* Department of Environmental Health and Science, University ofthe
\
' Quality Management Research Group, Geography Department,
Abstract
This paper is concerned with the development of a theoretical perspective on air qualitymanagement and the establishment of a series of theoretical principles of air qualitymanagement. In common with a number of other advanced nations the UK is embarked upona programme to improve air quality. This paper reviews and assesses the theoreticalunderpinnings of air quality management and within this context considers the effectiveness ofthe UK programme. It considers the management principles introduced by the Environment Act,1995, and examines some of the anticipated difficulties of implementing and practising airquality management in the U.K.
Introduction
This paper is concerned with the development of a theoretical perspective onair quality management and the establishment of a series of theoreticalprinciples of air quality management. It is timely to consider the theory of airquality management as a number of nations, including the UK, are developinga new air quality management framework [1, 2, 3]. The impetus for thischange has been the gradual recognition that policies and tools developed forthe reduction of visible air pollution, typified by winter time pollution due todark smoke and sulphur dioxide emissions from domestic and industrial coalburning sources, were no longer appropriate for the management of air quality,particularly in cities. Whilst the UK can rightly claim a successful applicationof policy in regard to smoke pollution it is no longer an appropriate policyresponse for contemporary problems. Modern nation states now confront quitedifferent air quality challenges when compared to the situation appertaining 30
26 Air Pollution Modelling, Monitoring and Management
years ago. Contemporary problems are associated with the emissions of avariety of primary pollutants, with numerous and varied sources, many of whichundergo subsequent chemical transformations into secondary pollutants. Hence,a control framework, based largely on source emission controls and dilute anddisperse approaches [4] did not have the policy tools to provide an effectiveresponse this more complex air quality situation. In the UK different emissionsources tended to be controlled by separate government Departments and theirassociated agencies. This resulted in a fragmented approach to air pollutioncontrol which was particularly noticeable at the local scale [1,5]. Asa resultof this and increasing public concern, a new solution was sought which couldmake more effective use of air quality control mechanisms in an integrated andholistic manner. A framework for the integration of such a local air qualitymanagement approach has been developed and enshrined within theEnvironment Act, 1995 [6] and a National Air Quality Strategy [3] willimplement this new framework. This paper will examine the new frameworkwithin a theoretical framework of air quality management and test theprinciples of the National Air Quality Strategy against theoretical principles.
Theoretical issues in air quality management
Recent works by the authors have developed the theoretical perspective on airquality management and have started the process of identification andcodification of the principles of air quality management [1,5,7,8,9].
The effectiveness of the framework being introduced in the U.K. must beconsidered from the theoretical perspective of the processes which actuallycontrols or exert influence upon air quality [8,9]. In theory, and viewed froman anthropogenic perspective, prevailing air quality is a function of fourvariables: meteorology and climatology; geography and topography; urbanform; and emission source density and intensity. Meteorological andclimatological variables are outside of our managerial capability. Geographicalor spatial variables are important in determining air quality particularly inrelation to incoming air quality, which, in turn, is a function of emissionsources and air circulation patterns. Topography whilst amenable to humanintervention is, in the absence of human activity, a variable changing over along time scale. Urban form is a function of topography and economicdevelopment factors. Its shape will change over timescales relevant to humans.The shape can be directly influenced by managerial action over relatively shortperiods of time but significant changes occur over the medium to long term.The spatial scale of the urban form is important in determining the nature andextent of air quality. Of these variables the one most directly amenable tohuman managerial intervention is that of emissions. The density of emissionsources and the intensity of releases from individual sources can be affected bya variety of direct and indirect actions. Hence, theory suggests that air qualitymanagement has to address the density and intensity of emission sources if the
Air Pollution Modelling, Monitoring and Management 27
desired outcomes are to be achieved. Such a response will require themanagement of the urban environment and the processes affecting itsdevelopment.
