Air quality action plan appraisal 2024

The action plan sets out information on air quality obtained by the Council as part of the Local Air Quality Management process required under the Environment Act 1995 (as amended by the Environment Act 2021) and subsequent Regulations.

This appraisal report covers the final air quality action plan (AQAP) for 2024 - 2029 submitted by Cheltenham Borough Council (CBC), taking into account updated LAQM policy and technical guidance. The AQAP covers CBC’s sole AQMA, which encompasses an area extending from the junction of Gloucester Road, Tewkesbury Road and High Street, through Poole Way and along Swindon Road to the junction of St George’s Street. This was declared for exceedances of the annual mean NO2 objective. Previously, an AQMA covering the whole borough had been in force, but this was revoked in 2020 to make way for this new, more focused area. The previous AQAP completed by CBC, dated April 2014, had covered the wider AQMA.

The final AQAP follows the latest Defra template well, meeting the content requirements, and is very detailed, well-presented and clearly formatted. The AQAP addresses one of the main comments from the previous appraisal report, where it was unclear how the supporting information from the original draft version of the report was intended to be read and/or linked back to the original final document.

The Council presents monitored concentrations in detailed graphical and tabular form within the Cheltenham AQMA, covering the five-year 2018 – 2022 period, updated from the draft AQAP. The monitoring summary indicates that there were no exceedances of the AQS objective for annual mean NO2 in 2021 or 2022, though this is likely to be attributed at least in part to the COVID-19 pandemic during 2021, as concentrations were far more elevated in 2019, with multiple exceedances across the borough in that year (though all three were within the current AQMA). The borough therefore exhibits a decreasing trend in monitored NO2 concentrations. PM2.5 concentrations, based on dispersion modelling, demonstrate compliance with the annual mean objective in 2019.

The final AQAP sets out the public health context in detail, citing the public health outcomes indicator, which was updated to the 2021 figure from 2018 previously, addressing the comment in the appraisal report. The indicator states that in 2021, the fraction of mortality attributable to PM2.5 pollution in Cheltenham was 5.5%, which is the same as the national average, but higher than that for the south-western region (5.1%). Two public health strategy documents, the Gloucestershire Air Quality and Health Strategy and the Gloucestershire Joint Health and Wellbeing Strategy 2019-2030, are also highlighted to demonstrate the synergy between public health and air quality work. Indeed, the AQAP has been signed off by the head of public health at the county level, showing the plan aligns with regional public health actions.

National and regional scale policy documents, such as the Clean Air Strategy 2019 and the UK plan for Tackling Roadside Nitrogen Dioxide Concentrations, are referenced in the plan, showing the AQAP is cognisant of complementary central government policies and will look to build upon these to ensure effective implementation.

Alongside this, the Gloucester, Cheltenham and Tewkesbury Joint Core Strategy, Local plan, Local Transport plan, Climate Emergency, Cycling Infrastructure plan and ‘Connecting Cheltenham’ are all referenced. The Local plan, adopted in 2020, has two core policies relevant to air quality, BG2 and EM2. Policy EM2 states that:

“Development proposals for a change of use of land and buildings currently or last in employment use will only be permitted where: c) The applicant for planning permission can demonstrate that employment use creates unacceptable environmental or traffic problems which cannot be satisfactorily resolved.”

This statement provides confidence that new planning applications will be assessed as they are brought forward for their impact on air quality.

Source apportionment was carried out in 2021 based on a baseline year of 2019 (exclusive of COVID-19 effects) using ADMS-Roads dispersion modelling. Results were presented at various levels, across the whole modelled area, the entire AQMA and at the receptor with the maximum road NOx. Of the road traffic sources, cars are, as expected, the dominant vehicle types and emissions sources within the local fleet (though this is not broken down by fuel type), at up to 54% of the total road NOx at the highest modelled location. LGVs are the second most significant source (29%), followed by buses and HGVs (~8%). Figures demonstrating total NOx source apportionment, including the background component, have also been included. The background component is between approximately a third and a fifth of the total NOx, depending on which level of exposure is considered.

In the final AQAP, the split between the local and regional background has also been shown within Table 3.2, addressing the comment from the appraisal of the draft.  Additionally, Table 3.3 presents the NO2 source apportionment broken down by vehicle type, as requested in the previous appraisal report, again showing that cars and LGVs dominate local emissions.

