Greater Manchester Clean Air Plan - Overview and update February 2019
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Greater Manchester Clean Air Plan Overview and update February 2019
What is air pollution and why does it matter?
Poor air quality is one of the largest
public health issues facing the UK
• Long-term exposure to elevated levels of particulate matter (PM2.5) and nitrogen
dioxide (NO2) contributes to the development of cardiovascular or respiratory disease,
and may reduce life expectancy.
• The youngest, the oldest, those living in areas of deprivation, and those with existing
respiratory or cardiovascular disease are most likely to develop symptoms due to
exposure to air pollution.
• People walking or cycling are exposed to significantly lower levels of air pollution
compared to drivers and passengers inside vehicles travelling along the same urban
route. Cars take in emissions from surrounding vehicles and they recirculate the
pollutants within the confined ‘cabin’ space.
• By 2035, the estimated UK health and social care costs due to exposure to air pollution
are £5.3 billion for diseases with a strong association with air pollution, and £18.6
billion for all diseases evidence shows have an association with air pollution.Why are we producing a Clean Air Plan?
• EU 2008 Directive on Ambient Air Quality sets legal limit values for a range of air pollutants, including NO2. • This was incorporated into UK law in the UK Air Quality Standards Regulations 2010. • The UK has been in breach of the legal limits for NO2 since 2010.
UK Air Quality Plans (AQP)
December 2015 AQP:
ClientEarth v The SoS for the Government to draw up AQP to
National Air Quality Plan:
Environment, Food and Rural achieve the EU limit values in the
Affairs [2015] UKSC 28 Birmingham, Derby, Leeds,
shortest time possible
Nottingham, and Southampton
ClientEarth (No. 2) v The SoS 2015 AQP gave too much weight July 2017 AQP: 23 local
for the Environment, Food to cost, political sensitivity and authorities including Bolton,
and Rural Affairs [2016] administrative difficulties. Bury, Manchester, Salford,
EWHC 2740 New AQP by 31 July 2017. Stockport, Tameside, Trafford
ClientEarth (No. 3) v (1) The SoS Mandatory order: urgent
for the Environment, Food and production of a Supplement to
March 2018 Supplementary
Rural Affairs; (2) The SoS for 2017 AQP including requirements
Directive: 33 local authorities
Transport and (3) Welsh for additional feasibility studies
including Oldham
Ministers [2018] EWCH 315 to be undertaken in 33 of the
45 areas.What have local authorities been directed to do?
Local responsibility to act • Government has delegated the responsibility to address NO2 compliance to Local Authorities and has set out the process and timescale for doing so. • Local Authorities are responsible for the local road network and their own fleets. • Responsibility for the Strategic Road Network (Motorways and trunk roads) lies with Highways England, who have not been directed to act to reduce NO2 on the Strategic Road Network in the same timescale/process. • Highways England is currently assessing sections of the motorway network around GM to explore potential measures.
What Government requires Defra and DfT (2017) ‘UK Plan for tackling roadside nitrogen dioxide concentrations’.
Diesel vehicles are the largest source
Public consultation to be undertaken if the option that emerges from the required feasibility study process requires it
GOVERNMENT HAS
ALLOCATED £255
MILLION FOR
IMPLEMENTATION
FUNDING AND £220
MILLION TO A CLEAN
AIR FUND
(NATIONALLY)The three legal tests for assessing air quality plans
Local plans must:
1. Aim to achieve compliance as soon as possible;
2. Choose a route to compliance which reduces human exposure as quickly as
possible; and
3. Ensure that compliance with the limit values is not just possible but likely.
(ClientEarth (No. 2) v The Secretary of State for the Environment, Food and Rural Affairs [2016]
EWHC 2740)
NOTE: The legal responsibility for achieving the requirements of UK Plan for
tackling roadside nitrogen dioxide concentrations sits with the local authorities with
exceedances in their area.The National Plan identifies charging Clean Air Zones (CAZ) as the benchmark measure for achieving statutory NO2 limit values in the shortest possible time. Local authorities must consider introducing charging CAZ unless they can identify alternatives that are at least as effective at reducing NO2, and deliver compliance as quickly as a charging Clean Air Zone.
Differences: Congestion Charging and Clean Air
Zones
Clean Air or Low
Congestion Charging
Emission Zone
Objective: ensure drivers pay the cost they Objective: persuade drivers to upgrade their
impose on others vehicle to a cleaner model
Charge applies to all vehicles (with some Charge applies only to non-compliant
discounts and exemptions applied) vehicles, compliant vehicles are unaffected
Designed so most people upgrade their
Designed so most people stay and pay
vehicle and do not pay
A CAZ is a
Goal is to reduce congestion with wider Goal is to improve air quality and reduce temporary
benefits to air quality, safety etc emissions by cleaning up the vehicle fleet
measure to
achieve air quality
targets
Schemes are highly profitable, providing
Schemes typically make a loss, especially in
resources to invest in public transport, active
later years
travel and other complementary measuresClean Air Zone Framework:
Compliant Vehicles
GM being encouraged
to sign up to Fossil-
Age of Compliant Vehicles Fuel-Free streets (buy
zero-emission buses
GM has signed a Vehicle Type Compliant Class from 2025 and ensure a
declaration of intent major area of city is
for the city-region
Diesel Euro 6 (2015)
Car/Taxi zero emission by 2030)
to move to a zero- Petrol Euro 4 (2005)
emission bus fleet Van Euro 6 (2016)
(May 2018)
Bus/HGV Euro 6 (2013)
Motorcycle/Moped Euro 3Activity in Greater Manchester
A Greater Manchester Clean Air Plan The purpose of taking a GM-wide approach is to avoid introducing measures in one part of the conurbation that simply displace pollution to other locations, and to ensure that (as far as possible) the eventual Clean Air Plan complements other GM-wide strategies including the existing GM Air Quality Action Plan and GM Low Emission Strategy.