Principles of air quality management
The four key principles of air quality management are emissions, impacts, cost- benefit analysis and controls. These are established and expressed within ascientific evaluatory context. Thus, air quality management is concerned withthe emission and impact of air pollutants released from human sources. Theeffect of the release is scientifically evaluated to determine effects basedstandards which provide a high degree of protection. Human health andenvironmental protection standards which result are implemented by actiontargeted at sources identified in a cost - benefit analysis. The cost of controlmust be met by the polluter. The application of the principles is dynamicallowing feedback via the scientific evaluation stage to influence the standardssetting and cost - benefit analysis stages of the process.
The acceptance of these principles indicates that not all forms ofenvironmental damage due to air pollution can be or will be controlled. Thusair quality management is the acceptance that some damage will occur andhence, it is not pollution prevention but the management of releases and theirresultant concentrations in the atmosphere at levels determined to beeconomically and politically acceptable.
The concept and application of local air quality management
There are several distinct strategies for the control of air quality which can beused in isolation or as package to provide a response to national or regionalrequirements and philosophies [4]. The general concept of air qualitymanagement is one that has been developing over recent years although thereis no universally agreed definition of local air quality management in use inrelation to the United Kingdom. Several definitioms have been offered; Laxen[10] considers local air quality management to be "the application of asystematic approach to the control of air quality issues". A fuller definitionwould need to incorporate aspects of integration, co-operation andcommunication in a system designed to consider air quality in a holistic way.It may be argued that the definition of the US State Implementation Plan (SIP)as "ongoing documents which provide a regulatory framework for each state todemonstrate to the federal government that they are on a path to attaining andmaintaining the national ambient air quality standards" [11] comes closest toa definition of air quality management in a procedural sense. Griffin [11] seesair quality management as comprising five continuous steps; definition;planning; control; implementation; and evaluation. Air quality management,however defined, is a relatively new concept for European states and it is
28 Air Pollution Modelling, Monitoring and Management
therefore, important to explore the differences between the theory and thepractice of a nation state, especially at the local scale.
A theoretical framework for air quality management
Whilst air quality management can be, and is, applied at the level of the nationstate, the spatial scale at which the issues are most acute is that of themunicipality or local authority. Hence, the application of air qualitymanagement needs to be responsive to local factors, flexible so as to allowmodifications due to new knowledge about emissions or concentrations yetstructured so as to provide a suitable framework within which all groupsconcerned with, and influencing air quality, can co-exist. Such plans require theinvolvement of agencies at a number of levels including those at the local level.These plans should enable local decision makers to choose the combination ofmeasures appropriate to local circumstances. This would enable a desirablelevel of air quality to be achieved which would be within the requirements ofregional, national and international regulations and plans. Air qualitymanagement at the local scale would thus ideally be a tier of a regional planwhich is in turn part of a national plan. Air quality management plans can betailored to the requirements of a local area, as with the US SIP system [12].Within this framework the following basic elements can be included: emissions;modelling and monitoring. In addition, air quality management providesopportunities for setting local air quality targets or guidelines, new possibilitiesfor public information and education and new mechanisms for the integrationof a wide range of local and national policies. A further essential componentof air quality management is the set of procedures for dealing with theoccasional occurrence of very poor air quality. The operation of a successfulair quality management system requires a set of mutually agreed goals and ashared vision amongst the various agencies involved. A theoretical frameworkand its guiding principles is set out in Table 1.
This theoretical framework provides a mechanism which would enablelocal decision-makers to select the appropriate policy responses to particularlocal air quality problems, consequently subsidiarity is at the heart of air qualitymanagement. In theory the process of air quality management should beviewed as a system, with feedback loops, comprising of a series of discrete,linked, operational units.
