Assessing the contribution of LAQM to environmental justice in England and Wales
Ioanna Gegisian - July 2007
The project combined environmental pollution and social data to provide an insight into how air pollution is distributed and experienced across the different social strata. It sought to determine whether there was a pervasive trend of inequality resulting from environmental policy decision making. It was restricted in its application to the Local Air Quality Management Framework (LAQM) and its associated structures within England and Wales. The term commonly used to express social equity in environmental legislation and policy is Environmental Justice (EJ).
LAQM is the procedure established by the UK government to combat air quality problems at the local level (Defra, 2003). The statutory framework that established the LAQM process and the Air Quality Strategy (AQS) was the Environment Act 1995 (HM Government, 1995). It set Air Quality Objectives (AQOs) and standards for eight pollutants: benzene, 1,3 butadiene, carbon monoxide, nitrogen monoxide, lead, particles as PM10, sulphur dioxide and ozone; however ozone is not included within the LAQM framework (Defra, 2003). The AQS set the framework of LAQM and stated that Local Authorities (LAs) are under a statutory duty to assess and work towards improving air quality where it breaches AQOs.
Environmental management mechanisms, such as LAQM, can be effective in reducing overall pollution levels; however they do not specifically take into account social issues. The importance of considering social impacts is due to inequalities that may rise in the distribution of pollution impacts across the different social strata arising from the implementation of management regimes. Environmental policies do not necessarily respect the different social circumstances or the need for different levels of protection for different groups in society. The project addressed these issues by examining the relationship between social deprivation and environmental quality in the context of the LAQM .
LAQM's contribution to EJ was investigated by assessing LA efforts in fulfilling their requirements under this framework. Part of LA s responsibilities, under LAQM, is to designate Air Quality Management Areas (AQMAs) where AQOs are not likely to be met and produce Air Quality Action Plans (AQAPs). AQAPs are designed to improve air quality through the implementation of a set of measures (Defra, 2003).
The research project evaluated the LAQM contributions to EJ in two ways. The first was to assess the relationship between deprivation and the presence of AQMAs. The second was to assess LAs ability to detect and take account of the relationship between deprivation and presence of AQMAs in their decision making when applying the LAQM regime.
In order to explore the relationship between deprivation and AQMAs a Geographical Information System (GIS) was utilised to produce digitised maps of AQMAs. The Index of Multiple Deprivation (IMD) 2004 and its Welsh equivalent were selected as deprivation indicators for this research project. The indices were developed for the UK Government to compute deprivation at a small area level (Office of the Deputy Prime Minister, 2004; National Assembly for Wales, 2005). The LAQM practices of LAs were examined through a questionnaire survey, appraisal of reports and selected case study interviews.
The methodological techniques were selected after careful consideration of both their advantages and limitations. The structure and content of the questionnaire was checked through a pilot study to ensure its suitability. The GIS protocol used to digitise and select appropriate deprivation and population data enabled the assessment of the relationship between social deprivation and AQMAs. The AQAP report appraisal was systematic in its design and application with the assumptions accounted for in the presentation of the results. The case study interviews were linked with the questionnaire through a selection process that accounted for the different rounds in the LAQM framework as well as the geographical locations and structure of LAs. The case studies gathered information on the production of AQAPs and issues relating to EJ. A thematic analysis of the interviews enabled a comparison between different LAs and highlighted concerns over the AQAP process and consideration of social impacts; it also assisted in the assessment of LAQM EJ credentials.
Results and discussion
The methodology successfully addressed the aims and objectives and revealed a series of issues regarding AQAP s and the consideration of social impacts in the decision making process of LAQM . The deprivation analysis established a link between AQMA s and deprivation levels. This was found to be most prevalent when using regional statistics presumably due to the nature of the data and the available statistical tests. AQMA s were characterised by a range of deprivation with a clear trend towards the more deprived areas overlapping with an AQMA declaration. Specifically, a quarter of the deprived areas in England and Wales were coterminous with AQMA s. This confirmed anecdotal evidence and previous research that areas of high air pollution are likely to experience high levels of deprivation. Additionally about one fifth of the English and Welsh people were found to live in Air Quality Management Areas. The management practices of LA s – the second aim – were investigated by combining the deprivation analysis results with the questionnaire survey, AQAP appraisal and case studies.
