MECHANISMS FOR THE ALIGNMENT OF AIR QUALITY PLANNING

MECHANISMS FOR THE ALIGNMENT OF AIR QUALITY PLANNING

Prepared by Randolph Angle, Ph.D.

For

Alberta Environment

July 2010 ISBN: 978-0-7785-9980-7 (Printed) ISBN: 978-0-7785-9981-4 (On-line) Web Site: http://www.environment.alberta.ca/

Although prepared with funding from Alberta Environment (AENV), the contents of this report/document do not necessarily reflect the views or policies of AENV, nor does mention of trade names or commercial products constitute endorsement or recommendation for use.

Any comments, questions, or suggestions regarding the content of this document may be directed to:

Air Policy Section Alberta Environment 11th floor, Baker Centre 10025 – 106th Street Edmonton, Alberta T5J 1G4 Fax: (780) 644-8946

Additional copies of this document may be obtained by contacting:

Information Centre Alberta Environment Main Floor, Oxbridge Place 9820 – 106th Street Edmonton, Alberta T5K 2J6 Phone: (780) 427-2700 Fax: (780) 422-4086 Email: [email protected] FOREWORD

Alberta airshed zone enable local stakeholders to design local solutions to address local air quality issues because many of Alberta’s air quality issues are local, both in their cause and the solutions required. Province-wide approaches may be inappropriate and inefficient. Airshed boundaries are decided with consideration of a number of geopolitical factors. In 2009 there were eight fully operating airsheds in Alberta, with a ninth in development for the Capital Region. The domains of these airsheds, however, do not cover the whole province.

The Alberta Stewardship Act (ALSA) requires Regional Plans to be developed. The province of Alberta is divided into seven Land-use Framework planning regions. These seven regions follow watersheds rather than the geopolitical boundaries used for airsheds.

The Comprehensive Air Management System (CAMS) proposed to the Canadian Council of the Ministers of Environment recommended that air management would occur at two scales: regional airsheds and air zones. Regional airsheds will be delineated mainly by the federal government for coordinating the management of transboundary air quality issues and the air zones, the finite air quality management unit, will be delineated by the provincial/territorial governments. Collectively the air zones will cover all of Canada. Their boundaries should be well-defined and follow natural or obvious boundaries.

This report reviews the histories and considerations taken in the formation of airsheds in Alberta and surveys other selected jurisdictions with respect to air quality planning approaches and use of airsheds. The report also provides information on air quality planning alignment mechanisms, which will be useful in delineation of air zones in Alberta under the Comprehensive Air Quality Management System.

Lawrence Cheng, Ph.D. Air Policy Air, Land and Waste Policy Branch

Mechanisms for the Alignment of Air Quality Planning i

ACKNOWLEDGEMENTS

The author would like to thank a number of individuals who contributed to the information used in preparing this report. Kevin Warren provided access to the parkland air management zone record archives and shared his personal knowledge of the unwritten history of several airsheds. Bob Scotten shared his direct experience with several of the airsheds. Michael Bisaga and Jill Bloor supplied background documents for Lakeland Industry and Community Association and Calgary Region Airshed Zone respectively. Discussions with Lawrence Cheng and Bettina Mueller were helpful in organizing the set of options. The comments of Alberta Environment reviewers improved the readability of the document.

Mechanisms for the Alignment of Air Quality Planning ii SUMMARY

Airshed boundaries are decided with consideration of a number of geopolitical factors. The complex balancing is often difficult to articulate and record; consequently documentation tends to be sparse or challenging to obtain. Air quality impacts (concentrations and depositions) predicted by air dispersion models provide an objective anchor for both boundary decisions and monitoring network design. Although air quality planning was envisaged in the 1995 Zone Guidelines, it was not until 2006 that five airsheds undertook the preparation of air quality plans triggered under the Clean Air Strategic Alliance (CASA) Particulate Matter (PM) and Ozone Management Framework.

Alberta’s Framework (LUF) uses seven regions that follow watersheds rather than the geopolitical boundaries used for airsheds. The Canadian Comprehensive Air Management System (CAMS) proposes the entire province be covered by CAMS air zones and has provision for the province to delegate functional responsibility for air zones to a multi-stakeholder Air Zone Management Team.

Various jurisdictions apply different approaches to addressing air quality. The European Union directs its Member States to identify geographical zones for monitoring and management of air quality and suggests zone boundaries be linked to administrative areas. In the United Kingdom, air quality planning is done by the local authorities with encouragement to cooperate with neighboring authorities. Management areas exist only where needed. Nordic countries, New Zealand and some Australian states have integrated air quality into their land use planning since the 1990s. The United States divides the country into areas based on air quality standards and the states develop plans depending on the designation. Five large multi-state areas have been formed to address larger scale problems. California has airsheds for monitoring purposes, but a different set of management regions based on counties. Australia defines airsheds where needed for inventory purposes, with management occurring at the state or municipal level. In British Columbia airshed plans are developed where they are needed using a collaborative process of provincial and local agencies, integrating with other types of planning in the communities. In all jurisdictions, stakeholders are consulted at various stages of the planning process.

Alignment is about “coordinated functioning” and “harmonious action.” Planning is “the act of formulating a scheme, program, or method worked out beforehand for the attainment of an end.” A variety of tools are available to assist in getting different organizations to coordinate their various activities. Alberta appears to be alone in having independent multi-stakeholder consensus organizations operate as air quality planners. Most jurisdictions use local authorities or a coalition of government agencies to create the plans and just consult with stakeholders. Airsheds are designated differently in different jurisdictions for different purposes. Nordic countries, the United Kingdom, New Zealand and some Australian states use an integrated planning approach that strives for much the same sustainability goal as Alberta’s Land Use Framework. The three systems—CASA airsheds, LUF regions, and CAMS airzones-- are not inherently incompatible and can work together. Six broad alignment mechanisms are available and can be used alone or together in various combinations: geographical congruence, contracts, mandates, standardization,

Mechanisms for the Alignment of Air Quality Planning iii plan, and mutual adjustment. To implement any of the modes of geographical congruence, government would need also to use at least one regulatory or financial mechanism.

Mechanisms for the Alignment of Air Quality Planning iv TABLE OF CONTENTS

FOREWORD...... i ACKNOWLEDGEMENTS...... ii SUMMARY...... iii LIST OF TABLES ...... vii LIST OF FIGURES...... viii ACRONYMS AND ABBREVIATIONS ...... ix

1.0 INTRODUCTION ...... 1

2.0 AIRSHED BOUNDARIES AND AIR QUALITY IMPACT AREAS...... 3

2.1 West Central Airshed Society (WCAS)...... 5 2.2 Buffalo Environmental Association (WBEA) ...... 6 2.3 Parkland Airshed Management Zone (PAMZ)...... 7 2.4 Fort Air Partnership (FAP) ...... 9 2.5 Peace Airshed Zone Association (PASZA) ...... 9 2.6 Palliser Airshed Society (PAS)...... 10 2.7 Lakeland Industry & Community Association (LICA) ...... 11 2.8 Calgary Region Airshed Zone (CRAZ) ...... 11 2.9 Alberta Capital Airshed Alliance (ACAA)...... 13 2.10 The Role of Airsheds ...... 14 2.11 Summary...... 15

3.0 ALBERTA’S LAND USE FRAMEWORK...... 16

4.0 CANADA’S COMPREHENSIVE AIR MANAGEMENT SYSTEM ...... 18

5.0 PLANNING IN OTHER JURISDICTIONS ...... 20

5.1 North America ...... 20 5.1.1 British Columbia...... 20 5.1.2 United States ...... 22 5.1.3 California...... 26 5.2 Europe...... 27 5.2.1 European Union (EU)...... 27 5.2.2 United Kingdom (UK)...... 29 5.2.3 Nordic Countries...... 34 5.3 Australasia...... 37 5.3.1 Australia...... 37 5.3.2 New Zealand ...... 39 5.4 Summary...... 41

Mechanisms for the Alignment of Air Quality Planning v 6.0 ALIGNMENT MECHANISMS...... 42

6.1 Literature Survey on Alignment and Coordination ...... 42 6.2 Alignment by Geographical Congruence...... 48 6.3 Alignment by Contract...... 50 6.4 Alignment by Mandates...... 50 6.5 Alignment by Standardization ...... 51 6.5.1 Decision-making ...... 51 6.5.2 Outputs and Values...... 52 6.5.3 Personnel Requirements ...... 53 6.6 Alignment by Plan ...... 54 6.7 Alignment by Mutual Adjustment ...... 55

7.0 CONCLUSION ...... 57

8.0 BIBLIOGRAPHY ...... 58

Mechanisms for the Alignment of Air Quality Planning vi LIST OF TABLES

Table 1 Components of coordination (Malone and Crowston 1990)...... 44

Table 2 Techniques for coordination in public administration (Jennings and Ewalt 1998)...... 45

Table 3 Continuum of coordination (Alberta Education 1993)...... 46

Table 4 Pros and Cons of geographical congruence...... 49

Table 5 Pros and Cons of various methods of decision-making...... 51

Table 6 Responsibility (R) for various air quality management functions...... 55

Mechanisms for the Alignment of Air Quality Planning vii LIST OF FIGURES

Figure 1 Airsheds in Alberta at the end of 2009...... 4

Figure 2 Predicted 1990 annual deposition of sulphur in Alberta ...... 4

Figure 3 RELAD results for West Central Airshed...... 5

Figure 4 Predicted sulphur deposition using ADEPT2...... 7

Figure 5 Predicted annual average sulphur dioxide using a multiple plume model ...... 8

Figure 6 Predicted one-hour ambient sulphur dioxide concentrations in FAP area...... 10

Figure 7 Predicted annual average sulphur dioxide concentrations in LICA area...... 12

Figure 8 Maximum daily nitrogen dioxide concentrations in CRAZ area...... 13

Figure 9 The seven land-use framework planning regions in Alberta...... 17

Figure 10 Regional airsheds under CAMS (AZMRA 2009)...... 19

Figure 11 Levels in Finnish land use planning system...... 34

Figure 12 Components of Finnish regional planning...... 35

Mechanisms for the Alignment of Air Quality Planning viii ACRONYMS AND ABBREVIATIONS

AAC Alberta Airshed Council ACAA Alberta Capital Airshed Alliance ADEPT2 Acid Deposition Model with Terrain version 2 AENV Alberta Environment ALSA Alberta Land Stewardship Act AMD Air Monitoring Directive AOSERP Alberta Oil Sands Environmental Research Program APCD Control District (California) AQ Air Quality AQAP Air Quality Action Plan (UK) AQCR Air Quality Control Region (US) AQLV Air Quality Limit Value (EU) AQFD Air Quality Framework Directive (EU) AQM Air Quality Management AQMA Air Quality Management Areas (UK) AQMD Air Quality Management District (California) AQS Air Quality Stategy (UK) AZMRA Zone Air Management and Regional Airsheds Working Group BC British Columbia BVLD Bulkley Valley-Lakes District (BC) CAA Clean Air Act (United States) CAMS Comprehensive Air Management System CASA Clean Air Strategic Alliance CCME Canadian Council of Ministers of Environment CENRAP Central Regional Air Planning Association (US) CEP Community Plan (BC) CRAZ Calgary Region Airshed Zone CWS Canada-Wide Standard DAO Delegated Administrative Organization (Alberta) EC European Commission EEC European Economic Community EPA Environmental Protection Agency (US) EPEA Environmental Protection and Enhancement Act (Alberta) EPM Environmental Protection Measure (Australia) EU European Union FAP Fort Air Partnership FIP Federal Implementation Plan (US) FLM Federal Land Managers (US) FVRD Fraser Valley Regional District (BC) GHG Greenhouse Gases GOA Government of Alberta GVRD Greater Vancouver Regional District H2S hydrogen sulphide

Mechanisms for the Alignment of Air Quality Planning ix ID Improvement District IWG Implementation Working Group (Australia) LADCO Lake Michigan Air Directors Consortium (US) LICA Lakeland Industry and Community Association LAQM Local Air Quality Management (UK) LUF Land Use Framework MANE-VU Mid-Atlantic Northeast Visibility Union (US) NAAQS National Ambient Air Quality Standards (US) NGO Non-government Organization NO2 Nitrogen dioxide NPI National Pollutant Inventory (Australia) OCP Official Community Plan (BC) PAMZ Parkland Air Management Zone PAS Palliser Airshed Society PASZA Peace Airshed Zone Association PM Particulate Matter RAMIT Regional Air Management Investigation Team RELAD Regional Lagrangian Model of Acid Deposition RDNO Regional District of North Okanagan (BC) RDOS Regional District of Okanagan-Similkameen (BC) RPO Regional Planning Organization (US) RMA Management Act (New Zealand) SIP State Implementation Plan (US) SO2 Sulphur Dioxide THC Total Hydrocarbons TSP Total Suspended Particulates TWG Technical Working Group UK United Kingdom US United States of America VISTAS Visibility Improvement State and Tribal Association of the Southeast (US) WBEA Wood Buffalo Environmental Association WCAS West Central Airshed Society WRAP Western Regional Air Partnership (US)

Mechanisms for the Alignment of Air Quality Planning x 1.0 INTRODUCTION

Various levels of government and affected stakeholders have engaged in air quality planning throughout the past and are still involved in its current evolution. The 1991 Clean Air Strategy for Alberta identified local air quality issues and problems as a priority and hence a goal to “develop and implement a zone approach to managing air quality within specific airsheds.” A Clean Air Strategic Alliance (CASA) working group then developed management guidelines to help stakeholders who wanted to set up a zone in their area. The first zone was established in March 1995 in the west central region of the province. There are now eight airsheds in Alberta, five of which have been engaged in air quality planning under the CASA Particulate Matter (PM) and Ozone Management Framework.

On December 3, 2008, the Government of Alberta (GOA) published the Land-use Framework (LUF) as a means of balancing economic, social and environmental interests. Among the seven key strategies to improve land-use decision-making in Alberta, the following three directly impact air quality planning throughout the Province:

• Develop seven regional land-use plans • Use a cumulative effects approach at the regional level to manage the impacts of development on land, and air • Establish an information, monitoring and knowledge system to contribute to continuous improvement of land-use planning and decision-making

Plans are to be developed for seven different regions in Alberta with each integrating provincial policies at the regional level, setting out regional land-use objectives, and providing direction and context for land-use decision-making in the region. The plans are also to reflect the uniqueness of the and priorities of each region within a planning context.

On October 21, 2006, the federal government published a Notice of Intent, proposing an integrated, nationally-consistent approach to the regulation of greenhouse gas and air pollutant emissions in order to protect the health and environment of Canadians. In November and December 2006, extensive consultations were undertaken with the provinces and territories, industry, aboriginal groups, and health and environmental groups on elements of the proposed approach and the development of the regulatory framework. The federal government will set stringent national standards and will work to reach equivalency agreements with those provinces that set provincial emissions standards that are at least as stringent as the federal standards. Both the Canadian Council of the Ministers of the Environment (CCME) and a group of non- government organizations (NGOs) and Industry worked to produce some alternative means of implementation. Eventually the three groups joined in a Tripartite initiative to develop a Comprehensive Air Management System (CAMS) for Canada. The proposed system introduces regional airsheds on a national level working with provincial air zones in a tiered approach to air quality management.

