I Need an Action Plan!
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Help! I need an action plan! Mike Holland, EMRC [email protected] Val Beale, London Borough of Hillingdon [email protected] Don’t worry… • Significant air quality problems have been dealt with in the past very successfully • Guidance is available • Many action plans available • External assistance available if needed Your progress so far • Screened your area for exceedance of air quality objectives • Detected exceedances of the objectives • Declared one or more AQMAs (with agreement of Councillors) Step 1: Investigate available guidance • Action plan help desk – http://www.casellastanger.com/actionplan_helpdesk/resources.asp •NSCA – http://nscaorguk.site.securepod.com/pages/topics_and_issues/air_quality_guidance.cfm • [CIEH training] • Action plans from neighbouring LAs • Action plans from LAs in similar situations Decide how you want to proceed • Develop the plan in-house? • Bring in outside experts? Step 2: Talk to Councillors • Councillors to agree mechanism for development and appraisal of the plan • Also, agree resourcing for development of the plan • Councillors may have ideas on specific measures, consultation, stakeholders, etc. Hillingdon example • Council referred plan to the ‘Overview and Scrutiny Panel’ – Fear of appearing to be anti-car – Heathrow problem • Used outside consultants to assist LA officers develop the action plan – EMRC – AEA Technology Step 3: Source apportionment • Key to an effective and efficient plan • Tells you where to focus action • Shows stakeholders the rationale for plan development Source Northwood Harefield apportionment Eastcote Ruislip • London Borough of Ickenham Hillingdon RAF Northolt A40 •NO2 exceedances Hillingdon A40 Hayes End Uxbridge • Main areas Yeading – Heathrow Airport Cowley –M4 West Drayton Hayes –A40 M4 Harmondsworth M4 Sipson –M25 Harlington – Other main roads Heathrow Airport Source apportionment: NOx emissions London Borough of Hillingdon Emission % of total Sector (tonnes /year) Domestic combustion 320 5.0% Commercial & small industrial combustion 165 2.6% Council heating 15 0.2% Non-council public heating 15 0.2% Regulated Industry 215 3.3% Airport on-site activities 3750 58.2% Public transport 515 8.0% Road transport – Heavy Goods Vehicles (HGVs) 605 9.4% Road transport – Light Duty Vehicles (LDVs) other than cars 145 2.3% Road transport - Cars 645 10.0% Road transport - Council fleet 30 0.5% Other 20 0.3% Total 6440 Source Northwood Harefield apportionment: Eastcote Ruislip NO2 Ickenham concentrations RAF Northolt A40 A40 site Hillingdon A40 Hayes End Uxbridge Yeading Cowley West Drayton Hayes M4 Harmondsworth Heathrow site M4 Sipson Harlington Heathrow Airport Source apportionment: -3 NO2 Concentration, µg.m Close to Heathrow Close to major road (A40) Background 15.3 15.3 Major roads 21.8 28.7 Industry 3.6 2.7 Airport 29.7 3.9 Other 9.3 12 Total 79.7 62.6 Step 4: Find out what is already being done • Local Transport Plans • Local development plans • Procurement policy in the Council – Council needs to lead from the front! • Actions by other bodies – Highways Agency – Environment Agency – Local industries • Don’t just look at plans – discuss with those responsible LTP • Consider air quality effects of each action in the LTP • Include actions as necessary as part of the Air Quality Action Plan – Talk to those responsible for implementation – Discuss timescales, costs, effectiveness • Consider whether any LTP measures are bad for air quality – Raise concerns, discuss how dis-benefit may be mitigated • Ensure air quality problems are recognised as a driver for funding LTPs Other plans • Again, examine for links to air quality • Discuss with those responsible • Consider whether air quality should be factored in more clearly or more extensively • Ensure recognition of the potential cost savings of ‘environmental’ technologies Step 5: Are existing actions sufficient? • Consider results of source apportionment • Consider effectiveness of each measure that is already planned and funded • Assess likelihood of the air quality objectives being met – Timescale? – Risk of non-compliance? –Threats? If existing plans look sufficient… • Do you need a separate AQ action plan? • Prepare report highlighting what is being, or will be, done. • Show why you believe these actions to be sufficient • Agree monitoring procedures with those responsible for these actions for feedback to air quality assessment • Ensure air quality is factored into future thinking • Take to Council • Report to Defra If existing plans do not look sufficient… • Inform Councillors • Produce an action plan that: – Defines the problem – Says what is being done – Identifies what else should be done, and how much of that the Council could do – Raises funding and other resource needs – Describes management structure – Assesses probability of meeting objectives – Defines barriers to meeting objectives Step 6: Consider the characteristics of a good action plan • Well targeted – Proportionate –Fair • Recognises the boundaries of LA action and the role of outside bodies • Accepted by stakeholders • Assesses likelihood of meeting the Air Quality Objectives • Achievable Step 7: Consider what else could be done • Traffic measures – Restrictions (LEZs, loading times, parking controls…) – Information – Public transport – Clean vehicles – Cycling, walking • Planning controls • Efficient use of energy – Building design – Sustainable procurement • End of pipe abatement, restrictions to industrial (etc.) processes, operation… Evaluation of options • Key criteria – Cost-effectiveness – Other impacts • GHG emissions, noise, congestion, accidents, local economy… – Acceptance by stakeholders – Availability of possible funding Complexities • Your plan may have – Many measures… – …with responsibility divided between several organisations or departments… – …and each with its own implementation programme – Many stakeholders to keep informed – Need for annual progress report • Essential to keep on top of plan management Hillingdon’s response • Use Action Plan Tracker, developed by EMRC to: – Collate information on each action plan measure • Costs, effectiveness, etc. • Implementation plan • Responsibility for action • Stakeholder feedback • Relevant planning applications • Progress – Permits identification of actions on or behind schedule, reporting in Defra format, etc. Plan management • However you decide to manage implementation it is important to: – Log information as it comes in – Organise it systematically – Monitor information from others (e.g. transport planners on progress with the LTP) – Provide a system that can easily be handed on to other people Barriers for Hillingdon for achieving the objectives • Limited control – No direct responsibility for Heathrow – Major roads controlled by Highways Agency and Transport for London – Major industry regulated by the Environment Agency • Limited funding opportunities Response by Hillingdon • On limits to control: – Planning for the Council to take a lead on air quality where it can – Close and regular engagement with BAA, HA, EA – Included actions in plan to lobby central government, European Commission, Mayor’s office • On funding: – Took advantage of SCA opportunities – Made recommendations during development of the LTP and other council policies – Looking to take more advantage of Section 106 agreements Main conclusions • Much help and guidance is available • Engage Councillors at an early stage • Other plans will help to reduce pollution • Ensure good consultation with stakeholders on additional measures specifically for air quality improvement • Know how you will manage implementation of the plan • Encourage your council to lead from the front.