Calculations of the required reduction in road NOx emissions have been included, undertaken as per the methodology prescribed in LAQM.TG(22) Box 7.6, updated since the draft AQAP. In 2019, there was calculated to be a 54.7% reduction in road NOx required to achieve compliance in the AQMA, taking into account that a more stringent figure of 36 µg/m3 for total NO2 concentrations has been used (10% lower than the annual mean AQS objective). Whilst this is now likely to be an overly conservative estimate of the reductions required, since monitored concentrations have reduced since that time, this represents a significant reduction required.

The council have developed 31 measures, with the final AQAP including an additional 3 measures since production of the draft.  The measures table has been updated to match that of the current Defra template, addressing the comment from the appraisal of the draft.  The measures have been considered under five key priorities:

  • Priority 1 – Transport;
  • Priority 2 – planning and Infrastructure;
  • Priority 3 – Policy Guidance;
  • Priority 4 – Public Health and Wellbeing Behavioural Change; and
  • Priority 5 – Air Quality Monitoring.

On an individual measure basis, these are generally focused on the transport topic, with several measures focussed on improving vehicular emissions (e.g. electric vehicle incentives) and traffic management at specific junctions, such as at North Place/Portland Street. There is also a large emphasis on increased public information, through enhancements to monitoring and reporting, primarily. Additional measures are policy led, including a stand-alone air quality strategy and setting an aspirational local NO2 objective of 30 µg/m3, which can be considered best practice.

All measures have been assigned target pollutant reductions, which addresses several comments from the draft AQAP appraisal report, and provide further clarity on the potential effectiveness of the measures.  It is noted that many of the measures’ pollution reduction potentials are difficult to quantify, and so a welcome discussion on quantification of all measures is presented in Table 6.1 to highlight any uncertainties here.  Some measures have been given indicative quantified pollutant concentration reductions via worked calculations presented in the report, which is helpful to the reader.

In addition to this, and in response to commentary from the draft AQAP appraisal report, a detailed section on cost-benefit and feasibility analysis of the measures has been presented in the final AQAP.  Table 6.8 clearly shows the ranked list of most cost-effective/feasible measures, along with the indicative costs, using an easy to understand matrix scoring system clearly explained in the report.  Engagement with Royal Mail to switch to a low emissions fleet, publication of AQ monitoring results and expansion of a park and ride scheme have been earmarked as being overall the most cost-effective, beneficial and feasible.

Responses to the consultations undertaken with local bodies in development of the draft AQAP are summarised in Appendix A. This includes additional text from public health at the county council, as well as specific feedback on measures 22 and 25 (pertinent to taxis) from the council’s licensing team.

The composition of the AQAP steering group has been presented, which consists of senior members of Council staff within the relevant stakeholder groups, an external consultant, members of the public and a local councillor. This means a broad range of views have been considered. Good detail is provided on their actions, primarily centred on two meetings early in the AQAPs development, in 2021. The ambition to continue to convene the group through implementation is a welcome one.

Overall, the final AQAP is thorough and comprehensive, and has incorporated the comments well from the previous appraisal of the draft AQAP, with a summary of responses to these comments also listed in Appendix D.  On this basis, the AQAP is therefore accepted. Specific commentary to inform the final version prior to publication, and future updates, is provided overleaf.

It is recommended that, as a minimum, AQAPs are updated every five years, and reported on annually within the ASR, as stated within the AQAP document itself.

The council should take on board the following considerations prior to publication, and in any future updates of the AQAP.

Commentary

  • The period of validity of the AQAP is not fully consistent throughout the AQAP document (e.g. 2023-2028, 2024-2028, 2024-2029) – please ensure this is consistent prior to publication.
  • There is a minor typo in Table 6.5, which could be corrected prior to publication of the final AQAP – should be “< 0.5 µg/m³”.
  • A clear cost-benefit and feasibility analysis has been presented for all measures in the final AQAP, helping to show the priorities and easy wins for tackling poor air quality – this can be considered an example of good practice.
  • A detailed discussion on quantification of measures has been presented, stating which measures could have AQ impacts reasonably quantified, with additional worked calculations presented for those quantifiable measures – this again is an example of good practice for AQAPs.
  • The Appendix C (detailed modelling report) and References section are blank –these should be filled out prior to publication, or in the case of Appendix C, a link to the modelling report and context summary should be provided, or otherwise refer to the report in the AQAP but remove the appendix.

This commentary is not designed to deal with every aspect of the action plan. It highlights a number of issues that should help the local authority in maintaining the objectives of its action plan, namely the improvement of air quality within the AQMA.