The CASA airshed approach, Alberta’s LUF and the CAMS airshed system each represent three different initiatives using different geographical boundaries and somewhat different modes of

Mechanisms for the Alignment of Air Quality Planning 1 governance. The provincial LU F uses boundaries largely following watersheds. Existing airshed boundaries are not congruent with these planning regions. Some LUF regions contain more than one Airshed, some Airsheds cross LUF regions and large parts of the LUF regions are not served by any existing Airshed. This report examines air quality planning in other jurisdictions and explores some alternatives for aligning existing Alberta Airsheds, LUF regions and CAMS zones.

Mechanisms for the Alignment of Air Quality Planning 2 2.0 AIRSHED BOUNDARIES AND AIR QUALITY IMPACT AREAS

Shortly after its creation, the CASA (1995) published “Zone Air Quality Management Guidelines” fulfilling one of the recommendations in the original Clean Air Strategy for Alberta (1991). This document provided the foundation for the subsequent formation of airsheds in Alberta. The West Central Airshed was forming in parallel with the development of the CASA guidelines and there was considerable interplay between the two groups. Boundaries were to consider a number of factors:

• Biogeography (landforms, watersheds, climate, animal behaviour patterns) • (wind, temperature stratification, turbulence, deposition patterns) • Jurisdictional responsibilities (boundaries of municipalities, national parks, native ) • Pollution receptors (effects on visibility, vegetation, , human health; chemical content of water, and /animal tissues) • Emissions themselves (sources, volumes, types). • Local management factors (land use patterns, industrial users, stakeholder organizations)

Airshed boundaries were to be discrete, obvious and directly related to the air quality concern at hand. It was recognized that political boundaries are the traditional basis for decision-making and that air quality management zones are unlikely to be in alignment. Success would require cooperation and commitment on the part of all participants, who may not be accustomed to working together in this manner.

In 2004, the guidelines were revised, but there was little change in the advice about boundary decisions. It was stated that stakeholders determine the boundaries of the proposed airshed zone using a consensus process and considering the same factors listed in the earlier guidelines. There was some elaboration in that boundaries should “follow natural and obvious markers”.

In 2009 there were eight fully operating airsheds in Alberta, with a ninth in development for the Capital Region. These are shown in Figure 1. Common information available to all airsheds at the time of their formation was a series of deposition maps produced by the Alberta Research Council using a regional scale acid deposition model (RELAD) developed under Alberta Environment’s acid deposition program (Cheng 1994a). Figure 2 is an example of the model output.

Mechanisms for the Alignment of Air Quality Planning 3

Figure 1 Airsheds in Alberta at the end of 2009

Figure 2 Predicted 1990 annual deposition of sulphur in Alberta

Mechanisms for the Alignment of Air Quality Planning 4 2.1 West Central Airshed Society (WCAS)

WCAS has not published an exact legal description of its boundaries, but indicates it is available upon request. The boundaries were recommended by a technical working group that also designed the monitoring program (TWG 1994). The group looked at maps of land use, soil sensitivity, lake sensitivity and distribution of emission sources. The provincial deposition model RELAD was applied to the region and surrounding areas (Cheng 1994b) allowing the consideration of impacts and transports to neighboring regions (Figure 3). The six types of factors outlined in the CASA guidelines were reviewed in finalizing the boundaries (West Central Regional Air Monitoring Committee 1994).

Figure 3 RELAD results for West Central Airshed

In 2003 WCAS revised its northern and eastern boundaries as a result of proposed expansions of the coal-fired electrical generating stations operated by EPCOR at Genesee and TransAlta at Keephills. As part of the approval process for the proposed expansion, the companies were required to develop an air monitoring area proposal in conjunction with a regional ambient air quality monitoring plan. Both facilities proposed to address these requirements through integration with the WCAS. The zonal boundaries were adjusted to include the four power and the area around them as well as several sour gas plants in the area northeast of the original boundaries.

In July 2002, Dr. Warren Kindzierski ((WCAS Newsletter 2002) prepared a report and recommendations for EPCOR and TransAlta on an air monitoring area for power plants in the Genesee-Wabamun area. His report considered a) air monitoring objectives in general, and those of the WCAS in particular; b) emission sources that influence the area and the location of these sources; c) local meteorology; d) locations of populated areas; e) modeled and measured ambient air quality; and f) discussions with stakeholders. Dr. Kindzierski recommended that there is a need to: maintain monitoring capabilities near major emission sources in the air monitoring area,

Mechanisms for the Alignment of Air Quality Planning 5 establish air monitoring capabilities extending eastwards towards urban areas of Edmonton and Leduc, exclude the large urban areas because of the great distance, and the presence and possible confounding of urban source influences).

The report also concluded four key continuous ambient air monitoring stations -- the existing Meadows station, a relocated Power station, and a relocated Wagner station all operated by West Central Airshed Society, and a relocated Genesee station -- should be part of the revamped monitoring network. This would ensure source influences could be accurately detected within the airshed boundaries. Dr. Kindzierski recommended all these stations continuously monitor sulphur dioxide (SO2) and nitrogen dioxide (NO2) as well as meteorological conditions. The Power and Genesee stations should also continuously measure particulate matter 2.5 (PM2.5) with monitoring of PM10 and elemental analysis (metals) on an intermittent basis. The Genesee station would also monitor ozone on a continuous basis (WCAS Newsletter 2003).

2.2 Wood Buffalo Environmental Association (WBEA)

In 1996, the boundaries of the Southern Wood Buffalo Zone were modeled after those of the former Alberta Oil Sands Environmental Research Program (AOSERP) study areas. These boundaries were based on the region of the Athabasca oil sand deposit with a northern extension to include Fort Chipewyan (Township 115). The northern extension was excluded from the Fort McMurray air quality zone as defined: the bottom of Township 84 in the south to the top of Township 104 in the north, and from left of Range 18 in the west to right of Range 6 in the east. Extending the eastern zone boundary to the Saskatchewan border to account for potential long range transport of pollutants and north to Fort Chipewyan were considered but because of access difficulty were excluded at the time (Ft. McMurray RAQCC 1996).

In 1995, the City of Fort McMurray and Improvement District 143 (formerly ID No. 18) were amalgamated to form the Municipality of Wood Buffalo, one of the largest in North America, stretching from north central Alberta to the borders of Saskatchewan and the Northwest Territories. The area covers 68,454 square kilometers. In 1996 the name was changed to the Regional Municipality of Wood Buffalo in recognition of the uniqueness of a municipality with a large urban centre associated with a large rural territory supporting a small population. In 1997, the Wood Buffalo Environmental Association changed its boundaries to match that of the municipality.

The initial design of the monitoring program was based on short-range deposition modelling by Bovar Environmental (1996) as shown in Figure 4.

Mechanisms for the Alignment of Air Quality Planning 6

Figure 4 Predicted sulphur deposition using ADEPT2

2.3 Parkland Airshed Management Zone (PAMZ)

The boundaries of PAMZ are:

North: the top of Township 42; East: Highway 21 South: the bottom of Township 28; West: the Alberta/British Columbia border.

These boundaries were chosen based upon the following criteria (PAMZ 1999).

• A large number of stakeholders in the region interested in pursuing the zonal air quality monitoring approach • Emission sources;, associated impacts and concerns;, and stakeholders are all located in a specific geographical area • Multiple emission sources are present within the area including sour gas plants, sweet gas plants, oil and gas batteries, forestry activities, chemical and other manufacturing firms, • Several areas of high population density are located in the area, especially one city (Red Deer), • Vehicular emissions from a major transportation corridor (Highway 2) exist, • Agricultural activities and natural emissions also contribute to air quality in the area

Mechanisms for the Alignment of Air Quality Planning 7 • Atmospheric transport within the proposed zone boundaries has been quantified by air quality modeling exercises

The Regional Air Management Investigation Team (RAMIT) was formed in 1994 to investigate the possibility of a zone in the Sundre, Caroline, Rimbey, Rocky Mountain House area. A year later RAMIT recommended the area proceed with the formation of a Regional Airshed Management Zone. As a result, PAMZ was formed in April 1997. In developing the boundaries, the team considered maps of emissions sources; maps of predicted air quality in the Shell Caroline Environmental Assessment; maps of deposition estimated for the West Central Airshed; and some multiple plume modelling that had been done for the area as shown in Figure 5 (Kevin Warren 2010 personal communication).

In March 2000 Northeast Zone Boundary was expanded from the top of Township 42 to the top of Township 44 to allow the Gulf Rimbey Plant to participate in the Management Zone and be part of the application to collapse their compliance monitoring. The change also aligned the northern boundary of PAMZ to be largely coterminous with that of the David Thomson Health Region.

Figure 5 Predicted annual average sulphur dioxide using a multiple plume model

Mechanisms for the Alignment of Air Quality Planning 8 2.4 Fort Air Partnership (FAP)

The boundaries of the FAP airshed can be described as:

North: Through the town of Newbrook, approximately 20 kilometres north of the Town of Redwater East: Highway 834 South: Highway 16 to the Edmonton city limits West: Edmonton city limits north and west to 97 Street/Highway 28 and then straight north along that road.

The boundaries were based on a consideration of: existing emissions data and air quality monitoring data; the potential effects of air pollution on human/animal health-related air quality modeling results; the proximity of Elk Island National Park; and the proximity of the City of Edmonton as a pollution source. Since the original intent was to establish airshed boundaries based on the influence of sources within the Fort Saskatchewan region; emissions from the City of Edmonton were not included in the dispersion modeling. The FAP airshed boundaries were determined based on public concerns with air quality; air quality monitoring; and ambient air modeling information. The contour map (Figure 6) representing one-half of the one-hour ambient air quality guideline for SO2 (e.g. 225 ug/m3) was a major factor in setting the boundary for the airshed (Technical Working Group 2001).

2.5 Peace Airshed Zone Association (PASZA)

The boundaries of the PASZA can be described as follows (PASZA Bylaws 2008):

North: Follows the Peace River to the town of Peace River; then follows the northern boundaries of the MD of Smoky River and the MD of Big Lakes. East: Follows the eastern boundary of the MD of Big Lakes south to TWP RD/line 670. South: Follows TWP RD/line 670 west to RR/line 140, then south to TWP RD/line 650. West: Follows the Alberta – British Columbia provincial boundary from TWP RD/line 650 north to the Peace River.

The Peace Airshed Zone covers a 38,500 square kilometer area of northwestern Alberta. The area stretches from the Peace River south to the top of Township 64 and includes the area’s two major population centres, Grande Prairie and High Prairie. Approximately 85,000 people live and work in this area. The zone's major industries are oil and gas processing, forestry, agriculture and tourism. It does not appear that any air quality modelling was done for this airshed. Boundaries followed natural features and administrative areas (Kevin Warren 2010, personal communication).

Mechanisms for the Alignment of Air Quality Planning 9

Figure 6 Predicted one-hour ambient sulphur dioxide concentrations in FAP area.

2.6 Palliser Airshed Society (PAS)

The PAS airshed is comprised of a region encompassing a population of approximately 53 000 people, including the City of Medicine Hat and the Town of Redcliff. The total area of the airshed is approximately 150 square kilometers. The PAS boundaries were determined based on air quality issues of the region and were evaluated utilizing results from air quality modeling for Medicine Hat Power and Canadian Fertilizers (Bob Scotten 2010 personal communication). Prior to the formation of PAS, the City of Medicine Hat had been performing some ambient air quality monitoring in association with the approval for the City’s power plant. With the formation of PAS, the airshed has increased its monitoring abilities to include 6 Passive Monitoring sites and one air monitoring trailer; housing continuous monitors to analyze for NO2, ozone (O3), total hydrocarbons (THC), meteorological parameters, and PM2.5.

In 2006, the Palliser Airshed zone expanded its boundaries to be coterminous with the Palliser Health Authority. The airshed now encompasses approximately 40,000 km2, and includes a population of about 100,000 people. A monitoring plan was developed based on the expansion and additions to the existing monitoring program include: a portable monitoring station intended to relocate once every six months; and a 20 station passive network.

Mechanisms for the Alignment of Air Quality Planning 10 2.7 Lakeland Industry & Community Association (LICA)

LICA began as one of the many Synergy Groups (Bisaga 2010 personal communication) established during the 1990s to establish a dialogue between energy developers and communities (SynergyAlberta website). Today, LICA is an umbrella organization overseeing both the LICA Airshed Zone and the Beaver River Watershed Alliance. The LICA boundaries can be described as (LICA website and 2007 Bylaws):

North: Northern edge of the Cold Lake Air Weapons Range East: 4th Meridian (Saskatchewan border) South: Highway 45 West: western edge of the Municipal District of Bonnyville # 87 and the County of St Paul #19 and at the North Saskatchewan River Bridge on Secondary Highway 881, south to Highway 45

The LICA air quality monitoring network currently consists of 25 passive stations monitoring monthly average ground-level concentrations of SO2 at all sites and three stationary multi- parameter continuous stations that were deployed using a high, medium, and low effects scheme based on predicted ground concentration. The high effects station is near Imperial Oil Maskwa facility. This site is representative of the northern part of the LICA region, which is characterized by steam assisted in-situ bitumen production. This site also provides a historical link to air quality prior to formation of the LICA Airshed Zone. Located in Cold Lake South, the medium effects station was brought on-line in late October 2005. Most of the region’s population in and around the City of Cold Lake. Air dispersion modelling indicates this is an area of lower SO2 compare to other areas in the zone. However, the high (relative to the region) NO2 ground- level concentrations warrant monitoring in this area. The low effects site is located at St. Lina where modelling predicts low ground-level concentrations of both SO2 and NO2. (RWDI 2008; Jacques Whitford 2003, 2006). Predicted annual average SO2 concentrations are shown in Figure 7 .

2.8 Calgary Region Airshed Zone (CRAZ)

CRAZ encompasses an area that approximately follows the boundaries of the Calgary Health Region except for the northern border which is defined by the southern border of the Parkland Airshed Management Zone (PAMZ). The Calgary Health Region’s boundaries were largely based on municipal boundaries. The airshed includes the City of Calgary, M.D. of Foothills No.31, Vulcan County, and Kananaskis Improvement District. Portion of the: M.D. of Rockyview No. 44 south of township 28 (80%); M.D. of Bighorn No. 8 south of township 28 (53%); Wheatland County south of township 28 (99%); I.D. No. 9 Banff National Park south of township 28 (32%); and the M.D. of Willow Creek No. 26 north of township 10 (64%) are included in the airshed. The remaining areas of the five municipalities mentioned previously are contained within the boundaries of PAMZ. The only exception is the southern third portion of the M.D. of Willow Creek which is not covered by any airshed (Amarok 2007). All towns, villages, and hamlets located in the area are contained within the CRAZ airshed along with the Siksika, Eden Valley, Tsuu T’ina, and Stoney First Nations. The design documents (Amarok 2007) include modelling for SO2, NO2 and total suspended particulates (TSP). An example of the maximum daily NO2 concentrations for CRAZ is provided in Figure 8.

