. Would the
availability of information on evidence based measures to improve air quality
or reduce exposure help in developing local action plans?
Quantifiable evidence for implementation of measures should
be shared to support local authorities producing Air Quality Action Plans.
Likewise, any data/tools devised for one local authority that may be applicable
in others should be made more widely available.
15. Do you have
examples of good practice on the implementation of measures to improve air
quality or to communicate on air quality?
The EU FP5 INTEGAIRE project, in which UWE played a major
role, undertook a major EU wide review of air quality related measures. Its reports and accompanying good practice
database provide a good example of existing evidence representing good practice
across Europe (including the UK). (http://euronet.uwe.ac.uk/www.integaire.org/home.html).
See also:
16. Which option do
you think is most likely to improve local air quality management and why? Do
you have an alternative approach?
Of the four options proposed, Option 2 is considered to be
most likely to improve air quality management, provided that all parties are
clear on their roles and responsibilities and that there is a strong national
lead not to undermine local action, i.e. by accepting increasing road transport.
This can only be achieved in the context of a revised national air quality
strategy for England and the Devolved Administrations to completely re-evaluate
and re-contextualise the balance of local and national action.
17. Are any of the
options and their proposed changes to regulation, guidance and reporting likely
to adversely impact on air quality, if so to what extent?
Options 3 and 4 are likely to potentially worsen local air
quality impacts through their disregard of local hotspots; although there will
be no local monitoring available to quantify the effect on air quality, public
health may suffer. It is unlikely that Option 1 or 2 will lead to an
improvement in air quality (or necessarily prevent a worsening) without
significant national action and national support for local action, which should
be made explicit in a revised national air quality strategy.
18. Assuming no local
air quality management requirements existed as proposed in Option 4 to what
extent would local incentives and pressures from public health and amenities be
sufficient to support local action to improve air quality?
AQMRC, UWE are wholly against the proposed Option 4. It is
entirely unlikely that local pressure would be sufficient to support local
action to improve air quality. Most members of the public do not currently
appreciate the extent that poor air quality is affecting their health, or the
role that local authorities are taking to protect them. Given the largely
invisible nature of air pollution from road traffic, even a worsening of air
quality resulting from the removal of LAQM would probably not be noticed as
being directly related to any worsening in health effects.
Even with a statutory duty to act in pursuit of the air
quality objectives, very little is actually done at a local level to improve
air quality. Without this statutory duty it is hard to see how public pressure
could achieve any more.
Some of AQMRC’s LAQM Publications
Longhurst,
J.W.S., Lindley, S.J., Watson, A.F.R. & Conlan, D.E. (1996) The
introduction of local air quality management in the United Kingdom. A review
and theoretical framework. Atmospheric Environment. 30 (23) 3975-3985.
Beattie,
C. I., and J.W.S. Longhurst (2000) Joint working within local government: air
quality as a case study. Local Environment. 5 (4) 401-414.
Beattie,
C. I., J.W.S. Longhurst A. Simmons & D.M. Elsom (2000) Regulation and
Practice of Local Air Quality Management in England's major urban areas. AWMA
Environmental Manager. April pp49-55.
Beattie,
C. I., J.W.S. Longhurst and N.K. Woodfield (2000) Air quality management:
challenges and solutions in delivering air quality action plans. Energy and the
Environment 11(6) 729-747.
Ing,
C., C.I. Beattie and J.W.S. Longhurst. (2001) Progress with implementing local
air quality management in rural areas of England. Journal of Environmental
Management.61 (2) 137-147
Beattie,
C. I., J.W.S. Longhurst and N.K. Woodfield (2001) Air quality management:
evolution of policy and practice in the UK as exemplified by the experience of
English local government. Atmospheric Environment. 35 (8) 1479-1490.
Beattie,
C. I., J.W.S. Longhurst and N.K. Woodfield (2001) A preliminary analysis of the
linkage between air quality management and transport planning policies in a
sample of English Highways Authorities. Journal of Environmental Planning and
Management 44 (3) 391-408
Beattie,
C. I., J.W.S. Longhurst and N.K. Woodfield (2002) Air Quality Action Plans:
early indicators of urban local authority practice in England. Environmental
Science and Policy 5 463 - 470.
Beattie,
C. I., J.W.S. Longhurst and N.K. Woodfield (2002) A comparative analysis of the
air quality management challenges and capabilities in urban and rural English
local authorities. Urban Studies 39 (13) 2469-2483.
Woodfield,
N.K., Longhurst, J.W.S., Beattie, C.I., & Laxen, D.P.H. (2002) Designating
Air Quality Management Areas (AQMAs) in the UK: Implications for Securing UK
Air Quality Objectives. Water Air and Soil Pollution. 2, 677-688
Woodfield,
N.K., Longhurst, J.W.S., Beattie, C.I., & Laxen, D.P.H. (2003) Regional
variation in the implementation of the local air quality management process
within Great Britain. Journal of Environmental Planning and Management 46 (1)
49-64.
