Memorandum submitted by Leicester City
Council (AQ08)
(I) THE
EVIDENCE
The key air quality issue in Leicester is nitrogen
dioxide from traffic in the City centre and in other areas where
there is exposure in proximity to the major road network. Leicester's
single Air Quality Management Area reflects this, comprising the
whole City centre and `ribbons' along the major radial and peripheral
road corridors.
In our experience, government `top-down' predictions
over the last decade of a fall in traffic-generated nitrogen dioxide
have been over-optimistic and continue to be so. Given considerable
year-on-year fluctuations due to gross meteorology and other extraneous
factors, no robust downward trend is detectable in our monitored
data. Indeed, Leicester City Council has had to extend its Air
Quality Management Area in 2008 so, at least locally, the situation
is deteriorating.
It is very difficult to attribute any change
to a given intervention since the impacts of individual measures
are currently so small as to be undetectable within the limits
of methodological error and background `noise'. Any slight trend
is almost certainly largely attributable to improvements in vehicle
technology rather than the impact of any local interventions.
Leicester City Council is probably more fortunate
than most in the resources currently allocated to air quality
monitoring and modelling. We have an extensive automatic monitoring
network and access to a computer dispersion model. However, it
seems to us that the picture of air quality across the UK since
the introduction of the LAQM regime in 1995 has been somewhat
patchy due to differences in approach and priorities. This can
only vitiate a proper appreciation of the importance of air quality
in some areas.
While there are some impressive consortium arrangements
in large conurbations there is no consistency: There should be
minimum standards for automatic monitoring, possibly on a `monitoring
stations per capita' basis. Web-based dispersion models should
allow consortium-based sharing, allowing wider access and methodologically
more consistent modelling. Government and local provision should
be formally integrated, in order to make national provision more
homogeneous.
There is scope for specialist functions of this
type (eg maintenance of monitoring networks, data management,
provision of dispersion modelling) to be shared across groups
of local authorities on a county or region basis, reducing costs
to individual local authorities, in particular those with very
limited resources to devote to this function.
(II) LAQM PROCESSES
Coupled with very slight or nonexistent downward
trend, observed annual means for nitrogen dioxide fluctuate significantly
year-on-year at a given site. Even over a decade, trends are difficult
to discern from `noise'. If this is coupled with the very real
constraints on local authorities to exert any significant control
over local air quality over time scales of this order, the requirement
to produce annual Progress can be regarded as excessive. The same
is possibly true of three-yearly Assessments, unless very significant
infrastructure change takes place.
The current concept of the AQMA is an arbitrary
and artificial construct. There is also significant latitude allowed
in the methodology of establishing boundaries. While problems
may manifest themselves at `hotspots', for example at major road
junction, the causes (and therefore the remedies) tend to be network-wide.
Precise boundaries are therefore of little significance, which
throws into question the value of the process of arriving at them
and of periodically adjusting them. Perhaps the procedural stage
of declaring an AQMA should be eliminated and the process move
directly from Review and Assessment to Action Planning, where
this is warranted. Any specific geographical requirements will
be identified in the former and can be addressed in the latter.
(III) THE
INTERRELATIONSHIP WITH
OTHER POLICY
AREAS
Transport Planning
Leicester City Council is producing a Detailed
Review and Assessment of Air Quality to be reported by April 2010.
The following year, we will need to model the impacts of the preferred
package of measures developed for the next round of transport
planning. Not only is this needless duplication, the Review and
Assessment exercise will also not have the benefit of detailed
understanding of the content of the forthcoming LTP, which will
not have crystallised until the following year. This is clearly
pointless and a waste of resources.
In cases where traffic is the dominant source
of pollution, and transport interventions are the principal remedy,
it is desirable to align the time-scale for Review and Assessment
with that for Local Transport Planning. In the light of the previous
comments about processes (section ii), an integrated, five-yearly
cycle would be appropriate.
There is also needless duplication in the respective
DEFRA and DfT annual reporting regimes, which require rationalising.
The last Transport Planning framework required
air quality targets to be set. In practice, these fell short of
meeting the Objectives and were merely projections of the air
quality impact of implementing the constrained package of measures
which the local authority could develop under current conditions.
This raises an interesting philosophical issue: Should policies
drive targets or targets drive policies?
There is no formal duty on local authorities
to deliver the air quality Objectives, which is not unreasonable
since this is to a large extent beyond their medium-term control.
