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Development andImplementation of StrategicFrameworks for Air QualityManagement in the UK andthe European CommunityDerek M. ElsomPublished online: 02 Aug 2010.
To cite this article: Derek M. Elsom (1999) Development and Implementation ofStrategic Frameworks for Air Quality Management in the UK and the EuropeanCommunity, Journal of Environmental Planning and Management, 42:1, 103-121,DOI: 10.1080/09640569911325
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Journal of Environmental Planning and Management, 42(1), 103 ± 121, 1999
Deve lopment and Imple mentation of Strategic
Frameworks for Air Quality M anage me nt in the U K
and the Europe an Community
DEREK M. ELSOM
Departm ent of Geography, Oxford Brookes U niversity , Oxford OX3 0BP, UK
(Received July 1998; revised September 1998)
ABSTRACT The U K and the EC have recognized that the application of national and EC
policies alone m ay not be cost effective in improving air quality in some areas, especially
in traf ® c-congested urban centres and along m ajor road transport corridors. Conse-
quently both have introduced new strategic frameworks for air quality management.This
paper outlines and com pares the U K N ational Air Q uality Strategy (NAQ S) and the EC
approach, set out in the A ir Q uality Framework and D aughter D irectives. Both
frameworks shift responsibility for reviewing, assessing and m anaging air quality on to
local authorities. The U K considers the N AQS will provide the principal means of
carrying out its comm itments under the new EC framework.Local authorities in the U K
have begun the rev iew and assessment phase of the NA QS. This paper exam ines the
support that central government has had to provide to local authorities to ensure the
N AQ S will be effective. It offers insights into what other Member States are likely to face
w hen implementing their interpretation of the EC air quality m anagement framework.
The paper highlights that m any U K local authorities lacked even basic air quality
m anagement capabilities when the NAQ S was being formulated. Consequently the U K
G overnment has had to expand the national pollution monitoring networks (this was
achieved primarily by af® liating the growing number of local authority funded sites),
comm ission new detailed urban emissions inventories, and develop and validate a suite
of air quality dispersion m odels. Training events in air quality assessment techniques
have had to be offered and m any detailed guidance notes issued to ensure an appropriate
and consistent interpretation of the NAQ S. Some government initiatives to support the
implementation of the N AQ S suffered delays which initially caused some unnecessary
uncertainties and inconsistencies am ongst local authorities conducting their review and
assessment of air quality. This points to the importance of the Government ensuring that
the support for the m anagement phase of the N AQ S will be in place in time. This
includes providing add itional pollution-control powers and reformulating transport and
planning policies in order to integrate air quality m anagement more fully.
Introduction: Traf ® c Emissions and A ir Quality
Air pollution problems may occur in all the 2000 cities in Europe with more than
50 000 inhabitants (Stanners & Bourdeau, 1995). Growth in the number and use
of motor vehicles , especially cars, is the principal cause of European cities
0964-0568/99/010103-19 Ó 1999 University of Newcastle upon Tyne
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104 D . M. Elsom
experiencing poor air quality in their city centres and inner areas as well as
along arterial transport routes. Detailed inventories compiled for UK urban areas
indicate that road transport accounts for a very high percentage of annual
emissions of benzene, 1,3-butadiene and carbon monoxide (CO) and a signi® cant
percentage of nitrogen oxides, non-methane volatile organic compounds
(NMVOC) and, in some areas, particulate matter less than 10 micrometres (PM 10)
(Table 1). Domestic heating emissions, except where coal or lignite is still
burned , now cause few pollution problems while emissions from industrial
plants (e.g. manufacturing , power, re ® ning) and commercial premises (e.g.
vehicle spray painting, petrol stations) may be responsible for only relatively
localized problems.
Emissions from petrol and diesel engine vehicles have been the cause of some
serious urban pollution episodes in recent years. For example, high nitrogen
dioxide (NO2) levels (1-hour peak of 423 ppb (809 m g/m3)) during the cold foggy
period of 12± 15 December 1991 in London brought a signi® cant rise in the
numbers of deaths (estimated excess deaths ranged from 101 to 178) and
reported illnesses amongst all age groups (Anderson et al., 1995). Other UK
episodes include: 22± 23 December 1992 in Manchester (1-hour peak NO2 of 369
ppb (706 m g/m3)), 22 December 1994 in London (1-hour peak NO2 of 288 ppb
(551 m g/m3)); and 30± 31 October 1997 in London (1-hour peaks NO2 exceeding
200 ppb (382 m g/m3) in the boroughs of Camden, Wandsworth and Southwark)
(Elsom, 1996; South East Institute for Public Health, 1998). Pollution alerts,
issued when 1-hour NO2 levels exceed 209 ppb (400 m g/m3), have taken place in
Paris on 10 October 1995, 8 November 1995 and 30 September 1997, the latter
resulting in banning half the traf® c during the following day, 1 October
(Mercier, 1998). Vehicle emissions have been major contributors to serious
regional photochemical episodes too, such as during the summer of 1995 when
more than 70 cities in western Europe experienced 1-hour ozone (O3) levels
exceeding 180 ppb (360 m g/m3), the threshold at which the European Com-
munity (EC) Directive 92/72/EEC requires a public health warning to be issued
(Elsom, 1996).
For several years there has been widespread concern that traf® c growth will
progressively erode, and eventually outweigh, the air quality bene® ts arising
from the implementation of national legislation and EC Directives aimed at
curbing emissions per vehicle, such as the requirement since 1993 that new
petrol engine cars be ® tted with catalytic converters (Royal Commission on
Environmental Pollution, 1994). In the UK, for example, the number of vehicles
has increased by over 80% since 1970 and the distance travelled each year
increased by 100% (Department of the Environment (DoE), 1995). Traf® c projec-
tions for Europe indicate a near doubling of road transport for both passengers
and freight between 1990 and 2010 (Stanners & Bourdeau, 1995).
