Greater Manchester Clean Air Plan: Tackling Nitrogen Oxide Exceedances at the Roadside - Outline Business Case
The report of the Deputy Chief Executive and City Solicitor is attached
In February 2018 we had noted the emerging content of the Draft Clean Air Plan and the GM Mayor’s Congestion Plan (Minute Exe/18/022). The origin of that work had arisen from the Government’s approach to improving air quality. In July 2017, the Government had published its latest plans to improve air quality and to achieve compliance with legislation across the country. Under that plan a number of local authorities were required to produce Clean Air Plans containing measures to address the Nitrogen Dioxide (NO2) problem in their area. Included in that were seven authorities in greater Manchester: Manchester, Bolton, Bury, Salford, Stockport, Tameside and Trafford. A further direction was issued in 2018 that related to a further 33 local authorities, including Oldham in Greater Manchester. Whilst Rochdale and Wigan Councils were not compelled to act through a ministerial Direction, they each agreed to participate in the Greater Manchester-wide approach under the leadership of the Greater Manchester Combined Authority. On this basis, Greater Manchester’s collective approach to develop a city-region wide Clean Air Plan had been accepted by government, and consequently no further ministerial Directions had been issued. A letter from the Minister in January 2019 required GM’s collective Outline Business Case to address Nitrogen Dioxide be submitted to Government by end of March 2019.
A joint report submitted to this meeting by the Deputy Chief Executive and the City Solicitor explained the further work that had been done at the Greater Manchester level on a Clean Air Plan Outline Business Case. It also explained that the collective plan had to be accepted and adopted by each of the individual councils in Greater Manchester, or that council would face legal action if it did not then have its own Outline Business Case to present instead of being a party to the GM collective case. The report therefore proposed that the Executive adopt and approve the feasibility study and Outline Business Case (OBC) to reduce NO2 exceedances in Manchester and across Greater Manchester in the shortest possible time.
The report described the process that had been followed to develop the GM approach and the GM feasibility study. It had been agreed that a GM-wide approach was needed so as to avoid the risk of measures being taken in one district that just displaced pollution to another part of the city-region.
In their National Plan the Government had identified the areas of road within Greater Manchester where the national Pollution Climate Mapping (PCM) model predicted NO2 concentrations were likely to exceed the statutory NO2 annual mean EU Limit Value beyond 2020. The local modelling that had since been done had identified 152 stretches of road and road links where concentrations of NO2 were forecast to exceed the legal Limit Value (40 µg/m3) beyond 2020. Some 112 of these road links were in the national PCM model, which have the highest car use and heavy freight flows. The other 40 were shorter stretches of local roads, often around town centres across Greater Manchester where there was greater bus, taxi and van usage.
The outcome of the local modelling was an agreement on the NO2 exceedances that Greater Manchester must resolve when developing possible solutions. That agreement was referred to as Target Determination. The Greater Manchester modelling had now been agreed by Government, meaning that all the illegal exceedances in all ten GM local authority areas needed to be addressed within the plans.
The report explained that in the approach taken to develop the options for Greater Manchester the core goal was to address the legal requirement to remove all exceedances of concentrations of NO2 that were forecasted to exceed the legal Limit Value (40 µg/m3) identified through the target determination process in the “shortest possible time” in line with Government guidance and legal rulings. The possible options had therefore been assessed against the UK Government’s Primary Critical Success Factors:
· reduction in NO2 emissions: the likelihood that the option will contribute significantly to a reduction in NO? concentrations to achieve compliance with the EU Limit Values; and
· feasibility – the likelihood of measure being implemented in time to deliver desired NO? reduction and achieve compliance.
Further refinement of options was then made using the Government’s secondary critical success factors:
· Strategic fit with local strategies and plans - ensuring the alignment of the option with longer term economic, social and environmental goals and that the risk of unintended consequences is minimised.
· Value for money - a high-level indication of the costs and benefits of each option.
· Distributional impact - in order to understand the potential impacts, both positive and negative on different groups within society, with a particular focus on the most vulnerable. It is of vital importance that the plan does not result in disproportionately negative economic or social impacts for the region or those living, working or doing business within it.
· Deliverability - the affordability of the cost of implementation, the supply-side capacity and capability to deliver the measures outlined in the options, and the achievability of delivering the option.