Where are we now? Spring 2018: - Development of long-list of 96 measures, refined to 17 to include in Strategic Outline Case. - Strategic Outline Case approved by 10 Local Authorities and submitted to Government. Summer 2018: - Detailed modelling and understanding of air quality problem across GM. - Refining possible measures and development of options. Autumn 2018: - Modelling of options (NO2 reduction). - Commenced analysis of socio-economic impact of options.
Understanding the NO2 problem • Government initially identified 11 non-compliant links on the Pollution Climate Mapping (PCM) network in GM • The national model does not contain detailed local data (local roads and fleet) (etc) and must be verified against local evidence. • Local authorities were asked to re-model predicted NO2 levels in 2021 under a “do minimum” scenario as part of the feasibility study to confirm the local air quality problem.
Local evidence used to understand likely NO2
concentrations beyond 2020
Based on government guidance:
• Detailed Base Year (2016) and Future Year (2021) transport model (actual and future demand
on the road network) for all roads within GM (the National Model underpinning the National
Plan includes only major urban roads).
• Local vehicle fleet (e.g. ages and types of vehicle) using ANPR data.
• Local background concentrations of NO2 (e.g. from energy generation, industry, domestic, non-
road transportation).
• Detailed road network & junction data (e.g. real-word road alignment and width).
• Representation of canyons (e.g. tall buildings).
• Local air quality monitoring data (from across GM).
• Confirmed future changes to the local road network, regional traffic growth and changes to the
traffic fleet.Manchester Evening News, 7th October 2018
A wide range of options continue to be analysed …
Type of option Overview of analysis (headlines) Latest
analysis
Increase public transport capacity Build new Metrolink line: not possible by 2021. May not provide sufficient
NO2 reduction across GM
Increase rail capacity: not possible by 2021. Insufficient powers
Increase bus capacity: commercial market, discuss with operators – identify
routes with most impact
Retrofit/upgrade public transport Existing fleet must be retrofitted or replaced with a higher Euro rating
fleet
Electric vehicle incentives Good NO2 impact, Early Measures Funding creating momentum
Travel choices/active travel Good NO2 impact but insufficient by 2021 as a single measure
engagement
Parking (e.g. different charges for Undeliverable in time (contracts with parking suppliers), unfair as based on
time of day/vehicle type/car reliance on parking rather than cleanliness of vehicle, and insufficient NO2
sharing/workplace levy) impact by 2021 as a single measure
Switch bus/HGV/LGV fuelling Industry engagement shows not feasible
stations or GM fleet to GtL fuel
Retrofit or upgrade GM Family fleet Existing fleet must be retrofitted or replaced with a higher Euro ratingA wide range of options continue to be analysed …
Type of option Overview of analysis (headlines) Latest
analysis
Congestion Deal – increase Feasible but unlikely to reduce NO2 sufficiently as a single measure
capacity
Congestion Deal – encouraging Feasible but unlikely to reduce NO2 sufficiently as a single measure
alternatives
Congestion Deal – network Feasible but unlikely to reduce NO2 sufficiently as a single measure
management
Active travel programme (e.g. Good NO2 impact but insufficient by 2021 as a single measure
cycling and walking infrastructure)
Communications campaigns Feasible but unlikely to reduce NO2 sufficiently as a single measure
Private hire and taxi EV and Switch to alternative fuels unlikely to be feasible in time
alternative fuels EV upgrade feasible but support needed
Charging Clean Air Zone (as Charging all non-compliant vehicles: undeliverable by 2021 (infrastructure),
defined by Government) and creates re-distribution of NO2
Targeted area-based charging: feasible as enables different vehicles to be
included in toll at different times/scales based on NO2 emissions, availability
Ongoing
of alternatives, and socio-economic impact. To include exemption periods +
support to replace/upgrade vehiclesCharging Clean Air Zones (as defined by Government)
As required by Government Guidance and agreed in the Strategic Outline Case (March 2018), a
range of charging options for Clean Air Zones (CAZ) are being developed and modelled.
Options being modelled include:
1. Different classes of charging CAZ for non-compliant vehicles at different scales (Government’s
categories A,B,C and D):
- E.g. within the inner ring road only
- E.g. within the M60 boundary
- E.g. across the whole of Greater Manchester
2. Exemption periods and discounts (including timing)
No decisions have been made. Analysis of their full impact continues.Analysis is not yet completed but …
A multi-option approach is likely to be needed because:
- Incentives and support to replace or retrofit the most-polluting vehicles must
underpin any action.
- Any residents in an area where a toll could be introduced must be offered
exemption periods.
- There must be support for people on low incomes to replace their vehicle if it
falls into the most polluting categories.
- Any tolls for the most-polluting vehicles must also take account of availability of
alternatives (timing).
- Action must reduce exposure as quickly as possible (some things can be done
faster than others).Analysis is not yet completed but … Multi-variant policy analysis is needed to … - Ensure any options support economic well-being. - Ensure any options support social inclusion. - Ensure any options support reduction of carbon emissions and particulates as well as NO2. Whilst recognising the reality of the implications of the court findings.
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