The introduction of a new framework for air qualitymanagement
Nation states like the U.K. have responded to the contemporary air qualityproblems by examining the potential of new systems for air quality control. Asearly as 1990, the Government [13] introduced the basis for a new directionfor air quality control. This was intended to build upon the existing
Air Pollution Modelling, Monitoring and Management 29
technology-based controls by adding an effects-based approach through theformulation of a series of air quality standards (AQS) to provide a frameworkin which the environmental gains from regulation could be assessed. Furtherdevelopments included consultation on air quality monitoring and managementissues culminating in the publication of a strategic policy framework forfuture air quality in 1995 [14]. The main points of this framework have sincebeen incorporated within the Environment Act, 1995 [6] which introduces theconcept of air quality management into the UK regulatory framework.
The Act sets a range of new responsibilities for local government. Firstly,they will be required to carry out periodic reviews of air quality to include bothcurrent and projected future levels of air quality. These reviews will be assessedin relation to a number of national AQSs within which air quality mustmaintained. Where an area does not, or is not likely to, achieve thesestandards, local authorities are required to create Air Quality ManagementAreas (AQMAs) and develop an action plan as a means by which air qualitywill be brought within the national standards.
In 1997, the Government published a National Air Quality Strategy [3]setting out its preferred mechanism of implementing air quality management inthe UK. In a number of important respects implementation has been devolvedto the local authority, allowing for greater powers to supplement nationalpolicies and integrate separate agencies in order to provide a balanced approachto air quality management. In order to assess the likely impact of theimplementation of the National Air Quality Strategy it is useful to assess thedegree to which the main points of the theoretical framework above are to beimplemented and to consider how the theoretical principles of air qualitymanagement find expression in the strategy. Table 2 presents a comparison ofthe theory and practice of air quality management implementation in the UKand identifies a number of important issues in respect of the translation ofNational Air Quality Strategy policy into practice.
The theoretical principles of air quality management are interpreted andpresented in the National Air Quality Strategy and Table 3 presents acomparison of the theory and practice of air quality as exemplified by theNational Air Quality Strategy.
30 Air Pollution Modelling, Monitoring and Management
Table 1: A theoretical perspective on air quality management
Goals and Objectives Clear policy goals are essential and must flow from the requirement to attainor maintain national air quality standards. Hence the overriding policy goal is the maintenance of publichealth. The objectives must be jointly owned by participating agencies various national, regional and localactors and lead to the attainment of policy goals. A flexible, evolutionary process is required.
Emissions Emissions are the key managerial variable under the direct control of airquality managers. The species of concern will be identified from effects based standards and the range ofsources at the local, regional and national level which contribute to air pollution in a local area will bedetermined by emission inventory approaches. Sources will include industrial, transport and domestic.
Monitoring The availability of monitored concentration data with which to assess currentair quality and the impacts of policy implementation is an essential precondition. National air qualitymonitoring programs may be used to check compliance with AQS and policy goals. The existing monitoringprovision of an area needs to be evaluated in the light of the policy aims and objectives. The existingmonitoring capability should not dictate the form of the air quality management response.
Standards and Guidelines Minimum standards are set by the EU or nation state but local decisionmakers may select alternative more stringent standards to work towards. These may include WHO guidelines.The legislative position is dynamic and standards at national and EU level are being re-evaluated and newrecommendations being made. In addition, new species are being introduced into the standards settingprocedure. The needs of the public and their ability to interpret the information effectively must beconsidered. In this context, effective information is defined as that which would allow the receiver to makean informed judgement of the air quality situation and thereby make personal decisions about undertakingcertain activities and actions.
Simulation Modelling Simulation modelling provides the ability to assess current and potential futureair quality in order to enable informed policy decisions to be made. Current emissions and monitoring datacan be used to validate an emissions and dispersion model which can then be used to forecast future changesbased upon a range of 'what if scenarios. The model is the key to assessing future local air qualitymanagement needs and responses.