Development of Local Air Quality Management in the U K
In 1995 the DoE concluded that, ª national [and EC] policies do not ¼ impact
uniformly in all areasº and ª it is like ly there will remain signi® cant `hotspots’ ,
particularly in [traf® c] congested urban centres, where air quality standards are
unlike ly to be achieved cost effectively by the application of national air quality
policies aloneº (DoE, 1995). As a result, the Government proposed that a local
authority should be given the primary task of managing local air quality, in
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Strategic Framew orks for Air Q uality Management 105
Ta
ble
1.
An
nu
al
po
llu
tan
te
mis
sio
ns
att
rib
uta
ble
toro
ad
tra
f®c
(%)
Urb
an
are
a
So
uth
am
pto
n/
Sw
an
sea/
West
Po
llu
tan
tB
risto
lL
on
do
nM
an
ch
este
rM
ers
ey
sid
eP
ort
smo
uth
Po
rtT
alb
ot
Mid
lan
ds
Be
nze
ne
89
86
93
92
94
80
99
1,3
Bu
tad
ien
e9
79
796
78
92
92
96
Carb
on
mo
no
xid
e9
79
795
91
93
83
98
Carb
on
dio
xid
e2
63
021
18
24
17
43
Nit
rog
en
ox
ides
61
76
63
42
47
28
85
NM
VO
Ca
60
62
20
28
46
38
46
PM
10
36
79
31
82
413
56
Su
lph
ur
dio
xid
e5
22
31
21
16
a Refe
rsto
no
n-m
eth
an
ev
ola
tile
org
an
icco
mp
ou
nd
sin
clu
din
gh
yd
roca
rbo
ns
ari
sin
gfr
om
ev
ap
ora
tio
no
rin
co
mp
lete
com
bu
sti
on
of
pe
tro
lfr
om
ve
hic
les
an
dev
ap
ora
tio
nfr
om
so
lve
nts
use
din
pa
ints
an
dp
rin
tin
gin
ks.
Sou
rce:
Lo
nd
on
Re
searc
hC
en
tre
/R
SK
En
vir
on
men
tL
tdo
nb
eh
alf
of
DE
TR
.
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106 D . M. Elsom
liaison with neighbouring local authorities, the environment agencies and
government departments. This partnership between central government and
local authorities was formalized by the addition of a late amendment, Part IV
(Air Quality), to the Environment Act 1995 (HM Government, 1995). Section 80
of this Act obliges the Secretary of State to prepare and publish a National Air
Quality Strategy (NAQS) ª as soon as possibleº . Disagreements amongst govern-
ment departments over the ® ner details and ® nancial implications of the strategy
caused delays (Environmental Data Services (ENDS), 1996) such that the NAQS
was not published until March 1997 (DoE, 1997). A change of government in
May 1997 added further delays such that the Air Quality Regulations requiring
local authorities to begin implementing the NAQS did not enter force until
December 1997 (HM Government, 1998).
From December 1997, for the ® rst time, local authorities were given a statutory
obligation to identify areas within their boundaries where national policies and
instruments alone appear unlikely to deliver air quality objectives by 2005
(Figure 1). These areas, where the health of the urban population is at risk , are
to be declared Air Quality Management Areas (AQMA). Local authorities must
then formulate an air quality improvement and management plan (Action Plan),
in consultation with the county and neighbouring local authorities, setting out
what transport, land use planning and other measures are needed to ensure that
the air quality objectives in these areas will be met by 2005. A limited range of
powers and resources for local authorities have been introduced, or proposed,
by central government for this purpose. The NAQS applies to all unitary
councils in Scotland and Wales and to district and unitary councils in England.
The Environment Act 1995 and the NAQS have not yet been legislated in
Northern Ireland despite some urban areas, in particular Belfast, being prone to
some of the worst air pollution conditions in the UK.
EC Framework and Daughter Directives on A ir Quality A ssessment and
M anagement
During the early 1990s the EC recognized that its air quality standards (Direc-
tives 80/779/EEC amended by 89/427/EEC on sulphur dioxide (SO2) and
suspended particulate matter, 82/884/EEC on lead, 85/203/EEC on NO2 and
92/72/EEC on O 3) were in need of review and likely revision in the light of new
scienti® c data in the ® eld of air pollution toxicology and epidemiology. The
timing of the review was also in¯ uenced by the decision by the World Health
Organisation (WHO) in 1993 to review and/or revise its air quality guideline
values for Europe issued in 1987. The EC decided that, rather than simply to
update its air quality standards (limit and guide values) and tighten pollution
control measures embedded in various directives (e.g. those concerned with
emission limits for vehicles and industrial processes , and product standards for
fuels), a new approach to pollution control in urban areas was needed. This
would take the form of a Community-wide approach to assessing and managing
air quality which would remove the differences that currently existed between
Member States in terms of air quality monitoring strategies, measurement
techniques and assessment practices as well as the degree of commitment
towards improving air quality. It would harmonize and standardize. The result
was the formulation of the European Community’ s Framework Directive on
Ambient Air Quality Assessment and Management (96/62/EC), commonly
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Strategic Framew orks for Air Q uality Management 107
Figure 1. The UK National Air Quality Strategy.
referred to as the Air Quality Framework Directive, formally proposed in July
1994 and ® nally agreed in September 1996 (Council of the European Union,
1996).