Mechanisms for the Alignment of Air Quality Planning 11

As CRAZ establishes itself, the group is trying to develop an ambient air monitoring plan to provide regional ambient air information. This approach must also consider all of the various areas found within the boundaries of CRAZ such as mountainous areas and valley situations. At the same time, the monitoring plan must also encompass rural and urban areas that both support industrialized areas.

Figure 7 Predicted annual average sulphur dioxide concentrations in LICA area.

Mechanisms for the Alignment of Air Quality Planning 12

Figure 8 Maximum daily nitrogen dioxide concentrations in CRAZ area.

2.9 Alberta Capital Airshed Alliance (ACAA)

ACAA has rather irregular boundaries, which can be broadly described as:

Northeast: southwest boundary of FAP South: almost the northern boundary of PAMZ West: eastern boundary of WCAS

A full description of the boundaries is much more complicated (ACAA website):

• East from Edmonton Along Hwy 16 to the eastern boundary of Strathcona County • South along Strathcona County Line to Leduc County • South along Leduc County Line to southern limit • West along Leduc County Line to Hwy 795 (WCAS Boundary) • North along Hwy 795 to intersection of Hwy 39 • Directly north of Hwy 39 to Hwy 627 • West along Hwy 627 to intersection of Hwy 777 • North to connect Hwy 777 and continued north to Northern Edge of Lac Ste. Anne County • East along County Line to Sturgeon County • East along Sturgeon County Line to northern extension of Edmonton 97th St. (Hwy 28) (FAP Boundary) • South to Edmonton city limit • Clockwise around city to Hwy 16

Mechanisms for the Alignment of Air Quality Planning 13 ACAA has not yet assumed responsibility for the operation of monitoring stations, but has been engaged in the development of a Particulate Matter and Ozone Management Plan. In 2008, ACAA received funding from Health Canada’s Healthy Environments and Consumer Safety Program to complete an air monitoring network assessment. The existing ambient air monitoring network within the airshed will be evaluated and recommendations for any necessary improvements will be reported. Currently, the network consists of ten continuous air monitoring stations including three operated by Alberta Environment, two by Lehigh Inland Cement, and five by the Strathcona Industrial Association. The report to be submitted to Health Canada will describe current emission inventories, current continuous and passive monitoring programs, and any shortcomings in air quality information or technical requirements. The goal is to develop a plan for a state of the art air monitoring network that provides comprehensive, accurate and reliable information to decision-makers for air quality management and control.

2.10 The Role of Airsheds

Airsheds were originally conceived for the purposes of air quality management within a defined zone to address local air quality problems. The issues were to be addressed by developing and implementing an appropriate management plan. Assessing impacts, monitoring ambient air quality, compiling emissions inventories, modelling air quality, and examining ambient air quality trends were all seen as work required to establish management goals, define options, set objectives, select an approach, prepare an implementation plan and evaluate success (CASA 1995). Over time, the primary reason for most airsheds being created was for the purposes of monitoring air quality and communicating the results. This was reflected in the revised CASA airshed zone guidelines (CASA 2004).

In response to the Canada-Wide Standards for PM and O3, the role of the airshed were to move beyond simply monitoring ambient air monitoring. In 2000, Alberta signed onto adopting the CCME Canada-Wide Standards (CWS) for PM and O3 . CASA developed an implementation plan for the CWS in the form of the PM and Ozone Management Framework at the request of AENV. The Framework consists of a three tiered response dependent upon the magnitude of ambient levels at the monitoring stations within an area. Annual air quality assessments determine the actions required.

In November 2006, Alberta Environment notified the Edmonton, Calgary and Red Deer areas of the need to develop air quality management plans. The trigger level for the development of management plans for ozone were reached in the framework based on the 2001-2003 particulate matter and ozone assessment. As a result, the three regions and associated airsheds were responsible for developing and implementing an ozone management plant. The affected airsheds in Northern Alberta -- ACAA, WCAS and FAP -- formed a partnership to develop a management plan for the Edmonton and surrounding area. PAMZ developed a management plan for the Red Deer region. CRAZ developed a plan for the Calgary region. Airsheds submitted their respective plans to AENV in December of 2008.

Mechanisms for the Alignment of Air Quality Planning 14 2.11 Summary

Airshed boundaries are determined with consideration of a number of geopolitical factors. The complex balancing is often difficult to articulate and record. Predicted air quality impacts (concentrations and depositions) provide an objective anchor for both boundary decisions and monitoring network design. Documentation is somewhat difficult to acquire since there is no consistency in how each airshed documented its development. A few have at least partial historical information published on the website, but several give very little information. Requests for additional information are not always unanswered. Recently five airsheds have undertaken the preparation of air quality plans under the CASA PM and Ozone Management Framework. Management planning was enabled in 1995 under the Zone Guidelines, but was not exercised until the 2006 triggering of the Management Plan Level under the CASA PM and Ozone Management Framework.

Mechanisms for the Alignment of Air Quality Planning 15 3.0 ALBERTA’S LAND USE FRAMEWORK

Originally published in December 2008, legislative authority for implementation of the Land Use Framework came in the spring 2009 session of the Alberta Legislature. The Alberta Land Stewardship Act (ALSA) was passed and received Royal Assent on June 4, 2009. The Act was not proclaimed until October 1, 2009. ALSA requires Regional Plans to be developed through Regional Advisory Councils consisting of individuals representing the range of interests within each region, and who are able to appreciate the broad interest of the region. Regional plans will be approved by Cabinet and implemented through line departments and the Land Use Secretariat. The Land Use Framework (LUF) consists of the following seven strategies to improve land-use decision-making in Alberta:

• Develop seven regional land-use plans based on seven new land-use regions • Create a Land Use Secretariat and establish a Regional Advisory Council for each region • Cumulative effects management will be used at the regional level to manage the impacts of development on land, water and air. • Develop a strategy for conservation and stewardship on private and public lands • Promote efficient use of land to reduce the footprint of human activities on Alberta's landscape • Establish an information, monitoring and knowledge system to contribute to continuous improvement of land-use planning and decision-making • Inclusion of Aboriginal peoples in land-use planning.

The seven Land-Use Framework planning regions are named after the major watersheds and are shown Figure 9.

On July 31, 2009 the Terms of Reference for the Lower Athabasca Regional Advisory Council were released (GoA 2009a). The terms of reference outline production scenarios and conservation goals. The advisory council will look at: implications of different levels of oil sands production --including effects on the air, , land and water; communities’ population growth and labour force needs; and the effect on the forestry industry; options for increasing the amount of conservation areas securing boreal in the region; options for developing the recreation and tourism industry; the general location of transportation and utility corridors; and impacts of development on Aboriginal communities. This is the first regional plan to be developed and much will be learned for the development of later plans.

On November 26, 2009, the Terms of Reference for the South Saskatchewan Regional Advisory Council were released (GOA 2009b) The council’s advice will reflect expected population growth of two million in the region by 2076 and that , efficiency and productivity will improve by a minimum of 30 per cent. In its consideration of development scenarios, the advisory council will look at: objectives for the agriculture, energy, forestry and recreation and tourism sectors, which should aim for all industries to be successful; options for improving source water protection and other management means to protect watershed integrity;

Mechanisms for the Alignment of Air Quality Planning 16 ways to reduce human footprint and reduce fragmentation of valued ; locations for recreation and tourism lands; and which lands could meet the criteria for conservation, considering development implications. The terms of reference also identify provincial policies and guidelines that will be integrated through the regional plan.

Figure 9 The seven land-use framework planning regions in Alberta.

Mechanisms for the Alignment of Air Quality Planning 17 4.0 CANADA’S COMPREHENSIVE AIR MANAGEMENT SYSTEM

Under the proposed Comprehensive Air Management System (CAMS) being developed through a multi-stakeholder process including the federal government, several provinces, industrial and NGO stakeholders; air management would occur at two scales: regional airsheds and air zones. Regional airsheds will be delineated mainly by the federal government and the air zones will be delineated by the provincial/territorial governments. While air zones would lie within a single province/territory and manage local air quality, regional airsheds are geographically broader areas which encompass a number of air zones and cross domestic and international jurisdictional boundaries. They would serve as a basis for coordinating the management of transboundary air quality issues (AZMRA 2010).

An air zone is defined as a finite area exhibiting similar air quality issues and challenges throughout the air zone, with a size effective for air quality management. Collectively these air zones will cover all of Canada. Their boundaries should be well-defined and follow natural or obvious boundaries. To facilitate air quality management, air zone delineation could incorporate socioeconomic and jurisdictional considerations such as municipal/provincial boundaries, postal code areas, counties, population density, number of sources, geography, similarity in air quality issues or challenges. Political boundaries could also be used to allow for support and authority for action. Criteria to delineate air zones can be broadly defined as geographical, practical, socioeconomic, and meteorological.

The province has the ultimate responsibility to ensure air zone management activities take place where needed. The province also has the flexibility to delegate functional responsibilities to an Air Zone Management Team (AZMT) where active air quality management is required. Stewardship of local air quality could then reside with the AZMT, which is intended to be a multi-stakeholder community team working in an open and transparent way to establish a sense of shared responsibility within the air zone.

To complement the activities focused on air zones, regional airsheds would coordinate action between jurisdictions. Airsheds in this context are defined as parts of the atmosphere exhibiting similar characteristics with respect to the movement and dispersion of air pollutants. Six regional airsheds were proposed across the country as shown in Figure10.

There are two elements of this proposal with significant implications for Alberta’s existing airsheds: (1) the entire province must be covered by CAMS air zones, and (2) the province may delegate functional responsibility for air zones to a multi-stakeholder AZMT. The criteria for defining air zone boundaries are quite similar to the criteria for CASA airsheds. The possible roles for an AMZT are similar to the original roles outlined for CASA airsheds.

Mechanisms for the Alignment of Air Quality Planning 18

Figure 10 Regional airsheds under CAMS (AZMRA 2009).

Mechanisms for the Alignment of Air Quality Planning 19 5.0 PLANNING IN OTHER JURISDICTIONS

A selection of jurisdictions in North America, Europe and Australasia was surveyed with respect to air quality planning approaches and use of airsheds.

5.1 North America

In Canada, airsheds for monitoring exist in Alberta and Saskatchewan, airsheds for planning exist in British Columbia and Alberta, airsheds for studies exist in Ontario and federal government cross-border initiatives. British Columbia provides extensive guidance for airshed planning. The United States uses several different methods for air quality planning. The State of California is well known for its use of airsheds.

5.1.1 British Columbia

In British Columbia, an airshed is defined as “an area where the movement of air (and related pollutants) tends to be limited by topography or meteorology. An example is a valley where surrounding mountains trap air pollution.” Airshed plans are in place for 9 provincial areas: Bulkley Valley-Lakes District (BVLD), Fraser Valley Regional District (FVRD), Greater Vancouver Regional District (GVRD), Prince George, Quesnel, Regional District of North Okanagan (RDNO), Regional District of Okanagan-Similkameen (RDOS), Whistler, and Williams Lake. British Columbia recognizes the responsibility for protecting air quality is shared among local, regional, provincial, and federal governments, as well as international jurisdictions. The Province has primary authority to develop air quality standards and guidelines, regulate point and area sources, and require the preparation of area based management plans.

The British Columbia Framework for Airshed Planning (2007) identifies six stages:

1. Evaluate the need for a plan 2. Identify and engage stakeholders 3. Investigate planning synergies 4. Determine priority 5. Develop the plan 6. Implement, monitor and report.

For each stage, the framework outlines what is involved and how the BC Ministry of Environment can help, examples being: air monitoring data and data interpretation, partnership funding, technical support, facilitation, emissions inventory, GIS, air quality modelling, identification of outside experts to help, implementation where it has responsibility, annual meeting of airshed planners, annual status report on airshed planning. Stages 2 and 3 are most relevant for the purposes of this study and key excerpts (BC Ministry of Environment 2007) are given below:

Mechanisms for the Alignment of Air Quality Planning 20 Participation At a minimum, agencies with a regulatory responsibility (e.g., provincial and local government), major emission sources, and organizations representing community interests should be involved in the planning process. Health agencies are a useful ally in communicating air quality health risks to local decision-makers and the public. Inclusion of those with facilitation or communication skills is beneficial, as either committee members or paid contractors. For the BVLD and Whistler plans, contracted facilitators played a pivotal role in providing continuity to the planning process as well as secretariat- level support. In some instances, key stakeholders may be unwilling or unable to participate. At the least, they should be included on a distribution list of planning related materials. Overall membership will need to be balanced with the committee’s ability to make decisions in a timely manner, recognizing that, generally, the larger the committee the longer the decision-making process.

Determining Airshed Boundaries An essential early task for airshed planning is to delineate the airshed. While in theory an airshed is determined in relation to the dispersion of pollutants, in practice it is often defined instead by political boundaries, to reflect the area in which there is support and authority for action.This could be based on municipal boundaries or on regional ones – where there are common issues requiring solutions across a broader area. Planning exercises to date have defined their airsheds in terms of municipalities (Prince George, Whistler), regional districts (FVRD, GVRD, RDOS, RDNO), and multiple regional districts (BVLD, Sea-to-Sky Corridor). .

Identify related planning processes Of particular interest is the overlap between three air related planning processes that occur at the local level: airshed plans, GHG action plans, and community energy plans (CEPs). A study (Holland Barrs 2004) for the Ministry found that there were substantial similarities among these processes, especially where the main source of air emissions was fossil-fuel-based energy consumption.

Determine the merits of an integrated approach The above study identified a number of potential benefits to integrated planning. These include a full consideration of synergies and tradeoffs between planning processes, more robust solutions when multiple objectives are considered, greater efficiency in the use of resources, and reduced consultation fatigue. At the same time, some challenges were noted, including the possible dilution of focus and support, technical difficulties in creating combined inventories, and the ability to secure required technical expertise. The community or region will have to weigh these relative benefits for its particular airshed.

An integrated approach will be less effective from an air quality perspective where the critical air issues facing the community are not a central concern in other planning processes. For example, open burning is a large source of PM emissions and hence a health concern, but is not counted as a source of GHG emissions (assuming that the wood is from sustainable ). The success of Whistler’s integrated plan was due to the fact that most of the GHG and air quality issues flowed from energy consumption. Planning

Mechanisms for the Alignment of Air Quality Planning 21 integration may also not be feasible if the community considers that the process may be too broad or overwhelming. However, any plans developed should at least be complementary, in order to avoid conflicts among airshed, GHG, community energy, and other planning objectives.

A background document (Williams and Battacharyya 2004) provides additional information on other community planning processes:

Many local governments are already involved in numerous planning processes that may address community development, growth, transportation and other infrastructure, as well as energy use. However, with some exceptions, air quality planning is rarely undertaken separately or even included in these ongoing planning processes. Yet much of this planning can have a direct impact on local and regional air quality and contribute to global air concerns such as climate change and ozone layer depletion. In some instances the authorities may be developing plans that will inadvertently degrade air quality within the airshed, while at the same time meeting other local objectives.

Regional growth strategies, developed at the regional district level, address critical issues that cannot adequately be addressed by individual municipalities. They provide local government with a strategic planning vision for achieving common economic, social and environmental goals. Goals of continued growth while maintaining a current or better standard of living often do not consider air emissions. Emissions from vehicles and industry may be on the agenda but these must be considered in a broader airshed-wide context.