Although the research revealed considerable variation, the AQAP s format and content is designed to satisfy government guidance. Reservations were raised regarding the nature and scope of guidance available with some LA s expressing the need for more prescribed guidance and others requesting more flexibility. LA s efforts to coordinate between departments and with other institutions often resulted in a more efficient and successful AQAP process. Notably transport and planning departments have become involved in the AQAP process. This was partly due to a new government initiative to integrate AQAP s with Local Transport Plans (LTPs). The integration efforts, according to the research, have not been widespread; however it is expected that this is likely to improve with time. Environmental health departments in LA s, that are responsible for implementing LAQM , were in favour of integration of AQAP s with LTP s. Judging the overall success of AQAP s was problematic for a number of reasons. The majority of the mitigation measures included in the plans stemmed from other LA strategies or were considered tentative. The nature of the measures in conjunction with the lack of information on implementation did not allow a rigorous analysis.
The main focus of the AQAP s analysis was to assess whether LAs consider social impacts and whether the LAQM framework contributes to EJ . According to the results reported here LAs do not appear to consider social impacts, at least not explicitly, when prioritising measures in AQAPs. This is not surprising as consideration of social impacts does not feature prominently in the guidance provided by Government. The degree to which such impacts were considered was explored through the derivation of an EJ score. This was based on LAs efforts to coordinate (through related strategies and communication with socially related disciplines like health, sustainable development), consult with the public and to directly employ social data. According to EJ score, 2 AQAPs were rated excellent whereas 44% were considered limited. In addition the views of LA officers on the use of such data were also included to ensure that any recommendations were practical.
Public consultation has been identified as a way of collecting local knowledge and an indirect way of using social data. Results on public consultation confirm that LAs report on their activities to stakeholders; however it is still uncertain whether the public consultation outcomes significantly influence decision making. The use of social data in AQAPs was found to be scarce. LAs views in applying social data were in the main negative as they expressed concerns over the funding and expertise that would be needed. However such data have been employed in some LA departments and, potentially, can exert an influence through better coordination with departments such as community development, neighbourhood renewal and regeneration.
EJ has the potential to be a factor in any management framework, but in the case of AQAP s it was difficult to quantify an EJ contribution as there were no means of assessing implementation. Taking the outcomes of the research into account, a conceptual model of AQAP production and implementation has been constructed. The model identifies the connections between air quality considerations and social equity issues. Utilisation of the model will allow LA s to develop actions and strategies that better incorporate consideration of the impacts of the measures in terms of social equity and EJ .
The conceptual model identified a key role for public consultation as this can be used to identify the public’s views as to which locations are highly polluted and highly deprived. In terms of AQMA s, deprivation and population data can be incorporated in the declaration mechanism to highlight areas with high deprivation and high air pollution. Better coordination between LA departments and especially with initiatives such as neighbourhood renewal and regeneration, can offer a more informed choice of measures. Finally, communicating the AQMA declarations and the AQAP mitigation options to the public could ensure the decision making is more transparent.
The LAQM framework has succeeded in identifying AQMA s and producing AQAPs that meet government requirements. However the LAQM contribution to EJ could not yet be quantified mostly due to slow implementation by LAs. The inclusion of social considerations in LAQM decision making was scarce and the conceptual model constructed in this research has the potential to deliver a positive change in practice.
A series of recommendations to Defra, LAs and the EA were identified:
- Defra can improve the efficiency of LAQM and specifically the production of AQAPs by producing a clear timetable and procedures on LTP integration. This should complement the information found in the 2005 LAQM policy guidance addendum (Defra, 2005). County Councils that are responsible for transport planning in District Council AQMAs should be given incentives, potentially through a review of LTP budget to include district AQAPs in their LTP.
- Defra can consider updating guidance on AQMAs to a more prescribed format to ensure uniformity in declarations. This should include how to take account of pollution levels, modelling outputs, population exposure and consultees views in selecting boundaries. In addition incorporating population density, extent of exceedences and deprivation levels in the declaration criteria, the highly disadvantaged areas, in terms of environmental quality, social deprivation and population density, can be identified and targeted.
