AQMRC is recruiting an RA/RF

The Air Quality Management Resource Centre @ UWE is now recruiting!! An exciting opportunity for a Research Fellow or Research Associate to join a busy team working on air quality, carbon management and wider environmental issues at a local, national and international level. Further details here - http://tinyurl.com/aqm-job. The closing date is 8 Sep 2013.

Local Air Quality Management consultation - UWE response

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. PM_2.5. 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 PM_2.5 pollution? Please provide examples, where appropriate.

Typically, any local authority measure that is targeting PM₁₀ or NO₂ from traffic will also be relevant to PM_2.5.  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 PM_2.5, 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:

Guide for Cities http://euronet.uwe.ac.uk/www.integaire.org/project/Guide%20for%20Cities.pdf

Database of examples: http://euronet.uwe.ac.uk/www.integaire.org/database-new/gpdb.php?m=0

General contents page: http://euronet.uwe.ac.uk/www.integaire.org/Project.html

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