The Air Quality Framew ork Directive requires that each Member State divides
the country into agglomerations (de ® ned as areas with a population exceeding
250 000 inhabitants or less populated areas characterized by high population
density, such as more than 1000 inhabitants/km2) and other zones. In the UK
this could be interpreted as individual or groups of local authorities. Member
States must designate the national, regional or local authorities who are respon-
sible for the implementation of the Directive. After making a preliminary
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108 D . M. Elsom
assessment of air quality the authorities have to decide which pollutants pose a
problem or a potential problem and so need to be measured and how best, in the
local circumstances, to do this. The next stage, from the year 2000, is to assess
ambient air quality in relation to limit values and/or alert thresholds using
common methods and criteria . The Directive de ® nes what adequate air quality
information is needed by specifying the monitoring strategies (location and
minimum number of sampling points), measuring methods and quality assur-
ance procedures. The criteria for the use and required accuracy of modelling and
estimation techniques in assessing air quality are speci® ed too. If initial surveys
show levels are below 75% of limit values, a combination of measurement and
modelling may be used for assessment. Below 50%, modelling and estimation
may be used. Having assessed air quality in agglomerations and zones, the
authorities must submit an air quality improvement (action) plan and/or status
report to the Commission. Three situations are recognized (Figure 2):
(1) Area of poor air quality. If pollution levels are above the margin of tolerance
(a permitted percentage of exceedance of the limit value which decreases
with time) an air quality action plan must be developed within two years to
improve air quality and to ensure the limit value is reached by the target
data (2005 or 2010, depending upon the pollutant).
(2) Area of improving air quality. If pollution levels do not exceed the margin of
tolerance but are above the limit value then authorities must devise an
Action Plan outlining the policies and measures that will reduce emissions
progressive ly to ensure the limit value is attained by the target date. An
annual report must be submitted to the Commission.
(3) Area of good air quality . If pollution levels are below the limit value then there
is an obligation to maintain good air quality and report to the Commission
every three years.
There is a set format for the annual reports submitted to the Commission . They
should include details of the air quality situation, emission sources and those
measures or projects adopted with a view to reducing pollution, including the
timetable for implementation. The Commission will regularly check the im-
plementation of the plans and their impact on air quality trends. A list of poor
air quality areas will be published each year and a report published every three
years on the ambient air quality throughout the Community. The Commission
will review the Air Quality Framework Directive and Daughter Directives in
2003.
The Directive attaches considerable importance to ensuring the public have
easy access to clear, up-to-date information (hourly for SO2, N O2 and PM 10 and
every three months for lead). Routine information must show when limit values
are exceeded and active steps must be taken to inform the public if an alert
threshold is exceeded. The authorities have to develop short term action plans
to enable measures to be taken where there is a risk of a limit value and/or alert
threshold being exceeded. The measures should aim to reduce that risk and to
limit the duration of a pollution episode. Such measures include controlling and,
where necessary, suspending activities, including motor vehicle traf® c.
The Air Quality Framework Directive is to be supported by a series of
Daughter Directives, the ® rst being concerned with SO2, particulate matter, NO2
and lead. Agreement on the common position was reached by the Council of
Ministers in June 1998 with ® nal adoption later in the year. It enters force two
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Strategic Framew orks for Air Q uality Management 109
Figure 2. Three air quality situations in agglomerations and zones as de ® ned by
the limit value and the margin of tolerance.
years after adoption, that is, 2000. Further Daughter Directives are being
developed for other pollutants which specify the limit values, alert thresholds,
margins of tolerance, target dates for the attainment of the limit values, pollution
measuring criteria and assessment techniques.
NA QS A ir Quality Objectives and the EC Limit V alues
The National Air Quality Strategy speci® es eight health-based air quality stan-
dards together with the air quality objectives which must be met by 2005 (Table
2). The standards are based on research reviews undertaken by the independent
Expert Panel on Air Quality Standards (e.g. Expert Panel on Air Quality
Standards (EPAQS), 1996). Air quality standards are not given statutory backing
and there is no timescale of attainment attached to them. Instead, the Govern-
ment considers the standards as reference points to be used for setting air
quality objectives. These objectives ª represent the government’s present judge-
ment of achievable air quality by the year 2005 on the evidence of costs and
bene® ts and technical feasibilityº (DoE, 1995). For some pollutants, the objective
is identical to the standard but for three pollutants, O3, PM 10 and SO2, percentile
values are de ® ned which allow for some occasions to exceed the standards.
The EC Daughter Directives specifying limit values are being introduced in
three stages. The Directive specifying the SO2, NO2, PM 10 (or PM 2.5) and lead
limit values was agreed in 1998 (Edwards, 1998) (Table 3). This will be followed
by a Directive on O 3, benzene and carbon monoxide (CO) in 1999, and a
Directive on polycyclic aromatic hydrocarbons (PAH), cadmium, arsenic, nickel
and mercury by the end of 1999.
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110 D . M. Elsom
Table 2. The UK National Air Quality Strategy standards and objectives
Pollutant Standard Measuring period 2005 objective
Benzene 5 ppb Running annual mean 5 ppb
16 m g/m3
16 m g/m3
1,3 Butadiene 1 ppb Running annual mean 1 ppb
12 m g/m 12 m g/m3
Carbon monoxide 10 ppm Running 8-hour mean 10 ppm
12 mg/m3
12 mg/m3
Lead 0.5 m g/m3
Annual mean 0.5 m g/m3
Nitrogen dioxide 150 ppb 1-hour mean 150 ppba
287 m g/m3
287 m g/m3
21 ppb Annual mean 21 ppba
40 m g/m3
40 m g/m3
Ozone 50 ppb Running 8-hour mean 50 ppb, 97th percentilea
100 m g/m3
(no more than 33
exceedances per year)
PM 10 50 m g/m3
Running 24-hour mean 50 m g/m3, 99th percentile
a
(no more than 4
exceedances per year)
Sulphur dioxide 100 ppb 15-minute mean 100 ppb, 99.9th percentilea
266 m g/m3
(no more than 35
exceedances per year)
aObjectives are regarded as provisional and may be revised before the target date.
