Summary of responses to consultation on air quality plans to meet EU
Limit Values for nitrogen dioxide in Scotland
October 2011
Background
1.
On 9 June 2011, the Scottish Government published a consultation on
actions being taken at local, Scottish and UK levels that will help meet the
hourly and annual EU Limit Values for nitrogen dioxide as set out in the
Ambient Air Quality Directive 2008/50/EC. The consultation included a UK
overview document and technical report, a UK wide table of measures and
four air quality plans covering Edinburgh, Glasgow, Central Scotland and
North East Scotland. The consultation documents can be found at
http://www.scotland.gov.uk/Publications/2011/06/07111812/0
Similar consultations were undertaken in England, Wales and Northern
Ireland. The consultation closed on 5 August 2011.
Consultation responses
2.
10 responses to the consultation were received in Scotland. A list of
respondents is at the end of this summary. The table below summarises the
main issues raised in Scotland and the Scottish Government’s response.
Next steps
3.
The UK made its submission to the European Commission on 22
September 2011. The submission included the UK wide documents and the
40 air quality plans for England, Scotland, Wales and Northern Ireland. For
those plans where compliance by 2015 can be demonstrated, we are seeking
postponement of the compliance date for up to five years from January 2010.
The Commission has up to nine months to assess the submission. In the
meantime all possible actions to hasten progress towards full compliance in
all zones are being explored.
Issue
Summary of responses and Scottish Government
response
Fulfilling the Several respondents noted that the application does not meet
requirements the requirements for a time extension because some plans
of a time
demonstrate compliance beyond 2015.
extension
SG response: All the UK administrations are committed to
under Article working towards compliance with the Limit Values as soon as
22 of the
possible. This is an extremely challenging task and is one
Ambient Air
faced by most other Member States.
Quality
Directive.
Article 22 of Directive 2008/50/EC allows postponement of
the attainment date for NO2 by up to five years from January
2010 where plans demonstrate compliance by then. The
introduction to the UK overview document makes clear that
the European Commission advised Member States also to
Some local
air quality
action plans
are out of
date.
Local
authority
monitoring
data were
not used in
the
application,
with an overreliance on
modelling.
Road
transport
emission
factors used
in the
modelling
work.
submit plans for zones where full compliance is predicted
after 2015. Plans for such zones have been submitted under
Article 23 of the Directive on the basis that they set out
actions to keep the exceedence period as short as possible.
Some respondents noted that the most recent versions of
local authority plans are not included in the submission.
SG response: The technical work to gather information
required for the zone plans started in early 2009 and
continued through that year. This means that, given the large
number of plans that had to be prepared and the constraints
of the consultation timetable, it was not possible to include
plans updated or published in 2010 or 2011.
Most respondents highlighted that modelled exceedences,
source apportionment and future projections were based on
AURN monitoring data only and took no account of local
authority data. This was considered to result in an over
optimistic view of the compliance situation, with many
exceedences detected through local monitoring not being
picked up by the national modelling.
SG response: The air quality plans were developed using
information from the UK monitoring network (AURN) and the
UK modelling methodology. Whilst it is acknowledged that
most local authority sites in Scotland are operated to AURN
standard through the Scottish Air Quality Website and
Database project and would thus meet the requirements for
assessment in terms of operation and QA/QC, location of
these sites is generally based on the requirements of LAQM
which may not always coincide with the locational
requirements of the Directive. Additionally, fewer local
authority sites elsewhere in the UK are operated to AURN
standards. Given that compliance assessment must be
undertaken in a standardised way to satisfy the requirements
of the Directive and that the assessment is done for the UK
as a whole, it is considered appropriate to use the AURN as
the basis for assessment.
Nevertheless, local authority data do have an important role
to play in assessment at Scottish and UK levels, and this is
reflected in the inclusion of local authority action plans in the
submission.
Most respondents stated that the road transport emissions
factors used in preparing the plans show an over optimistic
compliance situation for 2015.
SG response: It is made clear in the submission documents
that actual emissions reductions are less than those projected
using the UK National Atmospheric Emissions Inventory
emission factors. However, this is the best currently available
information on which to base the assessment. The Scottish
Government and the other UK administrations are aware of
the need to address these issues and we are currently
The Low
Emission
Zone (LEZ)
Framework.
Other
measures.
working on updated emission factors. Further information on
this work will be provided in due course.
Although general support was expressed for a UK wide LEZ
framework, there was some concern that uneven uptake
could lead to older vehicles being concentrated in areas
without LEZs.
SG response: Work continues on developing a possible LEZ
framework. Should it be decided to take this measure
forward, a further consultation will take place on the specific
proposals.
Respondents, whilst being broadly supportive of most of the
proposed measures, generally felt that more needs to be
done. Various suggestions for further measures were made
e.g. removing vehicle excise duty incentives for diesel,
incentives for electric vehicle takeup, achieving greater
reductions in business travel, road user charging, specifying
procurement of low emission vehicles for the public sector.
There was also a general feeling that the measures could be
more focused, with no real prioritisation or impact
assessment.
SG response: Suggestions for additional measures are
welcome and, whilst not taken forward as part of the
submission, will be considered during wider policy
development.
Synergies
and tradeoffs with
climate
change
measures
and other
policies.
Impact of measures has been quantified as far as possible.
In some cases, measures have not been in place long
enough for their impact to be assessed, or are still to be
introduced. In other cases, particularly where air quality
improvement is not the main policy aim, either the air quality
impact was not possible to quantify or the information not
available.
There was some concern about the possible adverse impact
on air quality of measures intended to tackle climate change,
especially biomass policy and specifically the Renewable
Heat Incentive (RHI).
SG response: The importance of ensuring that air quality
and climate change policies complement each other as far as
possible was discussed in detail in Air Pollution: Acting in a
Changing Climate which was published by the UK
administrations in March 2010. The Scottish Government’s
position in relation to the air quality impacts of biomass has
also been widely publicised. From October 2012, eligibility
for the RHI will be subject to compliance with emission limits
for particles and NO2.
Respondents
Aberdeen City Council
Ashley Lloyd
City of Edinburgh Council
Dundee City Council
Falkirk Council
Fife Council
Scottish Water
Scottish Environment Protection Agency
Transform Scotland
WWF Scotland