Public Information The public must be involved in goal setting and should be informed inaccessible ways of the development of the plan and its success in improving air quality. Clear informationis needed about how the public can complain about air quality. In this way, public information will help inallowing the public to become involved in identifying problems and implementing solutions. Thedissemination of routine air quality information and the occasional poor air quality alert will require a varietyof techniques to be deployed. These include the electronic transmission and hard copy release of poor airquality alert information to agencies cooperating in managing the response, for example, health authoritiesand highway agencies and to the local and national press, television and radio to warn sensitive individuals.Routine information can be supplied to public visual display units in libraries and other places of publiccongregation.
Air Quality Alert A set of procedures to deal with the occasional acute occurrence of very poorair quality is required. The various agencies involved must decide and agree upon a number of thresholdconcentrations at which an alert system would be triggered and the nature and priority of the procedures tobe carried out in response to it. The alert procedures should be developed in such a way that they representan incremental response to a developing problem. The response of the air quality manager to a potentialepisode of poor air quality will be to attempt to stop the forecast materialising by modifying emissions ofair pollutants both within the local area and over a wider scale by cooperation with other air qualitymanagers. Should this fail then attempts could be made to minimise the peak concentration and the durationof poor air quality by progressively more stringent restrictions on polluting activities. The range and scopeof the restrictions available will have been previously agreed between the planning agent and theparticipating agencies responsible for the development of the plan thus enabling a rapid response.Simultaneously, a series of health warnings to the public will be issued to provide general advice to thepublic at large as well as advising sensitive individuals of actions to take to minimise their personal risk.
Air Pollution Modelling, Monitoring and Management 31
Planning and Air Quality Management The air quality plan must be an agreed procedure by whichair quality goals are progressively achieved across a specified time period. This period is, by necessity, longterm. The long timescale means that the land use and transport plans can be integrated within an air qualitymanagement framework and the projected outcomes of the land use and transport plans tested within itsframework. Air quality management becomes a means for integrating and testing alternatives and forreconciling economic development, land use and transport policies with air quality goals.
Sources [ 1,5,8,9]
Evaluating theory and practice in a UK context
It would be foolish to assume that a theoretical structure could be implementedin practice without compromise and change. It is however, important toconsider the nature of such change and to evaluate the consequence of suchchange for the purpose of air quality management. A theoretical framework(Table 1) provides an idealised system where coherence and integrity ofpurpose are demonstrated and the conflict of air quality policy with other policyor policies, whilst acknowledged as a possibility, are assumed to be have beenresolved.
In the real world of air quality management practice, where implementationof an air quality policy package abuts and conflicts with a range of policies inthe field of economic development, transport and land use, tensions will beexplicit and the primary purpose of the air quality policy package will be atrisk from compromise solutions. The resolution of such tensions will not beeasy and will clearly not always conform to the theoretical principlesenunciated above.
The practice of urban air quality management in the U.K. will be linkedto the land use development plans prepared under the various Town andCountry Planning Acts and to the transport policy and programme packageprocess [8]. Whilst national policy measures, such as vehicle emissions,economic instruments and emission standards will contribute to the attainmentof an AQS the main effort to improve air quality in an area of poor air qualityat risk of breaching air quality standards will come from the local level throughthe designation of an air quality management area.
The implementation of the air quality management policy package withinthe air quality management area will be the key test of how well thetheoretical principles and structure of air quality management sits within theoverall policy and implementation framework of central and local government.For it is in such areas that the solutions to air quality problems will be mostclearly identifiable and the conflicts, potential or actual, will equally be mostvisible. The strength of the proponents of various policy packages within alocal authority and the range of duties and obligations the authority has, willdetermine the overall policy outcome and the method of implementation.
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Table 2: Theory and practice in air quality management
T h e o r e t i c a lComponent
G o a l s a n dObjectives
Emissions
Monitoring
Standards andGuidelines
S i m u l a t i o nModelling
Public Information
Air Quality Alert
Planning and AirQuality
Issues and Problems in Translating Theoryto Practice
Embedding a policy framework withinexisting structures and resolving policytensions.