The EC annual N O 2 limit value for 2005 is 21 ppb (40 m g/m3), the same as
the U K objective. The 1-hour limit value for the target date of 2010 is set at 105
ppb (200 m g/m3) not be exceeded more than 18 times per year. A consultative
draft of the NA QS in August 1996 proposed to adopt the same 1-hour value
as its objective but measured as the 99.9th percentile , allow ing for eight
exceedances per year. H owever, in December 1996, EPAQS (1996) proposed a
relaxation of the health -based standard on the basis that the 105 ppb (200
m g/m3) value had been selected originally on the results of a 1976 study that
claimed to have found health effects from N O 2 at concentrations as low as 100
ppb (191 m g/m3) yet these results have never been replicated since. Conse-
quently, the N A QS adopted a 1-hour objective of 150 ppb (287 m g/m3). Given
the 18 occasions that the EC 1-hour lim it value is allowed to be exceeded by
the 2010 EC target it would seem that the EC value is similar to the N AQS
objective.
Whereas the WHO did not set a health-based guideline value for ® ne partic-
ulates because it considered there is no safe threshold, both the EC and the
NAQS have introduced PM 10 standards. There are two stages to the EC limit
values whereby the number of exceedances of 50 m g/m3
per year must reduce
from 35 times in 2005 to only seven times by 2010. The latter exceedances will
avoid having to impose restrictions on national festivities in which emissions
from bon ® res and ® reworks can cause high pollution levels (e.g. Guy Fawkes
night on 5 November in the UK, Bastille day on 14 July in France). However, the
second stage is considered `indicative’ and will be reviewed before then.
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Strategic Framew orks for Air Q uality Management 111
Table 3. EC air quality limits
Target Measuring
Pollutant date period Limit value
Lead 2005 Annual 0.5 m g/m3
Nitrogen 2010 Hourly 105 ppb (200 m g/m3) no more than 18
dioxide exceedances per year
Annual 21 ppb (40 m g/m3)
PM 10 Stage 1 Daily 50 m g/m3
no more than 35 exceedances
2005 per year
Annual 40 m g/m3
Stage 2 Daily 50 m g/m3
no more than 7 exceedances
2010 per year
Annual 20 m g/m3
PM 2.5 Action Daily 40 m g/m3
no more than 14 exceedances
level per year
2005
Sulphur 2005 Hourly 132 ppb (350 m g/m3) no more than 24
dioxide exceedances per year
Daily 47 ppb (125 m g/m3) no more than 3
exceedances per year
A fundamental difference between the EC and the NAQS standards for PM 10
is that the EC reference measurement technique is the high volume gravimetric
sampler whereas measurements throughout the UK are mostly undertaken
using the Tapered Element Oscillating Microbalance (TEOM). Recent research
suggests that the TEOM underestimates particle mass by around 20% in com-
parison with the gravimetric technique because it preheats the airstream prior to
® ltration which results in evaporation of water and semi-volatile components
(Airborne Particles Expert Group, 1998). This is a signi® cant difference and may
require results from TEOM measurements to be adjusted accordingly. The EC
offers a derogation of the limit value for arid regions within the Community
where there are high levels of natural dust. Most natural particles are larger than
2.5 micrometres in diameter. A 24-hour action level for the protection of human
health has been set at 40 m g/m3
of PM 2.5 for 2005, not be exceeded more than 14
times per year. The derogation will be reviewed before applying a second stage.
It is hoped by then that there will be much more data on PM 2.5 to help make
public policy choices. Member States are urged to reduce PM 2.5 concentrations
when meeting limit values for PM 10. One problem facing the authorities in
reducing levels of PM 10 is that on some occasions the source of this pollutant is
a long distance away and outside the ability of a local authority or even a
regional authority to control.
The SO2 limit value of 132 ppb (350 m g/m3) measured over 1 hour is designed
to be equivalent to the WHO 188 ppb (500 m g/m3) guideline value measured
over 10 minutes. Given that it allows for this value to be exceeded 24 times per
year (the European Parliament’ s proposal for exceedances to be permitted for
only eight times per year was rejected by the Commission) , it is sligh tly less
stringent than the NAQS objective. Occasions of exceedances are often due to the
short term grounding of plumes from coal-® red power stations.
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112 D . M. Elsom
Limit values for other pollutants will follow. In the case of O 3, the limit value
may be replaced or complemented by a target value. This provision arises
because O3 is more dif® cult to manage than other pollutants because this
secondary pollutant is formed by photochemical reactions on precursor pollu-
tants that are emitted at a European-wide scale. Similarly, although the NAQS
speci® es an air quality objective for O 3, this is regarded as a `desirable objective ’
rather than one which must be met by statutory duty by 2005. It argues that the
responsibility for achieving the O3 objective must lie at the national and
international levels. In other words, if exceedances of the objective occur, a local
authority would not have to declare an Air Quality Management Area for this
pollutant.