- Defra should continue promoting policy integration, as exemplified by the LTP process. Emphasis should be placed on sustainable development strategies and climate change mitigation and adaptation strategies. The integration efforts should coincide with a review of all strategies produced by LAs that relate to environmental management. Consultation with LAs on the timetable, budget, staff responsibilities and individual requirement relating to the LA structure should be discussed prior to any new policies.
- The distribution and density of the air pollution monitoring network should be reviewed by Defra to establish how it relates to the social make up of the resident population. This should include the Government’s automatic monitoring network (AURN) as well as any LAs monitoring equipment that do not form part of official network. Defra should also consider consulting with the public to ascertain their views on the network. This can be achieved through coordination with LAs.
- Defra should consider in the long term, the review of primary legislation regarding LAQM and specifically AQAPs to ensure that the process is efficient and clearly accountable. The research project was unable to review the effectiveness of AQAPs because of a lack of apparent implementation.
Local Authorities (LAs)
- LAs can consider promoting a person to lead AQAP production. This figure can be a highly ranked LA officer that coordinates the production and implementation of the AQAP. Defra can promote this by issuing recommendations and LAs can implement it as it is likely to improve coordination between different departments.
- LAs should consider using social data in the prioritisation of AQAP measures. The social data that can be used are population density and deprivation level; this would aid the identification of areas affected by numerous negative parameters and assist in them being given a priority status.
- LAs have improved their efforts to co-ordinate plans and strategies and should continue to do so Specifically the environmental health/protection department, that is usually responsible for all LAQM commitments, should start consulting with departments such as neighbourhood renewal and regeneration that deal with disadvantaged and problematic areas.
- LAs should continue their public consultation work and consider the outcomes of such work in their decision making. An agreed means of including the views of the public in selecting measures should be developed by Defra in conjunction with LAs.
- The Environment Agency can contribute to a more equitable LAQM Framework by continuing to provide up to date information on industrial pollution to LAs. In other aspects of Agency’s work social data are a possible parameter in judging the potential severity of pollution incidents. In addition, in its role as a consultee to LAs, the Agency can actively encourage consideration of EJ and inquire whether social data have been used in any environmental assessment, and specifically in the production of AQAPs.
This research project in its efforts to address its objectives uncovered a number of potential areas of further work. These are:
- This project investigated EJ within the LAQM framework and appraised AQAPs, the mitigation strategies. AQAPs are affected by a number of departments such as planning and transport. Development plans, such as regeneration programmes or major planning work within an authority can be examined in the realm of EJ. Different examples of air pollution circumstances can be used and compared with the deprivation levels of the area under consideration. In this way any EJ issues emerging from these practices can be highlighted.
- LA departments can be examined in terms of their EJ contributions. Local policies relating to EJ can be examined in detail to establish a conceptual model for the entire range of decision making in LAs.
- A review of the distribution of the air pollution network according to population density and deprivation level can potentially identify areas that were neglected due to monitoring being based in circumstances that do not reflect the social make up of the current location.
Defra (2003), LAQM.PG (03): Local Air Quality Management. Policy Guidance. London: The Stationery Office
Defra (2005), Policy guidance addendum LAQM: PGA(05). London: The Stationary Office
HM Government (1995), Environment Act 1995, Chapter 25. London: The Stationery Office
National Assembly for Wales (2005), Welsh Index of Multiple Deprivation. Cardiff: National Assembly for Wales
Office of the Deputy Prime Minister (ODPM) (2004), The English Index of Deprivation 2004. Wetherby: ODPM Publications
I. Gegisian, M. Grey, J. Irwin & J.W.S. Longhurst (2006) Environmental justice consequences of the UK’s local air quality management (LAQM) system. In Longhurst, J.W.S. & Brebbia, C.A. (Editors, 2006) Air Pollution XIV. WIT Press. Southampton and Boston. pp175-183.
I. Gegisian, M. Grey, J. Irwin, & JWS Longhurst (2006) Environmental Justice in England and Wales- Implementing the Local Air Quality Management system and its impacts on social deprivation. 9th World Congress on Environmental Health, (18-23 June 2006, Dublin, Ireland)
I. Gegisian, M. Grey, J. Irwin, & JWS Longhurst (2005) A preliminary investigation of local air quality management and environmental justice in England and Wales. In Brebbia, C. A. (Editor) Air Pollution XIII, WIT Press, Southampton and Boston pp.149-156.
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