Hear from those who are working directly with the latest policy and get an insight into the likely implications from Defra’s upcoming Air Quality Plan.

1. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Draft National Air Quality Plan
Dr Claire Holman
Brook Cottage Consultants/University College London
Chair, Institute of Air Quality Management
IAQM Discussion Meeting:
Mitigation in the 2017 Air Quality Plan
Manchester 6 June 2017

2. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Draft National Air Quality Plan (AQP)
Contents
1. Background to the Draft AQP
2. Draft Plan
3. Conclusions
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3. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Directive 2008/50/EC
NO2 limit values:
• Annual mean 40 µg/m3
• 1-hour mean 200 µg/m3 (18
hours above LV permitted per
calendar year)
• To be achieved by 1 January
2010
• Time extension permitted to I
January 2015 if member state
submits a compliant plan
showing it would be achieved
by then
• Same LVs and date as in
Directive 1999/30/EC
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4. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• Where limit values are exceeded Member States shall ensure that air
quality plans are established to achieve the limit value.
• When the deadline has passed the AQPs shall set out appropriate
measures, so that the exceedance period can be kept as short as
possible. The air quality plans may additionally include specific
measures aiming at the protection of sensitive population groups,
including children.
• Annex XV provides information required in the AQP.
Article 23Air Quality Plans
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5. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• 1-hour limit value:
• Greater London
• South Wales
• Annual mean limit value
• 37 zones exceeded LV;
• 6 achieved LV in 2015
• Brighton/Worthing/Littlehampton,
• Blackpool Urban Area,
• Preston Urban Area
• Highland Scottish Borders
• Northern Ireland
NO2 – non-compliance with EU limit values in 2015
Defra, 2016
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6. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Source Technical Report for Draft 2017 AQP
Exceedences of NO2 Annual Mean Limit Value
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7. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• 2011 AQP: April 2015 Supreme Court declared the UK was in
breach of article 13 of the Air Quality Directive (2008/50/EC).
ClientEarth (No 1) vs Secretary of State
"The new government, whatever is political
complexion, should be left in no doubt as to the
need for immediate action to address this issue.”
Lord Justice Carnwath, Supreme Court judge
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8. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
ClientEarth (No 2) -Mr Justice Garnham’s Conclusions
i. the Secretary of State must aim to achieve compliance
by the soonest date possible, that she must choose a
route to that objective which reduces exposure as quickly
as possible, and that she must take steps which mean
meeting the value limits is not just possible, but likely.
ii. that the Secretary of State fell into error in fixing on a
projected compliance date of 2020 (and 2025 for
London);
iii. that the Secretary of State fell into error by adopting too
optimistic a model for future emissions;
iv. it would be appropriate to make a declaration that the
2015 AQP fails to comply with Article 23(1) of the
Directive and Regulation 26(2) of the Air Quality
Standards Regulations 2010, and an order quashing the
plan.
Neil Garnham
Elizabeth Trusss
SoS 2014-2016
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9. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Secretary of State to publish:
• Draft modified AQP by 4 pm 24 May 2017
• Final modified AQP by 4 pm 31 July 2017
Secretary of State applied for a time extension, firstly
due to the local Government elections and secondarily
due to the general election.
• Extension granted until 9th May
• Draft AQP published 5th May (day of local election
results)
• Final modified plan publication date unchanged
Mr Justice Garnham’s Orders
Andrea Leadsom
SoS from July
2016
Neil Garnham
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10. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
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11. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Causes of high nitrogen dioxide (NO2) concentrations
• In areas of concern:
• Transport: 80% NOx
• The largest source - diesel
vehicles
• Due to
• the significant growth in
diesel vehicle numbers
• the emissions standards
not delivering the
expected emissions
reductions.
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Photo: Emissions Analytics

12. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
2017 Draft AQPTechnical Report
Year Baseline Non-compliant
Zones
2017 37
2018 36
2019 34
2020 31
2021 22
2022 18
2023 9
2024 3
2025 3
2026 3
2027 1
2028 1
2029 1
2030 1
London,
Birmingham
Leeds
London
Includes
Manchester
Extracted from Table Ex. 2 in Technical Report13

13. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• Based on latest COPERT emissions
• Modelling used SL-PCM model based on 2013-PCM model
• 2013-PCM model under-predicts at low concentrations; over-
predicts at high concentrations.
• SL-PCM only adjusts road NOx emissions,
• Background unchanged (so will under-estimate future
concentrations
• 2015 modelling in full PCM model; 2020, 2025 and 2030
SL_PCM
• Intermediate years interpolated
• Final plan – new modelling including using a 2015 base year.
Modelling is now more realistic BUT…

14. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
2017 DraftAQPTechnical Report
Option 1st year NO2
reduction
Year Net present
value
21 CAZs 8.6 µg/m3 2020 £1,100m
Retrofitting buses, HGVs
and black cabs
0.09 µg/m3 2019 £270m
Scrappage 0.008 µg/m3 2020 -£20m
ULEVs 0.008 µg/m3 2017 -£20m
Motorway speed limits (70-
60 mpg
Up to 2.5 µg/m3 2021 -£25m to -£32m
Government buying
standards
0.0005 µg/m3 2018 £0.13m
Vehicle labelling 0.004 µg/m3 2018 £12m
Influencing driving
behaviour
0.07 µg/m3 2019 £12m
157

15. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
2017 DraftAQPTechnical Report
Measures Number of zones non- compliant zones
2017 2018 2019 2020 2021
Baseline 37 36 34 31 22
Charging-CAZs
Same as baseline
30 9
Scrappage, Eco-driving,
ULEVs, vehicle labelling,
retrofit
30 22
Speed limits, Government
buying standards
31 22
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“All options, except charging CAZs, are shown to be similar to the baseline
projection, bringing forward compliance in only a small number of zones where the
exceedance is small. It is clear that charging CAZs have the greatest impact by
bringing the majority of zones into compliance by 2021.”
Technical Report p.189

16. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• Tackling poor air quality in all its forms is a priority for government.
• The aim is to achieve the statutory limit values for the whole of the
UK within the shortest possible time.
• The objective of the UK Government alongside the devolved
administrations is to transform the UK’s most polluted cities into
clean and healthy urban spaces, supporting those most directly
affected and ensuring that vehicle manufacturers play their part to
improve the nation’s air quality.
Draft Air Quality Plan
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17. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Summary of main additional actions (Table 3) :
England
• Mandate local authorities to implement CAZs within the shortest
possible time
• Tackling air pollution on the English road network –work will begin
immediately
Wales
• Consultation on proposal for a CAZ Framework for Wales within 12
months
Scotland
• Consultation on a draft national Low Emission Framework later in
2017
• Commitment to establish a Low Emission Zone by 2018
Draft Air Quality Plan
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18. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
CAZ Framework
• Published with the Draft AQP
• Identifies that CAZs are expect
to deliver:
a) Immediate action to
improve air quality and
health by delivering the
statutory NO2 limits values
within the shortest possible
time
b) Support local growth and
ambition
c) Accelerate the transition to
a low emission economy
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19. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
a. Exploring innovative retrofitting technologies and new fuels
b. Buying ULEVs/encouraging transport operators to do the same
c. Encouraging private uptake of ULEVs via ensuring adequate
charge points
d. Encouraging use of pubic transport, cycling, walking park and
ride schemes and car sharing
e. Working with businesses/neighbouring authorities to ensure a
consistent approach
CAZ Framework: Examples of Non Charging Measures
Technical analysis suggest these measures will not
generally achieve compliance in the shortest possible time
May work were there is a very small exceedence e.g.
< µg/m3
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20. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• Non-charging CAZs – defined geographical areas uses as a focus for
action to improve air quality
• Charging CAZs – zones where designated vehicles are also required
to pay a charge to enter or to move within the zone if they are driving
a vehicle that does not meet the standard for that zone.
English CAZs
CAZ Class Vehicles Restricted
A Buses, coaches, taxis, private hire vehicles
B Class A + heavy goods vehicles
C Class B + light goods/commercial vehicles,
D Class C + cars, motorcycles and mopeds i.e. all
vehicle types
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21. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
Vehicle type Minimum Emission Standards
Buses and coaches Euro VI
Heavy goods vehicles Euro VI
Vans Euro 6 (diesel) or Euro 4 (petrol)
Cars Euro 6 (diesel) or Euro 4 (petrol)
Motorcycles/mopeds Euro 3
Emission Standards
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22. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• It is for local authorities (LAs) to develop innovative local plans to
achieve the limits in the shortest time possible.
• If a LA can identify measures other than charging CAZ that are at
least as effective these measures should be preferred.
• LAs to consider all equally effective alternatives to charging zones.
• A proposed CAZ will only be approved by Government, and be
considered for funding support if it can show that:
a. It is likely to reach legal compliance in the shortest possible time
b. The effects/impacts on local residents & businesses has been
assessed including disadvantaged groups and there are no
unintended consequences
c. Proposals that request central Government funding support
demonstrate value for money
Draft AQP
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23. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
• Draft AQP should be a modified AQP not a new one
• Ignores results of technical analysis (but this will be redone using a
2015 calibrated PCM model for the final plan)
• Put the onus on English LAs to comply
• Very vague for the devolved administrations
• Provides no information on where charging CAZs will be required
• Provides no confidence that the final plan will be compliant with the
Directive
Conclusions
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24. Brook Cottage Consultants Ltd.: Experts in Air Quality Management
V
Alan Andrews New Secretary of State
More Legal Action?
Claire Holman E:info@brookcottage.info