The EC Daughter Directives include alert thresholds which represent the level
of a particular pollutant above which there is a health risk from brief (acute)
exposure. If the alert threshold is exceeded, the authorities will be required to
inform the public immediately and to take action to reduce pollution levels. The
alert threshold for SO2 is 188 ppb (500 m g/m3) measured over three hours and
for NO2 it is 209 ppb (400 m g/m3) measured over three hours (this threshold was
adopted as a result of an amendment proposed by European Parliament).
Parliament recommended an alert threshold for PM 10 but the Commission
rejected this proposal by arguing there is no `safe’ limit for this pollutant and so
there is no identi® able level above which the public ought to be informed. The
UK does employ information thresholds and alert thresholds for PM 10, SO2, O3,
CO and NO2 but these are not given statutory backing as part of the NAQS.
Lessons Learned During the Implementation of the NA QS
The UK NAQS and EC Air Quality Framework were being formulated and
developed at around the same time. Given the strong in¯ uence of UK represen-
tatives in the working groups negotiating the details of the Framework and ® rst
Daughter Directive and the high pro® le given by the British Presidency of the
Union from January to June 1998 to air quality, convergence of the two strategies
is evident. Indeed, the UK Government envisages that, ª the structures estab-
lished under the Environment Act 1995 and the NAQS will provide the principal
means of carrying out the UK’s commitments under this [Air Quality Frame-
work] Directiveº (DoE, 1997). Some differences still exist between the two
strategies such as the disparity between the EC limit values and UK objectives
(both in terms of levels and permitted exceedances), the greater attention given
by the EC to short term pollution episodes and the need for authorities to
develop action plans to deal with such occasions, and the reporting require-
ments for areas experiencing poor or improving air quality. Nevertheless, given
that the UK has required local authorities to begin the process of reviewing local
air quality and assessing whether air quality objectives will be met by the 2005
target date, then it is instructive for EC Member States to consider the lessons
being learned in implementing the UK approach to local air quality manage-
ment.
Preparing Local Authorities for Review and A ssessment of A ir Quality
Even before the British Government ® rst proposed a new strategic framework
for air quality management in January 1995, some local authorities had begun to
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Strategic Framew orks for Air Q uality Management 113
develop air quality management capabilities. However the resources and exper-
tise to do this effectively were restricted to relatively few authorities in large
urban areas such as Birmingham, Greater London, Greater Manchester and
Shef ® eld. The majority of the 400 or so local authorities lacked equipment to
monitor the pollutants of growing concern, especially NO2, O3 and PM 10, let
alone had they undertaken local emissions inventories (other than in connection
with authorizing Part B processes as required by the system of Local Air
Pollution Control introduced by the Environment Act 1990) or employed nu-
merical dispersion models to assess likely changes to air quality in the future.
For example, a UK survey of 84 major urban areas (population exceeding 80 000
inhabitants) outside Greater London undertaken in November 1994 found only
16 urban areas in which automatic analysers were monitoring ® ve or more
pollutants, including CO, NO 2, PM 10 , O3 and SO2, and 46 areas with no
automatic analysers at all (Crabbe & Elsom, 1995; Elsom & Crabbe, 1995).
A key government response to the situation of limited air quality management
capability was to formulate the NAQS in such a way to avoid the need for every
local authority to develop a sophisticated air quality management system
composed of components such as a network of expensive automatic pollution
analysers. The problem of air pollution varies considerably between local
authorities. Indeed, the Government stressed that national source-based control
policies already in place would ensure that, by 2005, many local authorities were
unlike ly to experience an air quality problem. Consequently, the Government
considered that the complexity and detail of an air quality review and assess-
ment should be consistent with the risk of the air quality objectives not being
achieved by 2005. This resulted in the adoption of a three-stage approach to
review and assessment whereby a local authority would have to progress from
one stage to the next only if that stage indicated an air pollution problem was
present or was likely to develop before 2005 (Department of the Environment,
Transport and the Regions (DETR), 1997a, 1998a) (see Appendix).
The concept of a three-s tage review and assessment was ® rst tested and
re® ned by 80 local authorities in 14 local authority groupings in Great Britain,
plus Belfast in Northern Ireland, in 1996± 97 in a trial phase (Elsom & Longhurst,
1997). These First Phase Authorities were chosen from more than 130 applica-
tions to be representative of a range of population sizes and densities, geograph-
ical regions, types and complexity of pollution problems, and degrees of
experience of local air quality management. For example, they included the 33
authorities constituting Greater London which were well advanced in air quality
management capability and those which had given limited attention to the air
quality issue so far, such as Cornwall and the Ribble Valley. It was unhelpful
that delays in the implementation of this trial phase were experienced, with the
® nal report of the ® ndings not being published until late 1998. Although some
provisional ® ndings became available before then (National Society for Clean
Air & Environmental Protection (NSCA), 1998), and the Government used these
to re ® ne the review and assessment process, local authorities had to begin their
review and assessment without the bene® t of all the detailed insights that this
trial phase was intended to provide.
A second government response to the limited air quality management capabil-
ities available in many local authorities was to develop national resources which
local authorities could draw upon. Emphasis has been given to increasing the
amount and quality of pollution monitoring data and emissions’ inventories
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114 D . M. Elsom
across the country, especially in large urban areas, as well as to making available
a range of numerical dispersion models applicable to urban situations:
(1) Monitoring data. The Automatic Urban Network (AUN) of automatic
analysers has expanded from the initial government-funded 12 sites monitoring
CO, NO2, O3, PM 10 and SO2 in 1991 to over 100 sites by 1998. This has been
achieved by further government investment in new sites but primarily by
af® liating the growing number of automatic analysers funded and operated by
local authorities. Local authority sites become part of the AUN once their
instrumentation and site operation procedures have been approved (DoE, 1993,
1995). The Government provides the telemetry to link the sites with a central
data collection point at the National Environmental Technology Centre in
Oxfordshire, and a quality control service, but the cost of establishing and
operating these sites remains with the local authorities . AUN sites provide
pollution concentrations from a range of different types of urban sites (DETR,
1998b). Pollution data from all the AUN sites and other pollution monitoring
networks (e.g. the 1100-site NO2 diffusion tube survey) are available via the
National Air Quality Data Archive , an internet site established in April 1997.
