9. Governance, Accountability and Delivery
183. Within both central and local government, air quality is a cross-cutting issue which has intricate connections with many other policy areas. It follows that, to deliver continued and sustained reductions in air pollution, there must be effective and consistent coordination across these policy areas. Although much progress has been made in this respect over recent years, the CAFS review made it clear that there is still more to do.
184. At central government level, the NTS2, NPF 4 and the updated Climate Change Plan will provide a clear, well-defined focus for building on achievements to date. In addition, the new National Nitrogen Balance Sheet (see para 21) will quantify nitrogen use efficiency and losses across all sectors of the economy and environment. At local level, positive developments could also be achieved through consideration of how to ensure better recognition and integration of air quality across the various disciplines to more effectively and efficiently deliver air pollution reductions and associated benefits.
185. Specific issues for consideration at local level include the extent to which local authorities have air quality policies within their development plans and/or guidance documents, how many City Deals have air quality objectives and initiatives and how widespread and effective joint authority working at the regional level is. This could result in shared learning for how local government engages, delivers, measures progress and gains credit for delivering change on air pollution.
Local Air Quality Management
186. The Local Air Quality Management (LAQM) system is the main focus for air quality action at the local and regional level. Under LAQM, local authorities are legally obliged to assess air quality in their area, designate Air Quality Management Areas (AQMAs) where objectives are at risk of or not being met, develop air quality action plans for dealing with the issues identified in AQMAs and report regularly on progress towards achieving compliance with the objectives.
187. The LAQM system has been periodically reviewed since its establishment across the UK in 1997, most recently in 2016 with the publication of revised policy and technical guidance and the introduction of a more streamlined approach to annual reporting. Although the monitoring and reporting aspects of LAQM continue to work effectively, with a large, comprehensive body of air quality data available covering Scotland over a number of years, the CAFS review suggested that air quality objectives could be made to apply in all places with public access (as is the case for EU air quality standards) as opposed to the current approach which restricts application to places where members of the public have regular access. This could potentially increase the level of human health and future land use protection delivered by LAQM and also simplify the communication of air quality issues.
188. Currently, there is an inconsistency in the level of protection from air pollution afforded to people depending on their location. Much greater weight is given to residential settings as opposed to other settings with public exposure with, generally speaking, higher thresholds set for the latter. There is also a disconnect between environmental health and health and safety legislation. Taken together, these two disparities mean that individuals are often subject to air quality in the workplace, or when shopping or partaking in leisure activities, that would not be permitted in a domestic context. In many ways, this is a legacy of estimating exposure based on the fixed monitoring network and modelled estimates, due to the difficulties of taking into account people's mobility. As the body of data on mobility continues to grow, and the technology to make use of these data continues to develop, we need to consider how we can better match policy and guidance to the ways in which individuals actually move about in and interact with a variety of spaces.
189. In addition, the review highlighted some ways in which action planning could be made to work more effectively. At present, there is no standardised format for action plans in the way there is for annual reports. There is also no systematic approach to reporting on progress with implementing action plan measures or reviewing overall plans, nor for setting and agreeing target dates and timelines. Local authorities are not legally required to achieve the air quality objectives but simply demonstrate they are doing all that is reasonably possible to work towards them, mainly because some sources of air pollution are outwith direct local control such as SEPA controlled processes and trunk roads managed by Transport Scotland. This means that any obligation to complete action plan measures to specific timescales will need to be delivered through guidance rather than legislation.
- Assess the advantages and disadvantages of extending LAQM assessment to all areas with public access, to provide the necessary evidence base on which to make a decision on whether this would deliver overall benefits.
- Undertake a further revision of the LAQM policy guidance to take account of developments since the last update in 2016.
- Develop a more systematic approach to action plan production and implementation, including a standardised format and a methodology for agreeing and setting defined timescales for completing individual measures, revoking AQMAs and reporting progress.
190. There was no formal role for the Scottish ministers in the governance structure for CAFS, a gap highlighted by the independent review. The Ministerial Leadership Group, which was established to oversee Low Emission Zone delivery in Scotland's four biggest cities, has proved to be effective in ensuring that high level accountability is in place, with a clear link to delivery bodies. An air quality Ministerial Group will be led by the Cabinet Secretary for Net Zero, Energy & Transport, and the Minister for Environment, Biodiversity & Land Reform. Additional membership will comprise ministers from other portfolios for consideration of specific issues (e.g. health, planning, agriculture), senior central and local government representatives, government agencies and external advisors. This would provide for greater partnership working between central and local government and across the relevant portfolios. The Ministerial Group will meet at least once a year and will be serviced by a secretariat to bring and take advice and action reports, as well as escalate action delivery and performance issues.
191. Transparency and public accountability are essential. Visible authority and leadership at ministerial level is a key component of this, as is an implementation structure within which it is clear who is responsible for what and the steps that can and will be taken to drive delivery. The Governance Group which oversaw CAFS will be renamed the CAFS 2 Delivery Group. The Delivery Group will be chaired by the Scottish Government, and the membership will reflect the scope and priorities of the new strategy. The Group will be directly accountable to the Ministerial Group and will be provided with a clear remit, including the authority and defined procedures to ensure that the actions in the new strategy are effectively delivered, and a description of how its advice is conveyed to the Scottish ministers. The Delivery Group will also need clear targets and KPIs.
192. The Delivery Group will in turn be supported by specialist subgroups which will meet on an ad hoc basis. The subgroups will provide advice and recommendations on delivery of CAFS 2 actions and provide any other input to the Delivery Group which that group requires or otherwise deems appropriate. The topics covered by the subgroups are likely to be wide-ranging, covering, in particular, climate change, agriculture, placemaking, human health, industry, transport and the natural environment.
193. In order to objectively judge the effectiveness of this delivery structure, a complementary reporting mechanism will be required. Building on the model of the annual progress reports produced for CAFS, there needs to be a simple line of sight from strategy to planning, through delivery and ownership of actions to ultimate accountability. All of this will be reflected in a revised and strengthened annual performance report which will be approved by ministers and submitted to Parliament.
- Establish a Ministerial Group to provide high level leadership and direction for CAFS 2.
- Establish a Delivery Group with a clear remit and well defined responsibilities for ensuring that the actions in CAFS 2 are delivered.
- Establish a series of specialist groups to provide advice to and support the work of the Delivery Group.
- Produce an enhanced and strengthened annual performance report documenting progress in implementing CAFS 2.
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