The report went through the option assessment, analysis and refinement process. It explained how all the initial options had been evaluated and presented those that had emerged as being the most likely to achieve the stated core goal. A detailed assessment of the best performing options was appended to the report. The report also explained why other possible options had been discounted. The option that had emerged from this work as that most likely be succeed was referred to as ‘Option 8’. It was shown to involve less risk that the others, could be delivered at a lower cost and so was more affordable. Option 8 was for a Greater Manchester-wide Clean Air Zone (CAZ) to be introduced in two phases:
· Phase 1: (from 2021) daily penalty for non-compliant HGVs, buses and coaches, taxis and private hire vehicles
· Phase 2: (from 2023) expanding to non-compliant LGV vans and minibuses
Non-complaint polluting vehicles would pay a penalty charge for each day they were in the CAZ boundary. The proposed penalties were:
Taxi / PHV
As well as cars, the following vehicles wouldn’t be liable for a penalty payment as their engines were cleaner, meeting these standards:
· Bus/HGV – Diesel Euro 6 engine (from 2013)
· Van and minibus – Diesel Euro 6 (from 2016)
· Motorbike/moped – Petrol Euro 3 (from 2007)
· Taxis and private hire vehicles – Diesel Euro 6 (2015 onwards)
· Taxis and private hire vehicles – Petrol Euro 4 (2005 onwards)
The report explained that the decision to not include private cars in the CAZ stemmed from particular concerns over the potential impact that including cars would have on low income car-dependent workers, small businesses, and city centre retail.
The report then examined the steps that would have to be taken to implement the proposals and the level of financial support needed from Government for it to be successful. Funding would be needed to help local businesses and sole traders, the voluntary sector, private hire and taxi operators, and bus companies upgrade to compliant vehicles. The possibility of providing support by means of low-cost loans to businesses and taxi or private-hire operators was being further examined.
The report set out the next steps to be taken to progress the Clean Air Plan. Subject to the approval of each of the ten GM local authorities, this Outline Business Case was to be submitted to Government within the required deadline of 31 March 2019. The Government’s response was expected 6-8 weeks after submission. Next, a public ‘conversation’ was being proposed, to run between early May and mid-June (for six weeks) to help further inform the work. That would supplement stakeholder engagement that was ongoing with affected businesses. In addition, further deliberative research was proposed to take place during March and April. These forms of engagement and dialogue would all inform the further development and detailed design of the measures identified in the OBC, to refine the proposals that were to comprise the Full Business Case. Then, as required by Transport Act 2000, a statutory consultation relating to the proposed introduction of a charging Clean Air Zone was proposed to run between August and October 2019. Subject to approval by the GMCA and the 10 districts, a Full Business Case could be submitted to Government by the end of 2019.
It was noted that a recent meeting the Neighbourhoods and Environment Scrutiny Committee had also considered the report and had endorse its recommendations (Minute NESC/19/16).
The report was welcomed and the proposals within it agreed.
1. To note that the Council is legally obliged to produce a feasibility study to identify the option which will deliver compliance with the requirement to meet legal limits of nitrogen dioxide following the Secretary of State issuing a direction under the Environment Act 1995.
2. To adopt the feasibility study undertaken to date.
3. To approve the Outline Business Case for submission to the government's Joint Air Quality Unit.
4. To note that further stakeholder engagement and public consultation is an essential part of the process to help inform and refine ongoing work to produce a Full Business Case by the end of the calendar year.
5. To approve the commencement of the public conversation and engagement activity from 15 May 2019.
6. To note that further reports will be submitted to Executive on:
a) the proposals for statutory consultation, informed by the outcome of the public conversation and engagement.
b) formal approval of the Full Business Case.
7. To agree that Transport for Greater Manchester continue with the activity to produce the Full Business Case on behalf of the ten Greater Manchester authorities, under the direction of the Greater Manchester Clean Air Steering Group.
8. To delegate to the Chief Executive, in consultation with the Executive Member for Transport, Planning and the Environment the approval of submission of supplementary information.
- 4 - Clean Air Plan, item 29. PDF 1 MB
- 4.1 - Clean Air Plan App 1 - Detailed assessment of options by compliance date, item 29. PDF 97 KB
- 4.2 - Clean Air Plan App 2 - Assessment of options by success criteria, item 29. PDF 217 KB