These data may be considered to provide pollution levels indicative of what may
be experienced at similar sites in other urban areas. These data also provide the
means to test assumptions about the degree of spatial variation of speci® c
pollutants and to research surrogate indicators, especially for PM 10. The AUN
and other monitoring networks have enabled 1 km2
grid maps of background
concentrations of the key pollutants to be compiled for the current year and
projected for 2005.
(2) Information on em issions. The National Atmospheric Emissions Inventory,
with much of the information available on the internet, provides top-down
estimates of emissions of key pollutants disaggregated to a 1 km2
grid together
with 10 detailed and recent bottom-up inventories of major conurbations exceed-
ing 250 000 population (Buckingham et al., 1997; DETR, 1998c). Emission factors
for vehicles according to type and speed are also available from the national
database. Emission data from point sources are available through the require-
ments of the Environmental Protection Act 1990 which established two groups
of industrial plants and processes for regulation purposes. Major developments
such as power stations are known as Part A processes, and require authorization
by the environment agencies. A computerized database for these processes is
available (Chemicals Release Inventory) . Less polluting industrial plants and
processes constitute Part B processes and are regulated by local authorities.
Some problems have been experienced by local authorities in obtaining emis-
sions data from authorized processes outside their area and it is not always in
the most appropriate form to use in the review and assessment.
(3) Sim ple and com plex air quality dispersion m odels. In 1995, the use of numerical
models by local authorities was minimal. Many had employed the Department
of Transport’ s nomogram-based Design Manual for Roads and Bridges (DMRB)
model in air quality impact assessments of new roads but that was the limit of
their air quality modelling experience. Moreover, DMRB is designed for rela-
tively open country but the most serious air pollution problems are often
associated with canyon-like streets for which the DMRB was not designed (a
street canyon version of DMRB is to become available in late 1998). This
situation pointed to the need for a range of simple and complex models
applicable to urban situations and all key pollutants. Indeed models are essential
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Strategic Framew orks for Air Q uality Management 115
for conducting the second and third stage of the review and assessment of air
quality (Appendix). Work undertaken by the First Phase Authorities was partic-
ularly useful in assessing the applicability and limitations of several existing and
new models, including AEOLIUS (Assessing the Environment Of Locations In
Urban Streets), the American CALINE-4 (California Line Source Dispersion
Model, version 4), the Netherlands CAR-International (Calculation of Pollution
from Road Traf® c, international version) and ADMS-Urban (Atmospheric Dis-
persion Modelling System, Urban module) models. Guidance to local authorities
on using models has now been issued and some training in their use has been
offered (DETR, 1998d). However, some problems have yet to be resolved such
as limitations in the availability of input data and the algorithms employed such
that many model outputs contain considerable uncertainty.
A third government response to the lack of experience and expertise in local
air quality management was to emphasize that, even though it is the local
authority which has the statutory responsibility towards the NAQS, the need for
a partnership approach is essential. There should be involvement very early on
of all relevant local, county and regional groups. This includes of® cers from
Environmental Health, Planning, Highways, Economic Development and Local
Agenda 21 as well as representatives from the Health Authorities, Environment
Agency, local universities, business, industry and community groups. This
partnersh ip approach is important not only in the review and assessment stage
but in the formulation of an Action Plan should an AQMA be designated (DETR,
1997b). Consequently, many local authorities have established an Air Quality
Forum or similar working group so as to involve all those groups which have
a part to play in air quality management. However, some local authority of ® cers
expressed concern in early 1998 that collaboration within a local authority is a
greater obstacle to progressing the NAQS than the lack of co-operation between
local authorities. Although they were members of some sort of regional pollution
grouping, there was no group as yet set up within their own council to deal
speci® cally with air quality issues (Beattie et al., 1998).
Developing A ction Plans for A ir Quality M anage ment Areas (AQM A )
Clear guidance about de® ning the extent of an AQMA and the Action Plan have
yet to be offered. An AQMA could be a single small area in which one air
quality objective is unlikely to be met by 2005. It may be an amalgamation of
several small areas where one or more air quality objectives are likely to be
exceeded or it may encompass an entire local authority (as proposed provision-
ally by Westminster Council, London, in mid-1998). For many local authorities
the AQMA will cover the central traf® c-congested area and/or the 200 m
margins of the major road transport corridors. De ® ning the boundaries of an
area in which one or more air quality objectives are exceeded will be dif® cult for
the current situation let alone the likely situation in 2005. The Government’ s
view is that its boundaries should be de ® ned in broad terms rather than an
attempt be made to delineate precise ly a line of poor air quality since spatial and
temporal distribution of air quality makes it impracticable to do so (DETR,
1997a).
Irrespective of the area designated an AQMA, the strategies and measures
implemented to improve air quality within an AQMA will need to cover a much
wider area and are likely to affect several local authorities, even an entire
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116 D . M. Elsom
conurbation, county or region. The Action Plan has to outline the transport, land
use planning and other measures needed to remedy the poor air quality
situation by 2005. This plan is to be developed in consultation with government
departments, neighbouring authorities and other bodies as well as being subject
to public consultation. The Government has powers to modify or even reject the
plans.
