Air quality strategies: What are they, who will need one and how do they differ from AQAPs?

2023 is set to be an exciting year, marking the year of the Rugby World Cup, the UK hosting the Eurovision Song Contest, and the cherry on top: the UK government mandated requirement for local authorities in England¹ to produce a local Air Quality Strategy.

From 2023, local authorities without AQMAs (Air Quality Management Areas), including those in the process of revoking their AQMA(s), are required to produce a local Air Quality Strategy. The requirement relates to local authorities in England and was included in the recently updated local air quality management (LAQM) Policy (PG22) and Technical Guidance (TG22). It reads as follows:

“Those authorities who have not had to designate AQMAs and produce AQAPs will from 2023 be required to draw up a local Air Quality Strategy. These strategies will not have a set format and authorities will be able to draw on content within their ASRs and local transport plans to produce them.”²

Where local authorities revoke AQMAs (and no longer have any in place), they will be required to produce an Air Quality Strategy “to ensure air quality remains a high-profile issue and to ensure it is able to respond quickly should there be any deterioration in condition”.³

It is currently unclear how the requirement will be monitored, and whether further guidance will be issued by Defra in due course.

For now, to contextualise what this means for authorities in England, we consider below what an Air Quality Strategy is, and how they differ from AQAPs.

What is an Air Quality Strategy?
Air Quality Strategies (AQS) are not a completely new concept to LAQM, or to national air quality governance. On a national level, the Air Quality Strategy for England, Scotland, Wales and Northern Ireland (2007) sets out air quality objectives, policy options and a long-term agenda to improve air quality in the UK. (A revised version of the Strategy is due for publication by 1 May 2023, in line with statuary requirements of the Environment Bill 1995 (as amended in 2021)).

On a local level, in the previous LAQM Technical Guidance TG(16), a recommendation was included for local authorities in Wales and Ireland, particularly those without AQMAs but with areas close to air quality objectives, to draw up a local air quality strategy.  It was recommended that progress against local air quality strategies be reported in annual progress reports.

Prior to the formal requirement being introduced, Ricardo has worked with local authorities for a number of years to develop robust Air Quality Strategies that focus on specific problems or areas of concern for councils. Informed by this experience, we would define an AQS as a committed plan of action to consider air quality at a local government level, with the intention of achieving a long-term goal or overall aim in relation to air quality within a local authority area. An AQS encompasses many of the same characteristics as an AQAP, except where AQAPs aim to achieve compliance, an AQS will likely have a wider aim, which is up to the local authority.

Common aims local authorities can look to address through a well-defined strategy include:

• Demonstrating commitment to keeping pollutant concentrations below objective levels
• Strengthening and integrating with other objectives strategies and policies, particularly those relating to transport, planning, climate change and public health
• Improving collaboration with neighbouring authorities to address shared sources of air pollution, or sources which can be better managed at a regional level.

What is the difference between an Air Quality Action Plan (AQAP) and an Air Quality Strategy (AQS)?

What should affected local authorities be doing now?
Now is a good time for local authorities to take action and start putting their Air Quality Strategy together. Following the advice from Defra that local authorities draw on content from ASRs, we would suggest that the initial drafting of the new AQS could be carried out alongside drafting of your local authority’s 2023 ASR, due at the end of June. Our suggested milestones to complete and publish an Air Quality Strategy in 2023 are:

• March: Start to plan who will be responsible for the AQS delivery. Consider what the overall vision and aims of the AQS will be
• June: Start AQS drafting, using relevant information from the 2023 ASR and other relevant policies and strategies
• September: Complete AQS draft
• October/November: Complete consultation process and implement any required changes
• December: Publish the final AQS

At present, it remains to be seen if Defra will provide further advice regarding Air Quality Strategies. Until such time, we recommend contacting the LAQM Helpdesk if you have any questions.

How can we help?
At Ricardo we have helped local authorities develop Air Quality Strategies which serve as both an informational resource on local air quality, and a tool to ensure that air quality is a cross-cutting theme considered throughout all local authority activities. In addition, Ricardo also run the accredited EMAQ+ air quality management programme, providing professional training and technical guidance for Air Quality Management professionals who have responsibilities under Part IV of the Environment Act 1995 and related regulations.

To discuss how Ricardo could help your organisation develop an Air Quality Strategy, or for more information about our training courses, please get in touch.

Footnotes
1 Defra LAQM “What’s New” web page - laqm.defra.gov.uk/whats-new/
2 LAQM Policy Guidance 2022, para 2.15 - laqm.defra.gov.uk/wp-content/uploads/2022/08/LAQM-Policy-Guidance-2022.pdf
3 LAQM Policy Guidance 2022, para 4.12 - laqm.defra.gov.uk/wp-content/uploads/2022/08/LAQM-Policy-Guidance-2022.pdf