However, where there are exceedances, there is a formal duty to
draw up time-based Action Plans. This creates a mismatch in time
horizons, where Action Plans are integrated with Local Transport
Plans. The latter are specific, short term bids for funding allocation
which lead to the implementation of concrete projects `on the
ground'. The former are only likely to be realised through radical
measures over the long term. It follows that Local Transport Planning
Guidance should make explicit provision for a longer-term `look
ahead' beyond the immediate package bid, perhaps more speculative
but nonetheless evidence-based: the last section of `LTP-3' should
be a glimpse of `LTP-4'.
Climate Change Strategy
There is a tendency in some quarters to regard
climate change as so pressing that it should be `the only game
in town'. While climate change is undoubtedly to most the biggest
issue in the long term, this approach of `moral panic' is neither
necessary or desirable. As many have observed, the danger is that
air quality will be marginalised. This risk is compounded by the
current separation of air quality and climate change functions
in the government departmental structure.
We consider that the developing Low Emission
Strategies approach is the way forward and should be rolled out
nationally: This means policy integration between Air Quality
and climate strategy, through LAQM, transport planning and land-use
planning (LDF/SPD's). The aim should be to identify `win-win'
solutions. Evaluation of options should be rigorously evidence-
based through access to modelling resources.
This approach ensures that interventions are
cost-effective and therefore make the best use of resources, avoiding
waste through duplication, overlaps and policy conflicts. The
latter are a real danger, for example the use of automotive diesel
engines, particularly those using some biofuels, and the combustion
of woody biomass in fixed installations. Potential policy conflicts
like this need to be explicitly identified and addressed at national
level.
The `Low Emissions Strategies' approach is also
more conducive to public understanding, and perhaps therefore
acceptance, lack of which is a serious barrier to progress at
present. Such an approach gives environmental policy a force,
direction and coherence which it otherwise lacks.
National Performance Indicators for air quality
do not refer to local authority areas as a whole. The rationale
for this is that there is an existing statutory framework of air
quality Objectives, which makes this unnecessary. However, our
experience is that the latter tends to be overlooked in corporate
performance reporting, leading to air quality being separated
from climate change emissions and marginalised. In addition, the
performance indicators for local authority `estates and operations'
are expressed in terms of mass emissions which are difficult to
relate to the concentration-based Objectives. Air quality needs
to be explicitly linked with climate change in the framework of
local performance indicators and Local Area Agreements.
(IV) ALIGNING
POWERS AND
RESPONSIBILITIES
There should be a formal national framework
of local authority powers and obligations, linked to a nationally
recognised package of interventions. Progress between comparable
authorities should be benchmarked:
The reality is that current Local Authority powers
are inadequate to make a real difference to air quality in the
medium-term. The legal, fiscal and political conditions are simply
not in place. This is compounded by lack of political will in
some areas. To put this in perspective, where nitrogen dioxide
from traffic is the key issue, a reduction of the order of ten
percent in current traffic flows would be required to make any
difference at all to annual mean values; At locations where annual
means are considerably in excess of the Objective criterion we
calculate that reductions in traffic volumes of considerably more
than fifty percent would be required.
An honest and realistic appreciation is needed
of the huge level of intervention needed to meet the air quality
Objectives: This implies rigorous evaluation of policy options
at national and local level. The tendency of government to devolve
technically challenging and politically unpopular decisions to
local authorities, under the pretext elevating local choice to
a political principle, is merely a cloak for inaction. There has
been little government-led debate on potential, radical interventions
and therefore little public understanding or acceptance. The reality
is that radical, unilateral action equates to economic and political
suicide for local administrations. This is perfectly illustrated
by the grim political fate of recent proposals to introduce road
charging in Manchester and Derby. Until a lead is set by government
in identifying, promoting and implementing specific interventions
at national level, there will be little progress.
There is a widespread perception by the public
that environmental interventions like road charging are merely
a `wheeze' by government and local authorities to raise extra
revenue. This perception is aggravated by sections of the media,
and the whole enterprise is bedevilled by polarisation between
environmental enthusiasts on the one hand and other powerful interest
groups on the other. Interventions of this type must be explicitly
fiscally neutral or, indeed, confer an identifiable economic benefit
to some sections of the community; ie they must be offset by reductions
in taxation elsewhere before they become politically acceptable.
It follows that there needs to be a radical shake-up of the whole
fiscal framework to support a uniform approach across the UK.
10 December 2009
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