The Environment Act 1995 did not itself set out the powers that local
authorities could employ in tackling air quality problems, but Section 87
provides a wide-ranging , regulation-making power which enables the Secretary
of State to introduce new powers as they are needed, including the prohibition
and restriction of certain activities or vehicles . The need for additional pollution-
control measures is acknowledged by the Government in their recognition of a
signi® cant `policy gap’ to be ® lled . For NO2 and PM 10, there is an estimated gap
of up to 10% between the emission reduction required to meet the objectives set
out in the NAQS and those likely to be achieved as a result of national measures
already agreed (DoE, 1997). This gap could be even greater if current policies
(e.g. requiring new cars to be ® tted with catalytic converters) are not as effective
as initially believed . Alternatively the gap may be reduced if new national
measures are implemented before 2005, perhaps as part of the Government’ s
current development of an Integrated Transport Strategy.
Some of the powers which local authorities may be allowed to implement in
order to bridge the national policy gap and achieve the air quality objectives by
2005 include:
(1) Vehicle targeted measure: random em issions testing . In February 1998 seven
local authorities began trials of random roadside emissions testing. Vehicles are
tested by trained local authority personnel after being stopped by a police
of® cer. The driver (not the owner) of a vehicle which exceeds national emission
standards is charged a ® xed penalty (£60 rising to £90 if not paid within 28 days)
and the vehicle must be tested again to show that its emissions are within
acceptable limits or be banned from the road. The schemes are intended to be
self- ® nancing. In Bristol, one of the trial areas, 10% of vehicles were found to
exceed legal emission standards and the drivers were ® ned (Muir, 1998).
Roadside emissions testing can be effective in elim inating the relatively few
excessively polluting vehicles which make a disproportionate emission contribu-
tion. These include older vehicles which are poorly or inadequately maintained,
vehicles whose owners have tampered with the catalytic converter or made them
ineffective by using leaded petrol, and even relatively new cars ® tted with a
catalytic converter that has malfunctioned for some reason (perhaps without the
driver realizing this). One gross polluter can produce as much as 40 times the
exhaust emissions of a new and well-maintained car (Elsom, 1996). Surveys in
four cities in the UK found that the highest emitting 10% of vehicles contributed
40± 59% of total vehicle emissions for CO and 52± 67% of total vehicle emissions
of hydrocarbons (HC). In contrast the cleanest 70% of the vehicles contributed
only 8± 23% of total CO emissions and 7± 21% of total HC emissions (Muncaster,
1994).
Some local authorities are pressing for powers to specify environmental
performance criteria for buses, taxis and public service ¯ eets. Enhanced emission
standards would be set for, say, buses which would require the use of very low
sulphur diesel and the retro ® tting of exhaust control equipment (e.g. particulate
traps).
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Strategic Framew orks for Air Q uality Management 117
(2) Transport and traf ® c m anagement measures. The Environment Act 1995
extended the Road Traf® c Regulations Act 1984 to allow local authorities to
make Traf ® c Regulation Orders prohibiting, restricting or regulating traf® c
along speci® ed roads in pursuit of air quality objectives (DETR, 1997c). How-
ever, the practicalities of implementing such restrictions as well as the concern
that this would simply shift the pollution problem to adjoining roads and local
authorities have meant this power has yet to be applied. Potentially more useful
is the concept of designating Low Emission Zones. Vehicles not conforming to
a speci® ed emissions standard (e.g. buses not operating with engines meeting
Euro II or III emission standards) or cars not ® tted with a catalytic converter
would be excluded from the zone. This type of scheme would be easier to
operate if a national identi® cation scheme for different emission classes of
vehicles was introduced. Alternatively, local authorities would need to introduce
some form of exemption permit which owners of certi® ed low-polluting vehicles
would have to display on the windscreen . Ultimately, the concept of an Urban
Clear Zone may be implemented in which only ultra-low emission or zero-emis-
sion vehicles (e.g. electric battery vehicles) may be permitted to enter (DETR,
1997c).
Experimental urban road pricing schemes are expected to be implemented in
late 1998 in Leicester and Bristol, where small pilot schemes have already been
operating. Charging motorists to enter the city, perhaps with the charges
re¯ ecting the state of air quality at the time, is intended to discourage them from
doing so, provided adequate alternative transport is available such as park and
ride services.
(3) Planning policies. Guidance issued by government encourages local author-
ities to use existing transport and land use planning powers in ways that will
achieve greater air quality improvement than previously achieved (DETR,
1997d). The land use planning system can be used to improve local air quality
in the long term by controlling the location of new homes, shopping centres ,
workplaces and leisure facilities such that dependency on the use of cars is
reduced and more people choose to use public transport, cycle or walk. How-
ever, most local authority Action Plans for an AQMA will not be in place until
2000. This allows strategic changes effected by planning policies only ® ve years
(target date 2005) in which to result in the attainment of air quality objectives.
This short time scale will put pressure on local authorities to select policies that
can deliver healthy air quality in ® ve years rather than alternative policies which
may be more cost-effective and sustainable in the long term but would take
more than ® ve years to deliver the necessary air quality improvement.