Official community plans (OCPs) guide all development, land-use and transportation activities in an area. Although rarely considered, these plans have a significant impact on future air emissions within a community. OCPs identify where significant emission sources may be situated. In addition, a community’s growth and development will often have significant impact beyond political boundaries when air emissions are considered. Additional municipal planning functions incorporate expansion in population and the industrial tax base, and ensure that adequate infrastructure is maintained. Rarely, if ever, are air emissions resulting from municipal planning decisions considered. In recent years some communities have developed community energy plans (CEPs) in an effort to address community energy supply, demand and overall costs. Many of the decisions made about how or what source of energy supply a community will use, or how to become more energy efficient, can have a positive impact on air emissions and overall airshed health.

5.1.2 United States

In the 1950s, the United States (US) began its effort to understand the scientific complexity of air pollution problems and to develop an effective air quality management system. The first major efforts of the US federal government began with the Air Pollution Control Act of 1955, which provided funds to local and state agencies for research and training. The Clean Air Act (CAA) of 1963 and the Air Quality Act of 1967 set Air Quality Criteria, Air Quality Control Regions

Mechanisms for the Alignment of Air Quality Planning 22 (AQCRs), and the process for State Implementation Plans (SIPs). This framework was further developed and refined with the passage of the CAA Amendments in 1977 and 1990. The CAA prescribes a complicated set of responsibilities and relationships among federal, states, tribal, and local agencies. The federal government coordinates efforts through the United States Environmental Protection Agency (EPA) and sets national air quality standards and approaches to pollution mitigation. This provides a basic level of environmental protection to all individuals in the U.S. States. Local governments can then develop, implement, and enforce specific strategies and control measures to achieve the national standards and goals. Although many aspects of the Air Quality Management system assume a collaborative relationship between the federal, state, and local agencies, the CAA empowers the EPA to oversee the activities carried out by these agencies. In addition, the federal courts also have a role in Air Quality Management (AQM) as final agency rules promulgated under the CAA are subject to judicial review and any citizen may file a civil action against EPA.

On the basis of national ambient air quality standards (NAAQS) and monitoring data, areas are designated as attainment, nonattainment, or unclassifiable, and on that basis become air quality control regions (AQCRs). Each AQCR, which can be areas within a state or areas straddling a number of states, is required to submit a SIP. Two separate types of SIPs are developed: an attainment maintenance SIP if the AQCR is designated as an attainment area and an attainment- demonstration SIP if designated as a non-attainment area.

The CAA gives each State the primary responsibility for assuring air quality within the entire geographic area comprising the State. For purposes of administering the AQM system, the CAA adopted the AQCRs which were previously designated under the Air Quality Act of 1967. The 1990 CAA Amendments updated the boundaries of AQCRs and a number of major intrastate areas were grouped into one AQCR. Within 1 year after promulgation of new or revised NAAQS, States are required to submit to the EPA a list of initial area designations for the AQCRs under their jurisdiction. Upon receiving a list of initial area designations and consulting with the State authorities, EPA announces final area designations within 2 years of promulgation of the NAAQS.

Under the US system, 1990 CAA Amendments required implementation of multistate air pollution mitigation strategies through the creation of regional planning organizations (RPOs). By issuance of EPA and voluntary adoption by States, rules and regulations of RPOs can be mandated and hence counted towards developing attainment-demonstration strategy. Also, any State or political subdivision can petition EPA if it suspects emissions from major stationary sources in upwind States contribute significantly to nonattainment (or interfere with maintenance). If EPA makes such a determination, it can impose additional regulatory measures for the emitting State (for example, the NOx SIP Call for ozone NAAQS).

SIPs are submitted to EPA for review to check if the plan meets its requirements. If EPA approves the plan, the SIP becomes enforceable as a matter of Federal and State law. As a result, the SIPs can be subject to lawsuits for failure to comply. EPA can disapprove a SIP if it does not meet the procedural and substantive requirements, and require a resubmission with revisions. A SIP is also subject to change in order to reflect new federal or state requirements, new information, or change in status of NAAQS attainment. Likewise, SIP revisions must be

Mechanisms for the Alignment of Air Quality Planning 23 reviewed and approved by EPA before it is enforceable. If a state fails to generate a SIP, then EPA has the power to control the air quality management programs for that state or area. In extreme cases where the state has an inadequate SIP or fails to implement its SIP, EPA can replace a SIP with a federal implementation plan (FIP).

Because the pollutants leading to regional haze can originate from sources located across broad geographic areas, EPA has encouraged the States and Tribes across the U.S. to address visibility impairment from a regional perspective. Today, EPA provides funding to five regional planning organizations (as discussed below) to address regional haze and related issues. These organizations will first evaluate technical information to better understand how their States and Tribes impact national park and areas (Class I areas) across the country. The planning organizations will then pursue the development of regional strategies to reduce emissions of particulate matter and other pollutants leading to regional haze.

Western Regional Air Partnership (WRAP) WRAP is a voluntary organization of western States, Tribes and Federal agencies. It was formed in 1997 as the successor to the Grand Canyon Visibility Transport Commission, which made over 70 recommendations in June 1996 for improving visibility in 16 national parks and wilderness areas on the Colorado Plateau. The Partnership promotes, supports and monitors the implementation of those recommendations throughout the West. WRAP is also implementing regional planning processes to improve visibility in all Western Class I areas by providing the technical and policy tools needed by States and Tribes to implement the federal regional haze rule. WRAP is administered jointly by the Western Governors' Association (WGA) and the National Tribal Environmental Council (NTEC). WRAP recognizes residents have the most to gain from improved visibility and many solutions are best implemented at the local, state, tribal or regional level with public participation.

WRAP is made up of Western States, Tribes and Federal agencies. The states are Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming. Tribal board members include Campo Band of Kumeyaay Indians, Confederated Salish and Kootenai Tribes, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Native Village of Shungnak, Nez Perce Tribe, Northern Cheyenne Tribe, Pueblo of Acoma, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort Hall. Representatives of other tribes participate on WRAP forums and committees. Participation is encouraged throughout the Western States and Tribes. Federal participants are the Department of the Interior (National Park Service and Fish & Wildlife Service,) the Department of Agriculture (Forest Service), and the EPA.

WRAP’s committees and forums seek consensus among the governmental partners and stakeholders including large and small businesses, academia, environmental groups and other public interest representatives. Scientific findings and policy options are presented to policy makers and the public for appropriate discussion and response. The WRAP is committed to bringing together all those who may contribute to or be affected by poor air quality. Findings and policy options go before the WRAP Board.

The Western Governors’ Association in Denver and the National Tribal Environmental Council in Albuquerque receive funding from the U.S. EPA to administer and support WRAP and its

Mechanisms for the Alignment of Air Quality Planning 24 committees and forums. The majority of the work is done by individuals serving on WRAP committees and forums, with assistance from staff and outside contractors. Work plans are prepared by WRAP forums and work products are reviewed by the forums and the co-directors. WRAP recognizes the great contribution from organizations and individuals who contribute often un-reimbursed time and effort to committee and forum work. WRAP’s success depends on the participation of concerned and informed participants who devote time and energy to this endeavor. Committees and forums are continuously accepting applications for a number of appointments.

Central Regional Air Planning Association (CENRAP) CENRAP is an organization of States, Tribes, Federal agencies and other interested parties identifying regional haze and visibility issues along with develops strategies to address them. CENRAP includes the States and Tribal areas of Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and Louisiana. CENRAP promotes policies that ensure fair and equitable treatment of all participating members; provides coordination of science and technology to support air quality policy issues in the central region; recommends strategies on air quality issues for use by member States and Tribes in developing implementation programs, regulations and laws; conducts research and undertakes other activities as necessary for information to support the development of sound state and tribal air pollution policies. CENRAP is incorporated as a not-for- profit corporation under the laws of the State of Oklahoma.

Midwest Regional Planning Organization (Midwest RPO) The Lake Michigan Air Directors Consortium (LADCO) is a non-profit organization established by the States of Illinois, Indiana, Michigan, and Wisconsin. The EPA is a non-voting member of LADCO. The Midwest RPO is a similar entity led by the LADCO States, as well as the State of Ohio and the federally-recognized Tribes in Michigan and Wisconsin. The EPA and Federal Land Managers (FLM) - e.g., National Park Service, U.S. Fish & Wildlife Agency, and U.S. Forest Service – are non-voting members of the Midwest RPO.

The main purpose of LADCO is to provide technical assessments for and assistance to its member states on regional air quality problems, including ozone, fine particles, regional haze, and air toxics. LADCO also provides a forum for its member states to discuss regional air quality issues. The Midwest RPO has a similar purpose, but is focused on visibility impairment due to regional haze in the Federal Class I areas located inside the borders of the five states. The Midwest RPO also focuses on the impact of emissions from the five states on visibility impairment due to regional haze in the Federal Class I areas located outside the borders of the five states.

LADCO consists of a Board of Directors (i.e., the State Air Directors), a technical staff, and various workgroups (i.e., monitoring, data analysis, emissions, modeling, public affairs, and training). The Midwest RPO has a similar structure, but, as noted above, includes Tribal and FLM representation.

In 1989, the States of Illinois, Indiana, Michigan, and Wisconsin, and the EPA signed a Memorandum of Agreement establishing the Lake Michigan Ozone Study and identified LADCO as the organization to oversee that study. Additional MOAs were signed by the States in

Mechanisms for the Alignment of Air Quality Planning 25 1991 (to establish the Lake Michigan Ozone Control Program) and January 2000 (to broaden LADCO’s responsibilities). In October 2000, the LADCO States and the State of Ohio signed a Memorandum of Agreement establishing the Midwest RPO. In March 2001, the operating principles for the Midwest RPO, which describe the roles and responsibilities of States, Tribes, Federal agencies, and stakeholders, were agreed. LADCO receives funding from EPA and the States. In addition, the LADCO member states contribute considerable in-kind resources to support various technical activities.

Mid-Atlantic/Northeast Visibility Union (MANE - VU) MANE-VU was formed by the Mid-Atlantic and Northeastern States, Tribes, and Federal agencies to coordinate regional haze planning activities for the region. The group includes Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, Northern Virginia, and suburbs of Washington, D.C. MANE-VU was formed to encourage a coordinated approach to meeting the requirements of EPA’s regional haze rules and reducing visibility impairment in major national parks and wilderness areas in the Northeast and Mid-Atlantic region. MANE-VU provides technical assessments and assistance to its members, evaluates linkages to other regional air pollution issues, provides a forum for discussion, and encourages coordinated actions. MANE-VU also facilitates coordination with other regions. MANE-VUs structure includes a board comprised of State and Tribal Commissioners/Secretaries, air program directors and two committees comprised of agency personnel. The first is a Technical Support committee to assess the nature of regional haze, the sources that contribute to regional haze and the technical tools States will use to develop their programs. The second is a Communications Committee to develop outreach messages and approaches.

The Visibility Improvement State and Tribal Association of the Southeast (VISTAS) VISTAS is a collaborative effort of State governments, Tribal governments, and various Federal agencies established to initiate and coordinate activities associated with the management of regional haze, visibility and other air quality issues in the Southeastern United States. Vistas is comprised of: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, West Virginia, the Eastern Band of Cherokee Indians, Knox County, TN. The Knox County, Tennessee, Department of Air Quality Management represents local air pollution control agencies in the southeast.

The agencies participating in VISTAS are committed to a sound and thorough scientific analysis of regional haze problems, development of effective control alternatives for agency consideration, timely delivery of the VISTAS analysis to participating agencies , and stakeholder involvement throughout the evaluation of the regional haze issue. Stakeholders are encouraged to participate at the workgroup level (data, planning, technical analysis) to consider all aspects of the problem and possible strategies..

5.1.3 California

California is currently divided into 15 air basins with an air basin being a land area with generally similar meteorological and geographic conditions throughout. To the extent possible, air basin boundaries are defined along political boundary lines and include both the source and receptor areas. Basins may contain one or more districts, a district being a political body

Mechanisms for the Alignment of Air Quality Planning 26 responsible for managing air quality on a regional or county basis. California is currently divided into 35 air districts. There are two types of districts: (1) Air Pollution Control District (APCD) is a county agency with authority to regulate stationary, indirect, and area sources of air pollution (e.g., power plants, highway construction, and housing developments) within a given county. Each APCD is governed by a district air pollution control board composed of the elected county supervisors; (2) An Air Quality Management District (AQMD) is a group of counties or portions of counties, or an individual county specified in law with authority to regulate stationary, indirect, and area sources of air pollution within the region. Each AQMD is governed by a regional air pollution control board comprised mostly of elected officials from within the region.

5.2 Europe

Two different approaches are used for air quality management in Europe. The concept of airsheds is inherent in the European Union directives and is well illustrated by the elaborate air planning system used in the United Kingdom. Nordic countries generally integrate air quality into their broader planning systems.

5.2.1 European Union (EU)

The EU air quality management regime started in 1980 with a Directive setting air quality limit values (AQLVs) and guide values for SO2 and suspended particulates. Later Directives set limit values for lead, NO2, and ozone. The European Economic Community (EEC) formed in 1956 did not begin to take specific actions with respect to environmental protection until the early 1970s. In fact, the EEC did not get a constitutional basis for acts with respect to environmental protection until 1987. In the meantime, a number of Member States had already developed air quality regimes. Part of the challenge for the EU has therefore been to harmonize not only AQ standards, but also the national systems in place for assessing and monitoring air quality (AQ).

The 1996 Air Quality Framework Directive (AQFD) and its daughter Directives are aimed at establishing a harmonized structure for assessing and managing AQ throughout the EU. The role of the European Commission (EC) includes oversight of the implementation of the EU legislation, including enforcement action if a Member State has not complied with its obligations under the EC Treaty. The European Environment Agency collects data on air quality from the Member States and other European countries and then publishes that information.

Within this structure, the EU Member States are given considerable scope to determine what actions they will take in order to meet their commitment to achieve the AQ standards within their territories. However, the Member States must at the same time implement the other EU-level measures that comprise the overall EU air quality management system. These include controls over stationary sources of polluting emissions to air, such as large combustion plants, industrial installations, and facilities using solvents. Other EU-level measures aim to reduce emissions from mobile sources, such as road traffic, and include technical requirements to limit air emissions from various types of motor vehicles as well as fuel quality standards.

Air quality limit values trigger planning requirements. The AQFD and its daughter Directives establish AQLVs for specific pollutants and the timetables for meeting those AQLVs. For certain

Mechanisms for the Alignment of Air Quality Planning 27 pollutants, temporary margins of tolerance are set and then reduced stepwise, so as to attain the limit value at the end of the determined period. The intensity of the monitoring required under the AQFD depends on the degree to which the zone’s AQ is in compliance with the AQLVs . Zones with a likelihood of an exceedence must be monitored more closely. Zones and agglomerations (zones with populations over 250,000) with pollutant levels over the AQLV plus the margin of tolerance (i.e., an exceedence) are reported to the Commission at the end of each calendar year. AQ management plans or programs must then be developed for those zones to show how they will come into attainment in the future.