Woodfield,
N.K., Longhurst, J.W.S., Beattie, C.I., & Laxen, D.P.H. (2003) Critical
evaluation of the role of scientific analysis in UK local authority AQMA
decision-making: method development and preliminary results. Science of the
Total Environment. 311 (1-3) 1-18
Woodfield,
N.K., Longhurst, J.W.S., Beattie, C.I., & Laxen, D.P.H. (2003) Judging the
risk of exceedance: local authority decision-making for air quality management
area designation. Local Environment, 8 (4) 423 - 436.
Beattie,
C. I., J.W.S. Longhurst and Elsom, D.M. (2004) Evidence of integration of air
quality management in the decision making processes and procedures of English
local government. Local Environment. 9 (3) 255 - 270.
Chatterton,
T.J, Woodfield, N.K., Beattie, C.I. & Longhurst, J.W.S. (2004). Outcomes of
the first round of local authority air quality review and assessments under the
UK's air quality strategy. Journal of Environmental Monitoring, 6 849 - 853
Woodfield,
N.K., Longhurst, J.W.S., Beattie, C.I., Chatterton, T. and Laxen, D.P.H.
(2006). Regional collaborative urban air quality management: Case studies
across Great Britain. Environmental Modelling and Software. 595 -599
Dorfman,
P., Beattie, C.I., Burnet, F., Gibbs, D. C., Longhurst, J.W. S., Weitkamp, E.
& Leksmono, N.S (2006) A conceptual model of the role of complex science in
local authority consultations about air quality management. Local Environment
11 (4) 399 - 419.
Longhurst,
J.W.S., Beattie, C.I., Chatterton, T., Hayes, E.T., Leksmono, N.S., and
Woodfield, N.K. (2006) Local air quality management as a risk management
process: assessing, managing and remediating the risk of exceeding an air
quality objective in Great Britain. Environment International 32(8) 934-947.
Chatterton,
T.J., Longhurst, J.W.S., Leksmono, N.S., Hayes, E.T. & Symons, J.K.,
(2007). Ten years of Local Air Quality Management experience in the UK: An
analysis of the process. Clean Air and Environmental Quality, 41(4): 26-31.
Longhurst,
J.W.S., Irwin, J.G., Chatterton, T.J, Hayes, E.T. Leksmono, N.S., & Symons,
J.K., (2009). The development of effects based air quality management regime.
Invited contribution to 50th Anniversary Special Issue. Atmospheric Environment
43 (1) 64-78.
Dorfman,
P., Gibbs, D.C., Leksmono, N.S., Longhurst, J. W. S., Weitkamp, E.L.C. (2010)
Exploring the context of consultation. The case of Local Air Quality
Management. Local Environment 15:1 15 - 26.
Leksmono,
N.S., Dorfman, P., Burnet, F., Gibbs, D.C., Longhurst, J. W. S., Weitkamp, E.
(2010) Enhancing consultation practices on Air Quality Management in local
authorities. Journal of Environmental Planning and Management 53 (5) pp 559 -
571
Olowoporoku,
A. O., Hayes, E. T., Leksmono, N. S., Longhurst, J. W. S. & Parkhurst, G.
(2010) A longitudinal study of the links between Local Air Quality Management
and Local Transport Planning policy processes in England. Journal of
Environmental Planning and Management 53 (3), 385 - 403.
Ross-Jones,
M.J & Longhurst, J.W.S. (2010) Managing Air Quality at the Local level. A
Case Study. The International Journal of Sustainable Development & Planning
5 (3) 223-237
Longhurst,
J.W.S., Olowoporoku, A. O., Barnes, J., Chatterton, T.J., Hayes, E.T. and
Irwin, J.G. Exploring issues of process efficiency and outcome effectiveness in
the United Kingdom’s Local Air Quality Management Regime.(2011) The
International Journal of Sustainable Development & Planning 6 (3) 286 -298
Olowoporoku,
A. O., Hayes, E. T., Longhurst, J. W. S. & Parkhurst, G. ( 2011) Improving
road transport-related air quality in England through joint working between
Environmental Health Officers and Transport Planners. Local Environment 16 (3)
603-618
Olowoporoku,
A. O., Longhurst, J. W. S., Hayes, E. T., & Parkhurst, G. ( 2012) The
rhetoric and realities of integrating air quality into the local transport
planning process in English local authorities Journal of Environmental
Management 101 pp. 23 -32.
Everard,
M., Pontin, B., Appleby, T., Staddon, C., Hayes, E.T., Barnes, J.H. &
Longhurst, J.W.S. (2013, forthcoming) Air as a common good. Environmental
Science & Policy DOI 10.1016/j.envsci.2012.04.008 Online November 2012.
Barnes,
J., Hayes, E.T., Longhurst J.W.S., Chatterton, T.J (2013) Air quality action
planning: why do barriers to remediation in local air quality management
remain? Journal of Environmental Planning and Management DOI:
10.1080/09640568.2012.762573 Online 3rd April 2013 pp. 1-22. ISSN 0964-0568