The Government urges greater integration of national air quality objectives
when preparing Development Plans (DoE, 1994; DETR, 1997d). However, prog-
ress is likely to be slow. Generally the NAQS is seeking to integrate what were
previously largely separate policy processes in the ® elds of air pollution control,
land use and transport planning, and economic development. The success of air
quality management will depend to a great extent upon how the process is
embedded within other local policy processes and how linkages and inconsisten-
cies are tackled (Longhurst, 1996). Planning Policy Guidance (PPG) Notes such
as PPG 6 (Town Centres and Retail Development), PPG 13 (Transport) and PPG
23 (Planning and Pollution Control) will need revising to better re¯ ect the
implications of the NAQS. A recent revision of PPG 13 has helped in this respect
(DoE/Department of Transport, 1995). However the need for clearer guidance is
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evident in the case of local councils being urged, on the one hand, to use
planning approval powers to resist proposals for development to locate in places
where there are no reasonable transport alternatives to the car, and/or will cause
adverse environmental impacts, yet having their rejection of such proposals
overturned by the Secretary of State.
Conclusion
Both the UK and the EC have introduced new strategic frameworks for air
quality management. Both frameworks shift the responsibility for assessing and
managing air quality to local authorities. The UK Government believes that the
NAQS will provide the principal means of carrying out its commitments under
the new EC framework. Given this situation, and the faster pace at which the
early stages of the NAQS are being implemented in comparison with the EC
framework, the UK’s experience is providing useful insights for other Member
States faced with implementing the EC framework. In this respect the NAQS
offers a testing ground for many aspects of the EC approach.
Some European cities have already developed good air quality management
capabilities but there are many that have yet to develop any such capabilities .
The UK Government has recognized, as the governments of other Member States
are likely to have to recognize, that it has to provide considerable support to its
local authorities in order that they can review, assess and manage air quality
effectively. It has had to expand the national pollution monitoring networks,
commission new detailed urban emissions’ inventories, and develop and vali-
date a suite of air quality dispersion models. Moreover, it has had to ensure that
information from these air quality management system components is accessible
easily by local authorities (via the internet). Training events in air quality
assessment techniques have had to be offered to local authority of® cers (and,
later, training for management practices will be needed). Many detailed guid-
ance notes have had to be issued to try to ensure a correct and consistent
interpretation of the air quality management approach. On occasions, govern-
ment initiatives to support the implementation of the NAQS, such as the trial
phase and the publication of essential technical guidance notes, have been
subject to delays. Initially this caused some unnecessary uncertainties and
inconsistencies amongst local authorities conducting the review and assessment
phase of the NAQS. This points to the importance of the Government ensuring
that the support needed to implement subsequent aspects of the NAQS, such as
de ® ning Air Quality Management Areas and formulating air quality improve-
ment Action Plans for these areas, will be in place in time. Currently, the
Government is testing and reviewing the additional pollution-control powers
that may be needed by local authorities in their Action Plans. Reformulation of
existing transport and planning policies is being considered, too, in order to
integrate air quality management more fully.
A ppendix: Review and A ssessment Stages in the National Air Quality
Strategy
The purpose of an air quality review and assessment, to be completed by
December 1999, is to identify areas where national policies to reduce vehicle and
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Strategic Framew orks for Air Q uality Management 119
industrial emissions are unlikely to result in air quality meeting air quality
objectives by 2005.
Stage 1
The ® rst stage is primarily a desk study which can be undertaken relatively
quickly and inexpensively, drawing upon a wide range of existing information.
Local authorities are issued with a checklist of questions designed to show
whether air quality objectives may be expected to be breached by 2005, taking
into account the likely effects of national emission control measures. This
screening stage is intended to identify local authorities with no major industrial
sources, no major road traf ® c problems (e.g. road links where current or
projected annual average daily traf ® c ¯ ows do not exceed 20 000 when consider-
ing NO2, 25 000 for PM 10 and 50 000 for CO) and no major developments with
signi® cant pollution potential planned for the future. For such local authorities,
there is no need to progress to stage 2 as the likelihood of air quality objectives
being breached is negligible. They must repeat a review and assessment at least
once more before 2005. However, the NAQS does expect all local authorities, not
just those with pollution problems, to develop a local air quality strategy as part
of their commitment to sustainable development. There must be explicit links to
local sustainable development planning and the Local Agenda 21 process since
air quality is regarded as a key environmental indicator of sustainability.
Stage 2
Where stage 1 has shown that one or more signi® cant emission sources are
present or, in the case of future developments, will be present before 2005,
maximum concentrations of the key pollutants must be estimated at the road-
side, urban background locations and industrial locations. Models to predict
such concentrations are recommended in the Government’s guidance notes
(DETR, 1998d). Guidance stipulates that it is not necessary to develop expensive
new local air quality management capabilities for this stage (DETR, 1997a). For
example, proxy or surrogate statistics and the results of monitoring elsewhere in
similar locations may be employed. If this second stage assessment indicates that
maximum concentrations are likely to approach or exceed air quality targets at
any of the speci® ed locations, local authorities must proceed to the more
detailed third stage.
Stage 3
The third stage assessment is likely to require the installation of automatic
pollution analysers, compilation of emissions’ inventories and application of
complex models although the Government stresses that tried and tested simple,
inexpensive approaches may play a role too. This stage is likely to require
considerable resources (cost of new equipment, staff time and training, and/or
hiring of consultants). If the results of this stage con® rm that one or more of the
air quality objectives are unlikely to be met in an area by 2005, then that area
must be declared an Air Quality Management Area (AQMA). Local authorities
designating an AQMA would then have 12 months to produce a more detailed
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120 D . M. Elsom
assessment. This is intended to con® rm the need for an AQMA and to provide
the in-depth understanding of the air quality problems that will be needed to
formulate an Action Plan. Given the requirement for widespread consultation,
local authorities have a further 12 months after completion of the detailed
assessment to complete the Action Plan. In other words, the review and
assessment of air quality for the purposes of the NAQS could take up to four
years to complete. This leaves a relatively short period for the Action Plan to
take effect and for the air quality objectives to be attained by 2005.
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