Issues specifically related to this appraisal can be followed up by returning the attached comment form to Defra, Welsh Government, Scottish Government or DOE, as appropriate

For any other queries please contact the Local Air Quality Management Helpdesk:

Telephone: 0800 0327 953

Email: [email protected]

Notice for 2024

Through the Environment Act 2021 and updated Local Air Quality Management Statutory Policy Guidance 2022, the Local Air Quality Management (LAQM) framework has been considerably strengthened. This page highlights some of the changes for delivery to help you prioritise action for improved air quality:

1. Strengthened Criteria for air quality action plans (AQAPs)

Where a Local Authority is not meeting air quality objectives they must create an AQAP setting out their intentions to improve air quality in the area. Without current action plans in place, Local Authorities risk negatively impacting their communities by not proactively working to reduce air pollution in the area. 

The requirements and guidance around AQAPs were recently strengthened under the Environment Act 2021 and revised LAQM Statutory policy guidance, which Local Authorities must have regard to. The key criteria for action plans are that they:

  • set out the measures they will take to secure the achievement, and maintenance, of air quality standards and objectives
  • specify a date by which each measure will be carried out
  • are revised no later than every five years

2. New escalation process for reporting

To ensure ASRs and AQAPs are delivered on time, Defra has introduced a new reminder and warning letter system for Local Authorities. This system was set out in the LAQM Statutory Policy Guidance 2022, published on 6 August 2022.

From 30 June 2023, Local Authorities with overdue ASRs and AQAPs will start to receive their first reminder letters. As set out in the Tables 1 and 2 below, if reporting requirements continue to be missed, the matter can be escalated to a Section 85 Secretary of State direction to the relevant Local Authority Chief Executive specifying action.

You are therefore advised to ensure all statutory reporting duties for LAQM are met on time. Please refer to the LAQM Statutory Policy Guidance 2022 for more information.

Table 1: Reminder and warning process for ASRs

Timescale

Enforcement

Recipient

Six months before deadline - January

Pre-reminder letter

From the Air Quality and Industrial Emissions (AQIE) Deputy Director to all local authority Chief Executives and relevant director/s - environment and public health reminding them of LAQM statutory requirements.

Two months before deadline - April

Final pre-reminder letter

From Defra’s LAQM team to all air quality officers reminding them of June deadline

One month overdue - July

Reminder letter

From Defra’s LAQM team to air quality officer at non-submitting local authorities

Three months overdue - September

Warning letter

From the AQIE Deputy director to relevant director/s - environment and public health

Four months overdue - October

Final warning letter

From the AQIE Deputy director to relevant director/s - environment and public health

Six months overdue – December

Ministerial letter: Section 85 direction

Local authority chief executive

 Table 2 – Reminder and warning process for AQAPs - Due to be revised at least every five years

Timescale

Enforcement letter

Recipient

AQAP 2 months overdue (e.g. 20 months post AQMA designation or 5 years & 2 months since previous AQAP publication)

Reminder letter

From Defra’s LAQM team to air quality officer at non-compliant local authority

AQAP 4 months overdue

Warning letter

From the AQIE deputy director to environment health/air quality manager at non-compliant local authority

AQAP 6 months overdue

Final warning letter

From the AQIE deputy director to relevant director at non-compliant local authority

AQAP 8 months overdue

Ministerial letter: Section 85 direction

Local authority chief executive

3. Public bodies required to Contribute to action plans

The Environment Act 2021 amended the Environment Act 1995 to increase the number of public bodies that have a duty to co-operate with local authorities for LAQM. Air quality partners are certain other public bodies that a local authority identifies as having responsibility for a source of emissions contributing to an exceedance of local air quality objectives. This could be a neighbouring authority, National Highways, or the Environment Agency. Once identified, there is a statutory requirement for such public bodies to engage and to contribute actions they will take to secure achievement of the local air quality objective and to maintain achievement thereafter.

All tiers of local Government are also now required by law to collaborate to address exceedances of Air Quality Objectives. County councils, the Mayor of London and combined authorities have similar duties to air quality partners. The difference is that, when requested, they must contribute to an action plan being prepared by a local authority, regardless of whether the local authority has identified them as being responsible for a source of emissions.

Under the new legislation, you may choose to request the support of another public body in the development of an AQAP and the same may be requested of your organisation.

Please refer to the LAQM Statutory Policy Guidance 2022 for more information. Should you require further assistance, please contact the LAQM Helpdesk:

Web: https://laqm.defra.gov.uk/helpdesks.html

FAQs: https://laqm.defra.gov.uk/laqm-faqs/

Tel: 0800 032 7953

Email: [email protected]

The Air Quality Hub also provides free online information and is a knowledge sharing resource for local authority air quality professionals.

Appraisal response comment form

Contact Name:

 

Contact Telephone number:

 

Contact email address:

[email protected]

Comments on appraisal/Further information

None.