Member States are responsible for defining the geographical areas within their territories that will constitute zones for the purpose of AQ monitoring/assessment. This is in addition to all agglomerations with 250,000 or more residents which constitute a special type of zone. If the zone exceeds AQLVs plus the margin of tolerance, an AQ management plan or program must be drawn up. As was suggested, zone boundaries are usually linked to administrative areas within the country. The AQFD requires the Member States to draw up lists of their zones and agglomerations where:

• concentrations of one or more pollutants exceed the LV plus margin of tolerance; • concentrations are above the LV but within the margin of tolerance; and • all levels are below LVs .

If a zone or agglomeration is in exceedence of the AQLV plus the margin of tolerance, the Member State is required to draw up a plan or program for attaining the AQLV within the time limit. Monitoring requirements are also more onerous. The Member State must carry out measurements at fixed sites, either continuously or by random sampling with a large enough number to enable determination of the levels. There is no requirement to draw up a plan or program if a zone or agglomeration is in exceedence of the AQLVs but within the margin of tolerance. Monitoring is still required, but the Member State may use a combination of measurements and modelling techniques. Zones and agglomerations where the levels of pollutants are below the AQLVs do not need plans or programs. In these cases, it is possible to assess levels of pollutants solely by use of modelling or objective estimation techniques.

The EU gives considerable latitude to the Member States to determine how they will meet the AQLVs set in the daughter Directives, and there is little formal guidance on general AQ management and emission control strategies at EU level. The Commission does make efforts to facilitate information sharing among the Member States, e.g., through the committee comprising Member State representatives established under the AQFD Committee. Attention is drawn to the best practices in the area of information sharing.

The AQFD stipulates when the level of a pollutant exceeds, or is likely to exceed, the limit value plus the margin of tolerance due to significant pollution originating in another Member State; the Member State concerned shall consult with one another with a view to finding a solution. The Commission may be present at such consultations. For example, the Ozone Daughter Directive requires neighbouring zones in different Member States either prepare and implement joint short- term action plans, or receive appropriate information about each other’s action plans.

Mechanisms for the Alignment of Air Quality Planning 28 5.2.2 United Kingdom (UK)

Part IV of the 1995 Environment Act requires the Secretary of State to publish a national Air Quality Strategy and also established the system of Local Air Quality Management (LAQM). The Government and the Devolved Administrations published the first National Air Quality Strategy in 1997. The Strategy was revised in 2000 to become the Air Quality Strategy for England, Wales, Scotland and Northern Ireland (AQS). An Addendum to the Strategy was published in February 2003. The Strategy underwent a major review and a revised version was published in July 2007 (DEFRA 2007). The Government has overall responsibility for ensuring the UK meets the various limit values set by the EU AQFD and Daughter Directives. The Government uses data from an extensive UK network of air quality monitoring stations (many of which are operated by local authorities) and modelling to assess compliance with AQS objectives and EU AQLVs (Storey 2008).

The LAQM process places a statutory responsibility on local authorities to review and assess local air quality. If the objectives for the pollutants are not likely to be met then the local authority must declare an Air Quality Management Area (AQMA). The local authorities must then produce an Air Quality Action Plan (AQAP) to work towards meeting the air quality objectives.

Local authorities have carried out three rounds of full air quality review and assessments as well as updating and screening assessments, the last of which was in 2007. Over 200 local authorities had declared AQMAs in England and Wales by the end of 2007 with the majority focusing on traffic-related NO2 and PM. Local authorities are now encouraged to incorporate any traffic- related AQAPs into their Local Transport Plans and many have already done so.

Defining the size and the boundaries of an AQMA has been somewhat problematic. According to the National Society for Clean Air and Environmental Protection (NSCA 2004):

The Environment Act states that “the local authority shall by order designate as an air quality management area any part of its area in which it appears that [the air quality objectives] are not likely to be achieved...”. Taken literally, this means that the AQMA and the area of exceedance are exactly the same. Some authorities have designated AQMAs using the contours produced by dispersion modelling software as their boundaries. However, the majority have used such plots only as a guide, making use of physical features, e.g. roads, property boundaries, to mark out the AQMA. Others have used administrative boundaries, such as electoral wards, and a significant number, mainly in large conurbations, have declared their entire area as an AQMA. While this latter case may not strictly be in the spirit of the Act, it does have some advantages, especially where the urban area (and area of exceedance) is contiguous with neighbouring authorities. This is especially the case in London, where authorities generally cover a small area and where there are few, if any, physical indications of the borders between different areas. In this case, “whole borough” declaration makes good sense. It also circumvents some administrative problems, and is perceived to avoid planning blight. ….the presence of an AQMA can be a useful tool in influencing the kind of development allowed in an area, promoting low pollution developments. Blanket declaration of a

Mechanisms for the Alignment of Air Quality Planning 29 whole borough, where there are only small areas of exceedance, is likely to dilute this effect.

Although NSCA (1999) recommends a technical approach to developing boundaries, the following seven different types of AQMA have been designated by local authorities:

• Linear or “ribbon” AQMAs along individual roads and motorways • Whole borough designations or “blanket” designations • Road network or “matrix” AQMAs encompassing many roads (trunk, major or minor) • Industrial “footprint” AQMAs around a particular industrial process, stack or building • Individual or “spot” AQMA encompassing a single building or property • Regional AQMA encompassing numerous local authorities • Combination of roads (matrix) and land in between roads to produce a “mitten” or “blob” approach.

NSCA (2004) also provides advice on the regional aspects of air quality:

Cooperation and coordination between neighbouring local authorities should be given particular attention throughout the administrative process of declaration, amendment or revocation of AQMAs, particularly where the boundary runs through an urban or residential area. In such cases, authorities using divergent methods and operating on radically different timescales can undermine the confidence of stakeholders. All efforts should be made to coordinate activities and ensure similar approaches, through consultation and joint working. The use of regional groups to exchange information and ideas, and to discuss administrative and technical issues is extremely helpful in this.

From the outset of the LAQM process, and more specifically the process of designating AQMAs, concerns have been raised over the potential for AQMAs to affect local planning processes and cause planning “blight”. As a tool for improving air quality locally, AQMAs are not intended to cause a complete and definitive block on development. The impact of AQMA designations on planning processes are slowly emerging, as applications are refused and appealed on grounds that may include air quality, either entirely or partly. The designation of AQMAs serves to indicate the locations where people are exposed to elevated concentrations of pollutants. Although the designation of AQMAs is a statutory requirement at locations of public exposure; AQMAs are also being used to inform local planning processes. They provide an indication as to those locations where air quality is impoverished, and where development should be sensitive to the need to ensure air quality is not compromised. The impact of AQMAs on local and strategic planning has been summarized (NSCA 2004) as:

Strategic Planning. There is a need for AQMAs to be identified in local plans, unitary plans, transport plans, and any local authority plan where policies and actions may impact on efforts to reduce the air quality concentrations locally. Air quality officers, environmental health professionals and all those involved in facilitating the LAQM process should ensure that the necessary local authority departments are made aware of

Mechanisms for the Alignment of Air Quality Planning 30 any designated AQMAs. Such departments should also be made aware of any subsequent AQMA revocations, amendments or new AQMAs as a result of subsequent rounds of air quality assessment.

Development Control Planning. Individual developments have the potential to affect local air quality concentrations. For example, bus stations or car parks with large movements of vehicles are not best located close to narrow, residential streets. Kerbside residential housing is best avoided along heavily trafficked roads or those experiencing regular and heavy congestion.

Planning Officers are not required to refuse planning proposals as a result of designated AQMAs alone. Air quality considerations, though material in planning terms, are considered together with a long list of environmental and other criteria. Experience so far has not shown air quality considerations to be responsible for determining applications on their own merit.

Local Transport Planning. For many local authorities with designated AQMAs, the Local Transport Plan (and the equivalent in Scotland, Northern Ireland and London) will serve as the main mechanism for improving local air quality through transport and traffic related measures. A Local Transport Plan has the potential to reduce significantly local emissions from traffic, but also to move traffic emissions into locations where air quality may be compromised. It is therefore imperative that AQMAs are considered as specific locations where a focus on improving local air quality must apply. Local authorities may need to put in place measures above and beyond those identified in Local Transport Plans in order to move towards the achievement of air quality objectives. The objective and purpose of air quality action planning is to identify the specific improvements to be made and the necessary schemes required to implement these.

Guidance on Planning and AQMAs has been provided under Planning Policy Statement 23: Planning and Pollution Control (Office of Deputy Prime Minister 2004):

The Government of the UK expects Regional Planning Bodies and Local Planning Authorities to adopt a strategic approach to integrate their land use planning processes with plans and strategies for the control, mitigation and removal of pollution The overall aim of planning and pollution control policy is to ensure the sustainable and beneficial use of land (and in particular encouraging reuse of previously developed land in preference to greenfield sites).Within this aim, polluting activities that are necessary for society and the economy should be so sited and planned, and subject to such planning conditions, that their adverse effects are minimised and contained to within acceptable limits. Opportunities should be taken wherever possible to use the development process to assist and encourage the remediation of land already affected by contamination. Among the matters for consideration in preparing local development documents and taking decisions on individual planning applications are existing action and management plans with a bearing on environmental quality including: Air Quality Management Area Action Plans, inspection strategies and program for contaminated land, River Basin Management Plans, Catchment Abstraction Management Strategies, Catchment

Mechanisms for the Alignment of Air Quality Planning 31 Management Plans, Biodiversity Action Plans, Noise Management Plans and Noise Action Plans, Local Sustainable Development initiatives, Community Strategies, State of the Environment Reports

The Scottish Executive (2002) summarized its expectations of planning in the following paragraph:

The planning system should be responsive to social and economic changes and ensure that a policy framework is established to inform decision making in the public interest. It can play an important role in delivering sustainable development that embraces the goals of economic prosperity, social justice and environmental justice and quality. Development plans should set out a long-term vision with a clear focus, setting out the scale and direction of change. They must guide investment decisions rather than being led by them. They must identify environmental resources that require protection to meet national and international obligations, but they must also take into account local character and identity. They should address local perceptions, community aspirations and seek to identify local development opportunities. This requires a consistent approach that is inclusive rather than exclusive; that anticipates rather than reacts; and that is consistent rather than arbitrary. Development control is a key means by which these objectives and policies are delivered. Organisational and other linkages with development planning must be frequent and direct.

Moreover, the Scottish Executive (2004) has directed that:

Local authorities should integrate air quality considerations within the planning process at the earliest possible stage. To facilitate this they should consider developing supplementary planning guidance or protocols. Although the land use planning system does not offer any quick-fix solutions to areas of poor air quality, it can do much to improve local air quality in the longer term, as well as ensuring in the short term that existing air quality does not deteriorate.

Air quality is capable of being a material planning consideration, in so far as it affects land use. Whether it actually is will depend upon the facts of the case. Wherever a proposed development is likely to have significant air quality impacts, close co-operation will be essential between planning authorities and those with responsibility for air quality and pollution control. The impact on ambient air quality is likely to be particularly important where: the proposed development is inside or adjacent to an AQMA;· the development could result in designation of a new AQMA; and the granting of planning permission would conflict with, or render unworkable, elements of a local authority's air quality action plan.

In looking at development controls, NCSA (2006) advised that:

New developments have the potential to affect air quality. When appropriate, the planning application for the development will be accompanied by an air quality assessment1. Local authorities, as planning authorities, are tasked with determining these

Mechanisms for the Alignment of Air Quality Planning 32 local planning applications against a whole range of social, economic and environmental criteria. Air quality may be one of the material considerations, which local authorities have a duty to take into account, as part of the local planning and development control decision-making processes. … AQMAs have a particularly important role to play in evaluating the significance of the air quality implications of new developments.

A new planning system emerged in England and Wales in late 2004. The enacted Planning and Compulsory Purchase Act 2004, replaced much of the Town and Country Planning Act 199016. The provisions in the new Act are intended to provide a more flexible plan-making system at the regional and local level, with more community involvement and an improved development control process. The 2004 Act has abolished Structure Plans and Local Plans, replacing them with Local Development Frameworks (LDFs) and Local Development Documents (LDDs), which must have regard to the Regional Spatial Strategy (RSS). Fundamentally, the Act introduces a more strategic spatial approach to planning.

Under Scottish Planning Policy (2002) planning authorities are legally required to consult community councils and certain statutory bodies before granting planning permission for particular classes of development. In addition the wider public has a right to view and comment to the planning authority on any application. Planning authorities are expected to respond to comments and objections received to explain what decisions have been taken and why. Public interest in planning extends beyond those most directly affected by a proposal to the wider community. Legislation provides for registers of all planning applications to be available for public inspection. In addition, applicants for planning permission are required to notify their proposals to owners and occupiers holding an interest in neighbouring land.

In the Guide on LAQM Consultation, NSCA (2000) makes this observation about policy boundaries:

• Though focusing on participation in air quality management, this guide has also highlighted the need to make concrete links with transport and land use planning, perhaps also with other areas of local authority activity and activities by those such as health authorities. At the very least, an air quality plan should not be launched without at least asking whether others exist for the area being addressed, are in development or are planned. Nothing destroys public confidence more than when a local authority is seen to be working against itself. • Though practical integration on the ground can be difficult and time-consuming, it can also, potentially, be time- and resource-saving. At the same time, there is little value in the lowest common denominator approach of always deferring an air quality strategies until every other plan is integrated with it! In addition, action plans prepared for Air Quality Management Areas will have statutory and guidance deadlines imposed on them. • A lack of full integration should never be used as an excuse for not starting a process, but great care needs to be used in presenting this to participants.

Mechanisms for the Alignment of Air Quality Planning 33 5.2.3 Nordic Countries

In most Nordic countries, clear air is one of the sustainable development goals directing the preparation of various types of land use plans.

Finland’s land use planning system, as defined in the Land Use and Building Act (2000), gives municipalities a high degree of autonomy in local land use planning. Finland’s 432 municipalities vary greatly in size, from Helsinki with more than half a million inhabitants, to about 20 municipalities with fewer than 1,000 residents. Municipalities produce local detailed plans to guide construction and other land use changes in areas where land is used intensively or in sensitive areas. These detailed plans are guided by local master plans, which may be produced by individual municipalities, or by groups of municipalities in the form of a joint master plan. Municipal planning is guided by national land use guidelines issued by the national government, and by regional land use plans. The different levels are shown in Figure 11.

Figure 11 Levels in Finnish land use planning system.

Finland is divided into 19 regions, each covered by a regional land use plan. These fairly general plans set out medium-term and long-term objectives for regional land use patterns concerning issues that affect land use planning in many municipalities. Regional land use plans are drafted and approved by the 19 regional councils, which are made up of representatives from the municipalities. Land use designations and planning reservations shown on the maps in the comprehensive regional land use plans provide a concrete expression of the regional development strategies drawn up by the regional councils. These plans ensure local developments planned at municipal level are in accordance with these strategies. The components of regional planning are shown in Figure 12.

Mechanisms for the Alignment of Air Quality Planning 34

Figure 12 Components of Finnish regional planning.