Setting a flexible approach to air qualitymanagement
Provision of high quality ,spatiallydisaggregated, time dated, emissions datafor screening and modelling purpose. Costconsiderations, data availability andcompatibility questions
How to use monitoring data in assessingand reviewing current and future air qualityagainst standards. Questions of: spatial andtemporal resolution; data quality;usability and cost.
Human health effect based. How do othercomponents of the environment (material,ecosystems) gain consideration? Compliancecosts?
Risk of fossilisation of standards throughslow response to emerging epidemiology/human health impacts data.
Complexity, reliability, cost and competencyquestions.
Trust and reliability; effectiveness ofmessage.
Strict procedures for managing an event ofvery poor air quality. Significant potentialfor policy / implementation disagreementand conflict. Possibly compromising abilityto make and implement decisions.Questions of public acceptability wherepersonal mobility is restrained.
Gains in air quality will be realised throughintegrating air quality management into theland use and transport planning. Air qualitypolicies will be difficult to integrate intothese decision making processes.
Practical Activity or Guidanceon Implementation in UK
National Air Quality StrategyConsultation Paper: DevelopingLocal Air Quality Strategiesand Action Plans. GuidanceNote: General Principles ofReviewing and Assessing AirQuality
Publication of the WestMidlands AtmosphericEmissions Inventory
Guidance Note: GeneralPrinciples of Reviewing andAssessing Air QualityConsultation Paper: DevelopingLocal Air Quality Strategiesand Action Plans.
Consultations on: The AirQuality Regulations 1997;Review of Local AuthorityPowers; Implications of theNitrogen Dioxide Report fromEPAQS.
No specific guidance issued yet.
Consultation: Air Quality PublicInformation System for the UK
No specific guidance
Consultation Papers: LocalAuthority Circular on AirQuality and Land Use Planning;Local Authority Circular on AirQuality and TrafficManagement.
Air Pollution Modelling, Monitoring and Management 33
Table 3: Air quality principles in the National Air Quality Strategy
Principles set out in theNational Air Quality Strategy
Sustainability
Health Based
Risk assessment
Sound Science
Proportionality
Polluter Pays
Precautionary Principle
Subsidiarity
Commentary
The air quality management process must contribute toattainment of sustainable development
Environmental quality objectives proportionate to risk are
Exposure assessments are used to set objectives.
International robust and peer reviewed science providescontext of risk assessment.
Measures proposed should be proportionate to their outcodetermined via cost benefit analysis.
The costs of measures taken to manage air quality shouldreflected in the cost of polluting goods and services.
Where risk is judged potentially great then action shouldtaken even where scientific knowledge is not conclusive.
Measures should be taken at the most appropriate level.
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the
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Conclusions
A theoretical framework and a set of principles for local air qualitymanagement in the UK has been presented and a discussion of the variouscomponents involved has been offered. The means of developing andimplementing air quality management in the UK, especially at the municipalscale is now in place through the Environment Act 1995 and the National AirQuality Strategy. It is recognised that there will be difficulties in attemptingto introduce air quality management policies into an existing policy packageand that, inevitably, compromise and pragmatic responses delivering somegains, if not all that the theoretical principles promised, will be introduced.This emphasises the need for an integrated approach and the importance ofaction at the local scale, particularly within partnerships. There remains a needto incorporate air quality management principles within the policy packages andprocesses of a range of central and local government departments and agencies,such that air quality becomes not an additional issue, to be considered at theconclusion of an economic or transport policy debate, but an issue whichprovides a context for the determination of other policy packages. This position,conforming to the principles of air quality management is arguably some wayoff and it may be speculated that the early phase of air quality management inthe UK will have limited coherence with the theoretical principles. However,as air quality management develops and becomes a central component of otherpolicy making processes greater coherence with theoretical principles may beexpected. The timescale over which this may occur can not, at present, beanticipated.
34 Air Pollution Modelling, Monitoring and Management
Key words: Air quality management , Theory, Principles, UK.
References
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