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 (e.g. 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; i.e. 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