Regional land use plans may be drafted in three forms: (1) comprehensive regional land use plans covering all major planning issues in the whole region; (2) phased ) regional land use plans covering certain specific planning issues during each planning phase, and (3) sub-regional land use plans covering smaller sub-regions or coherent areas such as river systems. The option of producing phased or sub-regional land use plans gives the regional planning authorities flexibility where changing conditions make the drafting of such plans desirable, or where resources are limited. In such cases the authorities must nevertheless also strive to keep the comprehensive land use plan for the whole region up to date (Finnish Ministry of Environment 2007).

Iceland has only two administrative levels-- national and local. Local authorities prepare the plans but the Minister for Environment has supreme control over planning in co-ordination with the Planning Agency. Both municipal and regional plans are subject to the Minister of the Environment’s approval. Regional and municipal plans approved by the minister and local plans adopted by local authorities are legally binding. There is no regional administrative level, but two or more municipalities can, at the initiative of the relevant local authorities or the Planning Agency, prepare a regional plan where the aim is to co-ordinate the policy of local authorities on development of settlement and land-use over a period of at least 12 years. Then, a provisional planning committee with representatives from all municipalities involved in addition to one appointed by the Planning Agency is established and is responsible for preparing the plan. The regional plan becomes legally binding when all the municipalities involved have adopted the plan and the Minister of Environment has approved it.

Norway has three levels of planning—national through the Ministry of Environment, regional through county councils, and local through municipalities. The municipalities are the main focus of planning with county councils formally responsible for an integrative regional planning. Skjeggedal (2005) concluded there was little coordination between nature conservation and regional planning. These activities were performed by different regimes, partly in the same kind of processes; but, by different authorities, with different competence and at different times.

In Sweden, planning is mainly decentralized and a municipal concern. On a national level there are steering documents and guidelines; but, the interpretations and decisions mainly take place on the municipal level. Municipalities develop comprehensive plans covering the whole

Mechanisms for the Alignment of Air Quality Planning 35 municipality and presenting the existing functions and the long term aims for land and water management. The comprehensive plan is not binding; but, is supposed to contain up to date guidelines for the future development. The plan is also required to be renewed when necessary. The decision to renew it is taken by the politicians at least once during their term of office. The detailed development plan covers parts of the municipality and is binding. This kind of plan is prepared when change is expected in a building block or a part of an estate. The detailed plan is decisive for the building permits, and also a tool for the caretaking of the built heritage. On the regional level Sweden is divided in 21 counties with a county administrative board as the regional state authority, seeing that national interests are taken into account in planning; laws are implemented; and governmental directives are followed. It is possible to make a regional plan, if there are issues clearly concerning more than one municipality; but, this is voluntary and the plan unbinding. More formalized regional planning for has taken place in the Stockholm region, and in the Gothenburg region (Nordregio 2004).

Nilsson (2007) comments on the difficulty of integrating all dimensions of sustainability in Swedish local planning. Planning processes must deal with large volumes of data and information and co-ordinate with differing stakeholder values and views of society. Swedish local authorities cope with these demands by differentiating between various modes of the planning process: the goal-orientated, the consensual, the entrepreneurial and the day-to-day. There is often an obvious emphasis on one of these modes, even where those local authorities often work with more than one type of planning in a parallel manner. Case studies indicate Swedish local authorities seek to limit the complexity of sustainable development by dividing it into topics, i.e. ecological, social and economic, and then devoting separated planning processes and planning documents to each.

Denmark’s Planning Act, first passed in 1992 and amended several times since, provides for a spatial planning system strongly decentralizing the delegation of responsibility. The municipal councils are responsible for comprehensive municipal planning, detailed local planning and permits for construction and changes in land use in rural zones. The 12 regional planning authorities are responsible for regional planning. The Minister for the Environment may influence decentralized planning through national planning initiatives. The state may veto the planning of municipalities and regional planning authorities to uphold national interests. Planning decisions may be appealed to the Nature Protection Board of Appeal. Only the legal issues in planning decisions may be appealed. The Planning Act ensures the overall planning synthesizes the interests of society with respect to land use and contributes to protecting the country’s nature and environment, to allow sustainable development of society with respect for people’s living conditions and for the conservation of wildlife and vegetation is secured. Spatial planning is especially intended to ensure: the whole country and the individual counties and municipalities develop appropriately, based on overall planning and economic considerations; valuable buildings, settlements, urban environments and landscapes are created and conserved; the open coasts continue to comprise an important natural and landscape resource; air, water, soil and noise pollution are prevented; and the public is involved in the planning process as much as possible. The Planning Act is based on the principle of framework management, in which plans must not contradict the planning decisions made at higher levels. If these higher-level decisions are changed, the planning at lower levels must be adapted accordingly (Danish Ministry of Environment 2002).

Mechanisms for the Alignment of Air Quality Planning 36

The planning process for regional and municipal plans follows six steps (Danish Ministry of Environment 2002):

1. Prior public participation every 4 years • Information on previous planning disseminated • Regional planning: ideas and proposals solicited; municipal planning: a strategy for planning developed • Deadline of at least 8 weeks 2. Proposed regional or municipal plan • Prepared in cooperation with other public authorities, citizens, nongovernmental organizations etc. 3. Proposal published • Deadline for objections of at least 8 weeks • Proposal sent to other public authorities • A regional plan or municipal plan may be vetoed to uphold national interests 4. Plan adopted • Objections (including vetoes) and comments processed and proposed changes negotiated 5. Final plan published 6. Administration of plan • Relevant planning authorities strive to implement the plan

5.3 Australasia

Australia has a variety of air quality planning activities in commonwealth (federal), state and municipal governments. New Zealand operates under a national integrated planning regime.

5.3.1 Australia

In Australia an airshed is defined as “a region (for example, capital city) for which a government agency has estimated pollutant emissions to air for various non-reporting facility sources such as motor vehicles” (Australian Government 2010). The formal designation of airsheds came about as a result of the National Pollutant Inventory (NPI), established by the National Environment Protection Council in February 1998. The NPI is delivered through a national cooperative model between the Commonwealth (that is, federal government) and States and Territory Governments. The administrative and implementation arrangements are set out in the NPI Environment Protection Measure (EPM) document and its associated Memorandum of Understanding. Implementation is managed by the Implementation Working Group (IWG), which comprises a representative of each jurisdiction and is chaired by the Commonwealth. Implementation in each state and territory is managed through NPI Units, and by the Commonwealth through the NPI Unit, Environment Australia.

The Commonwealth also funded State and Territory Environment Protection Agencies or Authorities (EPA), through the three-year Memorandum of Understanding, to establish NPI units

Mechanisms for the Alignment of Air Quality Planning 37 in all states and territories. The units were to receive, process, and transfer (to the central government) industry facility reports along with conducting associated education, assistance and information functions for facility reporters. They were also funded to conduct aggregated emissions studies for pollutant releases from identified sub-threshold, mobile or diffuse sources in particular airsheds or water catchments. State and Territory NPI units have managed projects to estimate emissions from sub-threshold, diffuse or mobile sources into major airsheds and nutrient emissions into major water catchments. As examples, airshed sources studied include motor vehicles, domestic heating (including wood fires) and cooking, railways, commercial and recreational shipping and boating and sub-threshold solvent emissions. The National EPM requires individual jurisdictions estimate the amount of particular substances emitted from smaller, diffuse and mobile sources within agreed regions, that is, collect aggregated emissions data. The MOU states aggregated emissions were to be estimated using handbooks prepared for the purpose. More than 19 handbooks have been prepared. (ARTD 2000).

There are now 33 airsheds and 32 water catchments together with reports on emissions to land included on the NPI database. This diffuse source data is estimated by the jurisdictions and provides estimates of emissions to air, land and water from sources other than reporting facilities. Its inclusion provides more complete depiction of emissions to our environment. Sources include facilities too small to report individually (such as dry cleaners), everyday household activities such as cooking on household barbeques and driving to work, and for land uses causing nutrient emissions to waterways. These aggregated sources are not estimated every year. (Environment Link 2005).

The airsheds and water catchments throughout Australia include both urban and rural locations. Their size and location is determined in line with stakeholder priorities. As a result, they do not cover the whole country and their sizes differ depending on the reasons they were established. For example, South Australia has defined six major airsheds and within them exist eleven minor airsheds covering the major populated, commercial and surrounding industrial areas.

In Queensland, air quality planning can occur in two ways. First, it may be integrated into land use planning. The State of Queensland’s Integrated Planning Act 1997 requires all local government planning schemes to coordinate and integrate State and regional dimensions of core matters. This is achieved through the incorporation and integration of State interests in planning scheme preparation. Through a policy directive (Government of Queensland 2000), the state government requires air quality and other environmental values be identified in planning schemes and the air environment be protected or enhanced through setting agreed objectives and assessment provisions in planning schemes.

Second, the State’s Environmental Protection (Air) Policy 1997 provides for the development of co-coordinated whole-of-government programs to enhance or protect environmental values. Such programs must be developed by the chief executive through a co-operative process that includes local government. Programs may be spatially defined or address a specified type or source of contaminant release. The South East Queensland Regional Air Quality Strategy is an example of a coordinated whole-of-government program to enhance or protect environmental values of the air environment. Planning schemes must take into account any relevant program and provide for implementation as may be recommended or stipulated by the programs endorsed by the State government under the Environmental Protection (Air) Policy.

Mechanisms for the Alignment of Air Quality Planning 38

Western Australia (2003) has a similar planning policy:

Planning strategies, schemes and decision-making should:

(i) Promote urban development patterns, densities and form that support reduced travel demand, increased availability and access to public transport and that encourage walking and cycling. (ii) Have regard to the potential for conflict between sensitive land uses and activities with air emission impacts. (iii) Have regard to the relevant requirements of other national and state policies.

Newcastle City Council (2005) has been managing air quality since 1947 when it established a Smoke Abatement Advisory Panel to reduce the impact of industrial emissions. In 1994 Newcastle City Council completed the Newcastle Environmental Management Plan. One of the key actions was to develop an airshed management plan for the city. A working group was formed in 1997 with membership from Council, regulatory agencies, technical experts, industry and community to develop a plan. The Newcastle Airshed Management Action Plan was completed and adopted the following year. Actions fell in nine areas: operations, energy efficiency, regional cooperation, land use planning, transport, vehicle emissions, business and industry, regulation, enforcement, and community involvement. Ongoing evaluation and review is through the City’s Environmental Protection and Pollution Advisory Committee.

5.3.2 New Zealand

There have been major changes in regulation of air pollution over the past two decades in New Zealand. Before the introduction of the Resource Management Act in 1991 air pollution was managed under the Clean Air Act 1972 through the control of emissions at source. At that time, , there were no comprehensive air quality plans to deal with transport and domestic emissions – although local responses were possible, e.g. the Christchurch Clean Air Zone Orders 1977 and 1984). Also, the Health Act was used to deal with health effects and nuisances, e.g. odour and domestic fires. The air issues were compounded by minimal ambient air quality monitoring and district schemes (plans) used for zoning and activity classification to control the industrial uses. Often the district schemes would rely on the Clean Air Act schedules for guidance on levels of emissions

The Resource Management Act (RMA) established one integrated framework replacing the many previous resource-use regimes, which had been fragmented between agencies and sectors, such as land use, forestry, pollution, traffic, zoning, water and air. It was one of the first statutory planning regimes to incorporate the principle of sustainability. ‘Sustainable management’ is an explicitly stated purpose at the centre of the regulatory framework.

RMA requires an air quality management approach that involves measuring the state of the air and assessing the influence of pressures on air quality. It also gave primary responsibility for managing air quality to regional councils (and unitary authorities). However, territorial authorities have a responsibility to manage the effects of land use and subdivision, which can

Mechanisms for the Alignment of Air Quality Planning 39 also impact on air quality. Both regional councils and territorial authorities also have particular requirements under the national environmental standard for air quality.

The different functions of regional councils and territorial authorities may cause tensions when managing air quality, such as allowing incompatible activities to be situated in proximity, for example, consenting residential housing alongside existing wastewater treatment plants. To effectively manage air quality, relationships need to be managed and roles integrated. National environmental standards require regional and district plans to give effect to any national policy statement and for regional policy statements and district plans to be consistent with the relevant regional plan. Regional policy statements need to provide clear direction on how the air quality issues of the region are to be managed. There must also be effective engagement between regional councils and territorial authorities when plans are being reviewed and prepared.

Developing good dialogue and partnership agreements are the best means of ensuring clarity of roles and responsibilities. These may be formalized through the regional policy statement, regional plans, delegations or negotiated memorandums of understanding. The integrated management of land use and transport activities may result in adverse effects on air quality and is also essential to meet the requirements of the air standards.

National environmental standards set concentration limits for clear air, regulating or prohibiting certain activities that pollute the air and imposing air quality monitoring and reporting requirements on regional councils. One of the first requirements of the air standards was for regional councils (including unitary authorities) to identify areas where air quality is either likely to or known to exceed the air standards. These areas are called airsheds and are published in the New Zealand Gazette. As of January 2008, there were 69 gazetted airsheds. Of these, approximately 30 are likely to exceed the ambient concentration limits in the air standards. Because they exceed the air standards (or are likely to), these airsheds face restrictions on development.

Councils can use several different tools to meet the requirements of the RMA and air quality standards. They can establish policies and rules to manage particular issues in their regions; issue resource consents for discharges from industrial and trade premises; carry out education campaigns; and provide incentives for people to use cleaner forms of home heating. Regional plans (sometimes called “air plans”) address specific air quality issues for each region. They outline a regional council’s goals for air quality and contain rules about discharges to air from activities such as industry, domestic fires and vehicles. Preparing such a regional plan involves several stages. Public participation and communication with the local community is important and is achieved through meetings and submissions. The New Zealand Ministry for the Environment provides national guidance for regional councils and unitary authorities to manage the air in their region. This national guidance includes ambient air quality guidelines, good- practice guidance, research and reporting, and assistance with public education campaigns. The Ministry does not have a formal enforcement role because it has been delegated to regional councils and unitary authorities. The Ministry assists councils by providing information on technology, collating monitoring data from all around the country, and providing help and advice to regional councils.

Mechanisms for the Alignment of Air Quality Planning 40 5.4 Summary

Air quality planning is managed differently by different jurisdictions. Stakeholders are consulted at various stages of the planning process in all jurisdictions. In British Columbia, airshed plans are developed where they are needed using a collaborative process of provincial and local agencies, integrating with other types of planning in the communities.

The EU directs its Member States to identify geographical zones for monitoring and management of air quality. The EU also suggests zone boundaries be linked to administrative areas and adjacent administrative areas with similar air quality characteristics be grouped into one zone. In the United Kingdom, air quality planning is done by the local authorities with strong encouragement to cooperate with neighboring authorities. Management areas exist only where needed, leading to a “spotty” pattern of airsheds similar to Alberta. Nordic countries have integrated air quality into their land use planning since the 1990s as have New Zealand and some parts of Australia.

The United States divides the country in areas based on air quality standards, requiring different types of state plans for each area. Five large multi-state areas have been formed to address larger scale problems. California has air basins for monitoring purposes, but a different set of management regions based on counties.

Australia defines airsheds where needed for inventory purposes, with management occurring at the state or municipal level. New Zealand has federal legislation requiring an air quality management approach with the local governments responsible for implementation. As a result, airsheds are typically required in areas where the air standards are likely to exceed or are exceeding air standards.

