Calderdale Council has sent Labour's air pollution plan back to the drawing board. The plan had a number of major flaws in it. As such it would have been inadequate at addressing Calderdale's air pollution problems. The plan will now go back to the drawing board for improvements, before coming back to Council.
We have the following concerns about the plan:
1. It contained no clear dates for completing actions to improve air quality. In the Estimated / Actual completion date column, many actions simply have no entry. As shown below a few actions simply have the entry as being 'date'.
2. No evidence of an impact assessment or the methodology used is included within the report. Whilst we are aware of how much we need to reduce air pollution to meet statutory requirements, the report does not state whether the interventions will meet these objectives. It does not even predict what the shortfall will be.
Many of the impacts are listed as being 'neutral', others are given vague categories such as 'moderate' or 'significant' with no prediction of the likely pollutant levels after the intervention, or the percentage decrease. All of these points were raised by Defra in the formal consultation to the plan. They can be read on page 59 of the report. The administrations attempt to address these points is clearly insufficient.
Some of Defra's many criticisms:
"The Technical Guidance TG(16) states that the Local Authority should subject their AQAP measures to an impact assessment that provides a clear estimate of the emissions reductions the measures may be expected to deliver within an agreed timescale.
It is also expected that there will be an assessment of whether the package of within the AQAP can expect to meet air quality objectives. These are expected to be reflected within a final action plan and future ASR reports.
There is no evidence that the measures presented in Table 5 have been assessed for their impact and potential effectiveness to reduce emissions in the AQMA, and emissions reductions have not been quantified to an agreed timescale. "
3. The report makes no mention of air pollution sources other than traffic. Whilst traffic pollution makes up a sufficient amount of air pollution it is not the only source. Woodburner stoves and coal fires also contribute. As do some industries. The Council has statutory powers in relation to the enforcement of the Clean Air Act 1993 and the enforcement of smoke control areas. There is also a significant problem with people burning building waste in Calderdale. This should form part of our general enforcement activities. This issue is not addressed in the report.
4. The report fails to set out an adequate plan for monitoring air pollution levels. There are now readily available dual laser air sensors. These networked devices upload their data straight onto the cloud and onto websites. We could easily monitor air pollution in real-time. Furthermore, these devices measure PM 1 and PM 10 alongside PM 2.5 which is mentioned in the report. Currently, no local authority in the UK measures PM 1 levels. These devices have been used in Salt Lake City in Utah to good effect. Details on how they are used can be found here.
For these, reasons we are glad the report is being sent back to cabinet. If some of the issues we are raising here are incorporated into a revised report then the outcome will be an improvement in the air quality in Calderdale.