Mechanisms for the Alignment of Air Quality Planning 41 6.0 ALIGNMENT MECHANISMS

According to dictionary.com, alignment can mean either “the adjustment of the parts of a device in relation to each other for coordinated functioning” or “a state of agreement or cooperation among persons or groups with a common cause or viewpoint.” In the corporate world, according to Management System Dictionary, alignment, is the “actions taken to ensure a process or activity supports the organization's strategy, goals and objectives.” Strassman (1997) defined alignment quite simply as “the delivery of the required results.” The management literature is replete with papers on various aspects of alignment because “despite its significance, aligning an organization to its strategy remains one of the most elusive and unsatisfactory areas of management endeavour.” (FSN 2008) Closely related is the concept of coordination which dictionary.com defines as "acting in harmonious combination”. Thus there are one or more actors, performing some actions which are directed toward some common ends. "Harmonious combination" makes it clear that the actions are not independent; they must be performed in a way to help create a positive movement toward the ends.

The term planning is usually defined as “the formulation of a scheme, program, or method worked out beforehand for the accomplishment of an objective or attainment of an end” (e.g. dictionary.com). A planning process is a structured approach to problem solving, with six-steps commonly used (Orth and Yoe 1997):

(1) identifying problems and opportunities, (2) inventorying and forecasting conditions, (3) formulating alternatives, (4) evaluating alternatives, (5) comparing alternatives, and (6) selecting a course of action.

In business, the term sometimes extends to include the management functions of:

(7) “arranging or creating the means required, and (8) implementing, directing and monitoring all steps in proper sequence” (e.g. businessdictionary.com).

Air quality planning or land use planning generally does not include implementation. The distinction is important in determining what constitutes alignment.

6.1 Literature Survey on Alignment and Coordination

Within organizations, Mintzberg (1983) discerned five mechanisms of coordination and later added a sixth (Mintzberg 1989):

• mutual adjustment: agreements in a informal consultation; • direct supervision: one person gets the responsibility over the work of others, instructing them and controlling their activities;

Mechanisms for the Alignment of Air Quality Planning 42 • standardization of working processes: for example, instruction how to do something, like the CASA guidance on consensus decision-making; • standardization of output: the result is fixed, not the way how to attain the result; • standardization of skills: a description or what should be the necessary training for the job (for example, air monitoring) ; • standardization of norms and values: everyone shares the same ideals.

These lead to six different organizational configurations when each is chosen as the main coordination mechanism, respectively, ad-hocracy, simple structure, machine bureaucracy, professional organization, division organization, idealistic organization. Another approach is strategic alignment around five aspects of business operations (BIPM 2010):

• Financial: the pool of monies is re-evaluated to ensure that more (not all) money is spent on the strategic priorities, but still maintain core business; • People: skills, hiring, training, rewards and incentives are consistent with the strategy; • Process: business systems, quality definitions and measures work for the strategy; • Stakeholder: parties with direct interest need to support the strategy on the ongoing basis, in-spite of not having 100% consensus; • Partner: delivery agents and service providers need to understand the strategy and re- orient themselves.

Alignment can also be viewed as vertical, top to bottom in an organization, and horizontal, such that internal units can ensure they satisfy the needs of the units dealing directly with the external customer.

Some common methods used by organizations to align staff are (Gomes 1996):

• related activities report to same manager; • coordinating teams; • cross-functional task forces; • dual reporting relationships; • informal organizational networking; • incentive compensation tied to group performance; and • executive-level insistence on teamwork & interdepartmental cooperation.

At the level of the individual, good coordination is accomplished by (Wade 2008):

• making and keeping commitments; • delivering on promises; • involving others when they have a clear interest; • consulting others in a meaningful and timely manner; and • staying in communication.

When there is more than one organization involved, the problem becomes one of inter- organizational alignment or coordination. Malone and Crowston (1990) identified four

Mechanisms for the Alignment of Air Quality Planning 43 components of coordination as shown in Table 1. The goal-relevant relationships are termed interdependencies and coordination is primarily the act of managing interdependencies between activities performed to achieve a goal.

Table 1 Components of coordination (Malone and Crowston 1990).

Coordination Component Associated Coordination Processes Goals (ends) Identifying goals together Activities Mapping actions to goals Actors Selecting actors Assigning actions to actors Interdependencies Sequencing activities Allocating resources Synchronizing action Making decisions Sharing information

Weber (2008) recounted the following three solutions to problems of interdependence:

• Standardization: establishing rules or procedures specifying the appropriate behavior in pursuit of the goal. This works bests in stable circumstances with little uncertainty. A standard process can be derived from historical organizational routines people keep using to coordinate their activities, or can derive from a scientific analysis, development and implementation of the most efficient and effective process (Cuel and Cristiani 2005). • Plan: developing schedules and steps to sequence actions correctly. There can be a series of routines and standard processes directly connecting two or more autonomous units, taking into consideration a continuous adaptation of activities and knowledge deriving from unexpected needs and resources variability (Cuel and Cristiani 2005). A plan can represent a “fusion” that resolves the conflict between the subsystem's loyalties to its own stakeholders and its loyalty to the total system (Wren 1967). There may be a need for some office or agency at the subsystem interface or for "boundary"" personnel to monitor the interactions between the focal organization and its organization set. • Mutual adjustment: sharing information and knowledge in repeated interactions enabling mutual feedback for each to modify behavior. This works best when there is high uncertainty, needs have not been predefined, preferences are fluid and the two interact dynamically. Interdependent organizations need to communicate and share knowledge in a semi-casual mode, or by non- predefined processes (Cuel and Cristiani 2005). Information transmittal serves to link subsystem decision centers and is essential for feedback and control in all systems (Wren 1967).

In examination of public administration performance, Jennings and Ewalt (1998) noted coordination problems become much more difficult in multi-organizational settings, where appeals to hierarchy and authority are likely to be of little use in setting priorities, settling disputes, or facilitating interaction. Separate missions, competing legal mandates, distinct

Mechanisms for the Alignment of Air Quality Planning 44 constituencies, and competition for resources are obstacles to effective coordination of the activities of diverse organizations. The literature and popular imagination make frequent reference to turf protection as a catchall phrase to capture the barriers to inter-organizational cooperation or coordination. The problems are accentuated in a pluralistic political system that generates a plethora of programs and agencies over time to address similar, often overlapping, needs. The growing use of a broad array of service providers complicates matters further. The involvement of not-for-profit agencies and profit seeking organizations through contracting and vouchers is central to the network arrangements being used in public administration in recent years. The multiplicity of activities and divided authority give rise to frequent calls for coordination, if not consolidation, of policies and programs.

It has been suggested the search for a solution to the problems of interagency coordination may be much like the ancient quest for the philosopher's stone to provide the key to understanding the universe. Although coordination difficulties grow out of "clashes in statutory missions or differences in legitimate mandates,” coordination is still fairly common and is typically attained through informal agreements and interactions among agencies having shared needs and interests. Informal coordination is greatly facilitated when people share the same goals, operate from a common set of legal authorities and information assumptions, agree on standards, have compatible professional outlooks, and can help each other" (Jennings and Ewalt 1998).

In the absence of hierarchy, the answer seems to lie in informal structures and mutual adjustment. A mixture of informal channels, networks, and norms operating at the interface of organizations can produce very effective service coordination. Such informal mechanisms are facilitated by norms of reciprocity, formal coordination activities facilitating the development of informal channels, policies of organization managers that indicate a willingness to allow informal contacts, personal attributes, and serendipitous nearby office locations. Service providers can establish a division of labor and connect their activities through well-defined, but largely informal, systems. Networks are central to the administration of many programs today and managers should take advantage of opportunities to identify coordination points for the full set of people in the network. The success of a network and of individual programs within the network is heavily dependent on relationships within the network facilitating cooperative action. The techniques they examined are shown in Table 2.

Table 2 Techniques for coordination in public administration (Jennings and Ewalt 1998).

Type of Activity Techniques Communicating and Decision- Information sharing, cooperative agreements, interagency making committee, workshops, interagency task force, working partnerships, liaison officers, interagency staff meetings, joint policy statements, common advisory councils, common geographical boundaries, joint meetings of advisory councils, shared employment and training programs Operating Joint funding, joint marketing, joint administration, sequential funding

Mechanisms for the Alignment of Air Quality Planning 45 Planning Review of each other’s plans, joint planning, criteria for interaction, specific goals, outside review, guidelines for review, uniform planning periods, combined plans, common definitions, quantifiable outcomes Supporting One-stop shopping, requirements, criteria, framework, common assessment tools, common electronic system, consolidated forms, model program documents, shared credit

Payan and Svensson (2007) investigated trust and commitment as two precursors to various types of inter-organizational relationships and subsequent satisfaction. They distinguished between cooperation, coordination and specific assets. Cooperation is defined as an orientation reflecting a spirit of willingness of one organization to work with another organization. Coordination is defined as general joint activities taking place between organizations. Specific assests are defined as dedicated activities tailored for use between organizations. They found commitment leads to co-operation, coordination, and specific assets. Yet, only co-operation and coordination leads to satisfaction with the relationship. Trust was necessary for co-operation but not coordination or specific assets. Trust is the expectation another organization can be relied on to fulfill obligations and will act and negotiate fairly when the possibility for opportunism is present. Commitment was an enduring desire to maintain a relationship.

In 1993 Alberta Education published a guide to coordination among public sector organizations. It spoke of a continuum of coordination and described the characteristics of 5 stages as shown in Table 3.

Table 3 Continuum of coordination (Alberta Education 1993).

Stage functions characteristics Information Networking little structure Sharing education no budget no staff front line staff engaged Needs Advocacy Semi-structures Identification gaps No budget No staff Middle management engaged Cooperation Program planning Semi-structured Resource sharing Small budget Shared, seconded staff management engaged Collaboration Policy & program Structured Planning Full budget Resource allocation Program staff Middle management engaged

Mechanisms for the Alignment of Air Quality Planning 46 Integration Joint planning Structured Joint resourcing Fully resourced Program management Program staff Service delivery Senior management engaged

The University of Nebraska (2003) categorized the degree of coordination into five levels:

1. No Coordination: no activity nor desire to work with the other organization even though they may provide similar programs. 2. Low Degree of Coordination a) informal and infrequent contacts between individuals b) exchange of general information to keep each other informed c) clients are referred to the other organization when it can better respond to the clients' particular needs 3. Moderate Degree of Coordination a) formal exchange of information (planned joint meetings, exchange of newsletters, annual report, meeting agendas) b) exchange of personal and resources for particular programs c) joint projects or programs 4. High Degree of Coordination a) written agreements or contracts b) joint budgets c) same (or overlapping) boards of directors d) joint ownership (of building, offices, equipment) 5. Merger (the two organizations become one)

Alexander (1995) distinguished between coordination strategies (the general and abstract processes or relationships), and coordination tools (concrete and specific linkages and activities which can be used in any of the strategies.) Strategies may be:

• anticipatory (proactive): coordination by plan; • adaptive (reactive): coordination through monitoring, feedback and control; • cooperative: voluntary interaction which can be induced by bargaining and resource exchange; • informational: influence and persuasion; or • controlling: aimed at biasing decisions in a desired direction through financial incentives, sanctions, authoritative mandates or changed structures.

General co-ordination tools include inducements, capacity building, and system change. Informal co-ordination tools are primarily interpersonal contacts and informal communication (meetings, telephone and correspondence). Formal coordination tools may be structural (e.g. task groups, joint meetings, shared administration, staff exchange), linkage mechanisms (e.g. co-location, contracts), or program management instruments. Program management instruments address structure (e.g. mandate), fiscal control (e.g. budgets, grant formulas) and implementation (e.g.

Mechanisms for the Alignment of Air Quality Planning 47 evaluation, plan review, joint action). Information sharing tools include meetings and workshops.

Litwak and Meyer (1966) noted both bureaucratic government and community primary groups are essential for achieving most tasks in our society., They also have antithetical atmospheres at the same time. Therefore, they are best linked when they are at some midpoint of social distance. If they are too close, there will be conflicts because of their atmospheres. If they are too far, they will not be able to coordinate to solve their mutual problems. Of their eight possible mechanisms of coordination between bureaucratic organizations with primary groups, the ones most relevant to airsheds are common messenger, settlement house (physical facilities, proximity, and staff), formal authority and delegated function.

This short literature survey shows there are many potential ways to achieve alignment of airsheds, land-use planning regions and CAMS air zones. They are not mutually exclusive and many can be used together. The following six alignment approaches are described in subsequent sections:

1. Geographical congruence: the boundaries of airsheds are adjusted to match those of the land-use planning regions. 2. Contracts: each airshed enters into an agreement, memorandum of understanding or other legal instrument that clearly delineates responsibilities, deliverables and exchanges. 3. Mandates: the GOA prescribes the authority of airsheds through some legal instrument and determines the financial arrangements to support operations. 4. Standardization: similar decision-making processes, forms of output, staff skill requirements and values are adopted within each of the relevant organizations. 5. Plan: airsheds, LUF regions and CAMS air zones adopt common goals and direct their activities accordingly. 6. Mutual adjustment (system feedback): each airshed is accountable for a specific unique portion of the overall system (a function) so they play complementary roles. Information is shared and stakeholders are expected to make appropriate changes to keep the entire system on track.

6.2 Alignment by Geographical Congruence

There are three possible ways geographical areas could be made congruent:

a) One-to-one: create one airshed for each LUF region resulting in seven total. b) One-to-Few: create one airshed for groups of LUF regions, perhaps four in total: (1) South Saskatchewan, (2) North Saskatchewan and Red Deer, (3) Lower Athabasca, and (4) Upper Athabasca, Upper Peace and Lower Peace. c) Few-to-One: adjust existing boundaries to fill respective LUF regions, that is, the boundaries of each airshed are made coterminous with those of the land use regions. Where two or more airsheds lie in one region, they could share the area as subregional air quality planners. The South Saskatchewan Region would be filled by PAS and CRAZ. The North Saskatchewan would be filled by ACAA and FAP. The Red Deer Region would be filled by PAMZ who would lose area in the northwest, but gain in the east. The

Mechanisms for the Alignment of Air Quality Planning 48 Lower Athabasca would be filled by WBEA and LICA. The Upper and Lower Peace would be filled by PASZA, or a new airshed could be created for the Lower Peace. The Upper Athabasca would be filled by WCAS who would lose area on their eastern edge.

The advantages and disadvantages of each variant are summarized in Table 4.

Table 4 Pros and Cons of geographical congruence.

Geographical Pros Cons Variant One-to-One • Simple • starts whole formation process from • No boundary conflicts scratch • Ideal if starting from • some areas have little industry to finance nothing operations • loses goodwill achieved in existing airsheds • would be viewed as heavy-handed and dictatorial • major disruption to existing airsheds One-to-Few • reduces number of • larger areas stakeholders • no shared feeling of “togetherness” • simple • cuts across municipal boundaries • reduces administrative • massive amount of work because costs virtually starting over • links well with national • gigantic disruption to current operations “air zones” Few-to-One • minimizes changes to • existing stakeholders may not be existing airsheds supportive • allows subregional • loses revenue for some airsheds planning • enlarges areas of coverage without • minor disruption of increasing revenue current operations • introduces new stakeholders to many airsheds

While simple in theory, in practice any of the variants would be massively disruptive of the status quo and would entail a great deal of work on the part of AENV to implement. If persuasion did not work, then AENV might have to impose the change by fiat. Reducing the number of airsheds would reduce the long term ongoing costs to AENV: fewer contracts, fewer boards needing representatives, fewer parties reporting data, less liaison needed between Edmonton and regional offices, reduction in total administration (summed over all airsheds).

Mechanisms for the Alignment of Air Quality Planning 49 6.3 Alignment by Contract

The five airshed associations that completed PM and Ozone Management Plans did so under contract to AENV. Each airshed association also has a contract with AENV for the operation of one or more monitoring stations in the provincial network. A Memorandum of Understanding or other legalistic document can be quite effective in keeping the parties in alignment. Vigilance is needed to ensure the parties adhere to their respective commitments. Resource exchanges usually ensure attention is paid to the provisions of the contract.

Fiscal controls are one of the most powerful coordinating mechanisms. Most government agencies using “networks” to achieve their ends have done so either by contracting out relevant services or creating a grant structure to ensure the provision of appropriate services. AENV is different in having facilitated networks (such as airsheds) to raise their own funds to provide public services. The CASA Ambient Air Monitoring Strategy for Alberta contained a non- consensus recommendation that “to ensure long-term sustainable funding for the Ambient Monitoring Strategic Plan, Alberta Environment develop within two years, a sustainable long- term funding mechanism that ensures equitable contributions from large industrial, small industrial and diffuse emitters.” If AENV can determine how best to collect all of the funds centrally, it would be a simple matter to ensure alignment of monitoring and any planning activities through operating contracts with the airshed associations. Central collection of funds would also reduce the administrative burden on the individual airshed associations.

6.4 Alignment by Mandates

In many jurisdictions some or all air quality management responsibilities are delegated to local authorities. The distinction between planning and implementation is crucial in deciding the mandates given to each stakeholder. Under Alberta’s LUF, regional plans are developed under the auspices of the regional advisory council; but, are implemented through provincial line agencies. Ambient air quality monitoring and reporting are the only aspects of implementation in which current airsheds are engaged. Therefore, it could be argued airsheds should have no role beyond that of an “advisory council” and AENV should actually assume all responsibility for monitoring and reporting. This would represent a huge change from the current situation, one that most air zone stakeholders would likely resist. However, costs could be reduced by eliminating association overheads and revenue could be guaranteed through approval requirements, regulations or other means. The current “free-rider” problem in some airsheds may also be eliminated by government edict.

While airshed associations can and have prepared air quality plans, responsibility for implementation generally falls to the individual members, and mainly government. The plans would be more effective if integrated into the regional land-use plan. Currently it is unclear howthe regional advisory council will use the existing plans or seek the advice of the airshed associations. This could have been specified in the Terms of Reference for the regional advisory councils.

Airsheds currently derive their authority from the monitoring clauses in approvals. If AENV desires to provide a mandate for more than just ambient air quality monitoring and reporting;

Mechanisms for the Alignment of Air Quality Planning 50 clear delegation of responsibility could be made through regulation. EPEA provides for the creation of Delegated Administrative Organizations (DAOs). Such a tool could certainly be used to ensure alignment.

6.5 Alignment by Standardization

6.5.1 Decision-making

There are three basic ways decisions can be made (Schwartz 1994; decision-making- confidence.com) :

a) Single Decider: The decision is taken by one individual or a small group (chair, administrator, executive committee, etc.). The decision-maker may obtain input from the public, staff or others prior to making the decision; but, there is no guarantee recommendations will be solicited or followed. In the public realm, this is the approach used in courts of law, arbitration or appointed Boards and Commissions. Within organizations, this is the prerogative of various levels of management for various types of decisions. b) Majority Rule: The decision is taken using some type of voting, either formally structured using Robert’s Rules of Order as in a legislature or informally organized as through a show of hands. There is usually discussion before the vote provides information on opposing interests and needs. c) Collaboration and Consensus: Discussion continues until everyone or a set percentage (agreed beforehand) can accept the decision being made. This method is commonly used in public policy facilitated settings. With the formation of CASA in 1994, this method was institutionalized and adopted by all of the airshed associations.

Some of the advantages and disadvantages of each method of decision-making are summarized in Table 5.

Table 5 Pros and Cons of various methods of decision-making.

Decision-Making Pros Cons Method Single Decider • fast • individual bias • responsibility in hands of • may not consider other few opinions, input, etc Majority Rule formal formal • everyone knows the rules • very cumbersome • there is an orderly process. • some subgroups can exploit informal • can prevent discussion of • relatively fast important issues. • puts long involved informal discussions to rest • not responsive to minority opinion

Mechanisms for the Alignment of Air Quality Planning 51 • those opposed may later undermine the decisions Collaboration and pure pure Consensus • responsive to minority • Takes a long time opinion • one person can block the • leads to the strongest decision support modified modified • Small percentage of people • reduces the chances of are still unhappy blocking

Consensus decision making is generally acknowledged as the most desirable decision-making method when making critical decisions requiring commitment and support (SeedsforChange 2010; Saylor 2006), such as:

• developing a focus (vision, mission, charter, goal); • formulating a code of conduct; • selecting an issue, problem, or opportunity; or • deciding on a solution to implement

However, consensus in not appropriate when:

• time is of the essence, as in emergencies; • the matters are insignificant or trivial, as in deciding how long a break to take; • there are no good choices, the lesser of evils or a clear win-lose; • there are deep divisions with no shared values; or • there is insufficient information to proceed.

The processes used in airsheds are similar to those adopted by CASA which are consensus – except for administrative matters. This seems to work well because it satisfies the conditions noted above. Airsheds have taken responsibility for monitoring and reporting which are relatively uncontroversial; but, do have significant financial and people implications. In their recently expanded role of air quality planning, consensus still works because the product is recommendations for which they have little responsibility to implement. If airsheds were to be given an administrative role for implementation of such plans or be delegated regulatory authority, the consensus model would not likely work well because the situation can be win-lose for the member organizations and there would be deep divisions in values “when the rubber hits the road.”

6.5.2 Outputs and Values

The primary business of airshed associations is monitoring and reporting. The “how” of monitoring is reasonably standardized through the provincial Air Monitoring Directives (AMD) (2006, 1989). The “what” of monitoring has a standardized “core” of parameters, but there is a variable range of additional and effects monitoring determined by the issues in the airshed. Each

Mechanisms for the Alignment of Air Quality Planning 52 airshed association reports data on its own website in addition to transferring it to the CASA Data Warehouse on a monthly basis. The airshed association websites differ markedly in complexity, content and display techniques. There is some opportunity for some further standardization with respect to maps, background information, indices, and the like. Of course, this must be weighed against the benefit of allowing each group of stakeholders to have full control of their own operations and tailor outputs to their specific needs.

The Alberta Airsheds Council (AAC) could provide an appropriate forum for output standardization since its purpose is: to identify and advocate for common interests of Alberta airshed zones, and facilitate communication and cooperation between airsheds and between airshed zones and the public. Elaborating further, the goals of the AAC are: communicating on a broad scale between airsheds in Alberta and with Albertans and others; facilitating information sharing between airsheds; acting as a resource for forming airsheds; providing a forum for discussing issues and concerns common to airsheds zones, and developing strategies and processes to address those issues; delegating airshed representation for various CASA working groups and project teams; hosting an airshed conference about every two years on topics of mutual interest to airsheds; strengthening the relationships between airsheds and regulatory agencies. Alternatively AENV could provide the guidance as it has on the roles of airsheds.

Airshed associations have many values in common with CASA. Given the similarity in member organizations and the history of their development, this is not surprising. The Combined Ground Rules for the Lower Athabasca Regional Advisory Council (LARP 2009) include: openness, clear accountability, “don’t get caught up in the details”, participation, respect, honour group decisions, strive for excellence, single voice, confidentiality. These are largely compatible with airshed association values; but, they do diverge on some aspects as a result of the differing nature of the organizations.

6.5.3 Personnel Requirements

The Alberta AMD (2006) requires that:

2.9.1 Personnel performing tasks that are related to environmental monitoring and reporting activities shall be competent on the basis of appropriate education, training, and/or experience.

2.3.2 The person responsible shall (a) Identify personnel, and (b)Define and document the responsibilities of personnel that have involvement with any of the following: (i)The establishment, implementation, and maintenance of the Quality System. (ii) Any environmental monitoring and reporting activities.

2.9.5 The person responsible shall: (a) Maintain records of the relevant authorization(s), including the date(s) on which authorization and/or competence was confirmed for personnel identified in clause 2.3.2, (b) Maintain records of the competence, educational and professional qualifications, training, skills, and experience of all personnel identified under clause 2.3.2, and (c) Provide a record of the competence, educational and professional qualifications, training, skills,

Mechanisms for the Alignment of Air Quality Planning 53 and experience of contracted personnel to the Director within 5 working days of the request.

The onus is on the person responsible for the Quality System to determine the competency requirements of the required personnel and provide appropriate documentation. In practice most of the airshed associations use contractors specializing in the air monitoring business. If there are any concerns about the available expertise, then some sort of standardization of credentials may be needed, for example, uniform testing, curriculum guidance, continuing education requirements.

6.6 Alignment by Plan

A good example of this type is alignment has recently occurred in the Edmonton area. After the abolition of the Edmonton and Calgary Regional Planning Commissions in the early 1990s, there were decades of conflict between the major cities and the surrounding municipalities, especially in the Edmonton area. On April 15, 2008, Alberta's Capital Region Board (CRB) was officially established, consisting of mayors and reeves from the 25 municipalities in the Alberta Capital Region. The board jointly developed a long-range regional growth management plan (Capital Region Growth Plan) which was submitted to the Province on March 31, 2009.

All airsheds plan their monitoring activities; however, only five were engaged in developing PM and Ozone Management Plans. The outcome of these plans was specified by the Canada-Wide Standards and the plans set out actions to maintain air quality at levels below the CWS. On the other hand, the South Saskatchewan Regional Plan seems to go one step further and seeks to set emission threshold:

There are three airsheds currently within the South Saskatchewan Region: the Calgary Region Airshed Zone (CRAZ), Palliser Airshed Society and a small part of the Parkland Airshed Management Zone. All have ambient air monitoring programs. Air quality is determined by emissions of pollutants, local meteorological conditions and topography and is currently managed to meet provincial ambient air quality parameter objectives. CRAZ has developed a draft Particulate Matter and Ozone Management Plan for the Calgary area. A revised version that incorporates stakeholder input is to be completed by December 2009. This plan identifies specific actions for maintaining or improving current ambient ozone levels for the future, given present growth projections of an additional 1.6 million people for the Calgary area by 2076. The present draft plan includes the provision for sector-specific emission thresholds to be developed. An Air Quality Scoping Study for the South Saskatchewan Region has been commenced and will be used to identify if and where additional air quality management thresholds and planning trigger limits may be needed in the region (Government of Alberta 2009).

The Airshed would need to interact with the LUF Regional Advisory Council to ensure the emission thresholds and triggers limits are consistent with the PM and Ozone Management Plan.

For the Lower Athabasca, similar emissions thresholds are sought as air outcomes.

Mechanisms for the Alignment of Air Quality Planning 54 In regards to airshed management, regional thresholds for oxides of nitrogen (NOx) and sulphur dioxide (SO2) emissions will be established. The Lower Athabasca Region includes two airshed organizations within its boundaries, the Wood Buffalo Environmental Association and the Lakeland Industry and Community Association. The NOx and SO2 thresholds will be based on:

- a technical review and assessment of existing and projected oil sands operations; and - the application of “best available technology economically achievable” to manage emissions from both existing and new oil sands operations. Thresholds will consider cumulative environmental impacts (e.g., acidification of soil and lakes, etc.) on key condition indicators and may be adjusted accordingly (Government of Alberta 2009)

Since a PM and Ozone Management Plan was not needed for this region, neither airshed has been engaged in air quality planning. The creation of emission thresholds is an air quality planning exercise with a different perspective from that of PM and Ozone Management. Without direct interaction, the use of their information and expertise is not guaranteed.

To ensure alignment of future ambient air quality monitoring and reporting activities, the respective airshed associations need to become part of the regional planning or agree to follow the regional plan once it has been created. Some of the other alignment tools can also be used in support.

6.7 Alignment by Mutual Adjustment

Mutual adjustment is based on a systems view of air quality management. Each stakeholder assumes responsibility for one or more parts of the system and is kept informed about both subsystem and overall system performance. Deviations from expected performance lead to decisions and corrective actions by the responsible party. Airshed associations primarily adopted the role of monitoring ambient air quality and reporting the information to the public. Recently some have accepted the role of planning to meet the Canada-Wide Standards for PM and Ozone. A tentative allocation of responsibilities for various air management functions is given in Table 6.

Mutual adjustment relies heavily on shared goals, frequent interaction and clear communication among stakeholders using a common language understood by all.

Table 6 Responsibility (R) for various air quality management functions.

Air Quality System Airshed AENV LUF Environment Component & Functions Canada Emitting Source standards R-prov R-national Source emission R conditions Source emission monitoring

Mechanisms for the Alignment of Air Quality Planning 55 Sources and R-prov R-national emissions inventory Emission targets R Dispersing Meteorological R-local R-prov R-national conditions Air quality R-prov R-national dispersion modelling Air quality R-local R-prov R-national monitoring Receiving Effects R-local Monitoring Ambient R-prov R-national objectives determination Research R-prov R-national Planning Trend prediction R-local R-prov R-national Scenario R-local R-regional R-national exploration Integration with R-regional R-national economic activities Supporting Reporting R-local R-prov R-national Quality assurance R-local R-prov R-national Equipment R-local maintenance Laboratory R-national analysis Training Data management R-local R-prov R-national

Mechanisms for the Alignment of Air Quality Planning 56 7.0 CONCLUSION

Alignment is about “coordinated functioning” and “harmonious action.” A variety of tools are available to assist in getting different organizations to coordinate their various activities. Alberta appears to be alone in having multi-stakeholder consensus organizations operate as air quality planners. Most jurisdictions use local authorities to create the plans and simply consult with stakeholders at some stage of the process. Airsheds are designated differently in different jurisdictions for different purposes. The United Kingdom, the Nordic countries, some Australian states and New Zealand use an integrated planning approach striving for much the same sustainability goal as LUF.

There are six major mechanisms that can bring about alignment: geographical congruence, contracts, mandates, standardization, plan, and mutual adjustment. Geographical congruence could lead to as few as four or as many as ten airsheds. Readjusting airshed boundaries would not be an easy task and would require significant government intervention through one or two of the other mechanisms.

From a pure monitoring and reporting perspective, strengthening the alignment of airsheds with LUF or CAMS may not be necessary. As the providers of feedback on overall air quality performance in their geographical areas, airsheds fulfill an important function in any air management system. From a planning perspective, there is some risk of conflicting goals if LUF Regional Advisory Councils do not take into consideration existing air quality plans. For the CAMS air zones, the role assigned to the airsheds would determine the need for stronger alignment.

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