Will we ever understand road vehicle pollution?

Alaric Lester

Principal Consultant (Air Quality)

When the UK’s first national air quality strategy was published in 1997, the country finally had a framework for dealing with air pollution. European and national policies and standards were expected to deal with the majority of problem areas, while local authorities would sort localised hotspots. Road vehicles were the predominant source of air pollution, but experts expected air quality problems to be all but gone by 2010.

How did we progress? With carbon monoxide, the advent of catalytic converters in the 1990s quickly removed any areas of high concentrations. For PM₁₀ – particles smaller than ten microns, which are possibly of more concern for health across Europe than any other airborne pollutant – progress has been slower. PM₁₀ levels have fallen steadily but slowly, and there are still more than 100 PM₁₀ air quality management areas (AQMAs) – areas that local authorities have identified as not meeting set standards.

For nitrogen dioxide (NO₂), progress has been well short of even pessimistic expectations. Data from the national Automatic and Urban Rural Network and London Air Quality Network tell a story of diminishing returns. After some early progress up to around 2005, NO₂ levels have been static or even increasing ever since. There are now well over 500 AQMAs for NO₂ across the UK. The European Commission has threatened infraction proceedings against the UK government for failing to deal with NO₂ problems. Road vehicles remain the predominant source of NO₂ and PM₁₀.

Fifteen years ago we thought we had a reasonable understanding of vehicle emissions. Now, owing to rapid developments in engine and emissions abatement technology, our understanding is arguably worse. Regulations on vehicle emissions limits are based on idealised tests that bear no resemblance to real-world driving; measured real-world vehicle emissions data is scarce; and most experts agree that UK and European emissions factors for road vehicles are highly inaccurate.

Vehicle emissions factors are based on laboratory test bed measurements. These tests give a fair approximation of road driving, but NO₂ is not measured directly. We need better data on vehicle emissions to have confidence that intervention measures will actually deliver.

Remote sensing equipment from the University of Leeds Institute for Transport Studies recently featured on the One Show. Remote sensing allows measurement of exhaust emissions at a specific location. It gives a useful snapshot, but does not provide information on how vehicle emissions perform over a range of driving conditions. Instantaneous emissions models, such as Graz University of Technology’s PHEM and TRL’s IEM, do have emissions information over all driving conditions, but they are models and based on very limited measured emissions data.

PEMS (portable emissions measurement system) equipment is ideal for capturing large amounts of real-world emissions data. It can be installed on vehicles driving on the road. Its restriction is expense – a laboratory-standard PEMS costs around £250k. A few universities, such as Imperial College, have experimental (less accurate) PEMS equipment and have been capturing useful data. We need far more data, though, to produce reliable emissions factors that could robustly test the effectiveness of measures such as Boris Johnson’s proposed ultra-low-emission zone. We need more data to challenge current policy and bring about effective change. Might we see a European project collecting PEMS data across the EU over a 12-month period (to allow for seasonal emissions effects) and a team of experts mining the data to generate a new, robust set of emissions factors that bears more than a passing resemblance to reality? Will anyone propose it, and would Europe fund it? The air quality community has a duty to build a robust case.

Are Development Consent Orders more stringent than EIA?

 Dani Fiumicelli 

Technical Director (Acoustics)

The purpose of Environmental Impact Assessment (EIA) is to ensure that those deciding whether a scheme should go ahead or not, consider the effects on the environment. They then decide whether to refuse permission or allow a scheme to go ahead with or without conditions. The conditions they set could include requiring actions that  reduce (mitigate)  significant environmental effects.

Where the decision-maker agrees that the EIA procedure shows that a project is not likely to have significant adverse effects on the environment, or that significant adverse effects can be suitably mitigated, it follows that the scheme should be allowed. However, normally, it does not automatically follow that a project must be refused where the EIA procedure reveals that it is likely to have an adverse effect on the environment. This is because it is the task of the decision-maker to judge each scheme on its merits within the context of National, Regional and Local Plans and policies. The decision-maker must take account of all material considerations, including not only the adverse environmental effects but also the potential benefits of the proposed scheme. This means that if the decision-maker decides that a scheme’s adverse effects are outweighed by the scheme’s direct or indirect social, political and economic benefits, they can decide to authorise the scheme.

This element of the nature of EIA reflects the classic “planning balance”  involved in “weighing up” the relevant material considerations for a proposed scheme; and was explained as long ago as 1995 by Christopher Wood in his book Environmental Impact Assessment: A Comparative Review (Longman, 1995),  as follows:

“It should be emphasised that EIA is not a procedure for preventing actions with significant environmental effects from being implemented. Rather the intention is that actions are authorised in the full knowledge of their environmental consequences. EIA takes place in a political context; it is therefore inevitable that economic, social or political factors will outweigh environmental factors in many instances. This is why the mitigation of environmental impacts is so central to EIA: decisions on proposals in which the environmental effects have palpably been ameliorated are much easier to make and justify than those in which mitigation has not been achieved”.

However, the Development Consent Order (DCO) process appears to be different. The DCO process is based on The Planning Act 2008 and Localism Act 2011 which lays out the processes for making decisions on the development of major, or 'nationally significant' infrastructure projects (NSIPs) for energy, transport, waste and water. This system is intended to expedite decision making on nationally significant projects. Applications under DCOs are scrutinised by the Major Infrastructure Planning Unit, which took over from the Infrastructure Planning Commission and sits within the Planning Inspectorate. The Unit advises the relevant Minister; the Minister then makes the final decision on whether the project should go ahead or not.  

The Planning Inspectorate examines applications in line with procedures which emphasise the use of written representations, seeking to minimise the need for issues to be examined through cross-examination at public inquiries. Although, typically, a hearing is held before a panel where the applicant makes the case for their scheme, Interested Parties can make submissions and the panel can ask questions of all parties.  National Policy Statements (NPSs) are the chief consideration in decision-making on NSIPs, as they set out the policies by which decisions on these infrastructure projects should be made. For example, the Overarching National Policy Statement for Energy (EN-1) in regard to noise states the following:

In regard to Noise – “ The IPC should not grant development consent unless it is satisfied that the proposals will meet the following aims:

·         avoid significant adverse impacts on health and quality of life from noise;

·         mitigate and minimise other adverse impacts on health and quality of life from noise; and,

·         where possible, contribute to improvements to health and quality of life through the effective management and control of noise.”

From this, there appears to an absolute policy requirement that there must be no significant noise effects in order for a DCO scheme to be approved. There are more examples with similar wording to this in other NPSs, which also appear to set absolute limits to the decision-makers discretion and overrule the normal planning balance type judgements possible in EIA.  The important change to note is that the above three bullet points are from the Noise Policy Statement for England and are also found in the NPPF. However, in the latter they are qualified by statements that they should be considered within the context of Government Policy on sustainable development and that noise should not be considered in isolation. On the face of it DCOs appears to set a threshold for the authorisation of  a scheme which EIA doesn’t require.

The DCO process is still relatively new. It will be interesting to see whether the apparent absolute limits are observed. 

Commitment from the Top

Martin Gibson

Head of Operations

This blog was first posted on 2degrees network on January 23^rd, 2014.

As anyone who has tried to improve sustainability, energy efficiency or resource efficiency knows, senior management support is critical. ‘Commitment from the top’ is always in the list of critical success factors from surveys of leading initiatives. At the opposite end of the spectrum, many a manager entrusted with delivering improvement has bemoaned the lack of top management support for undermining any real progress.

For about 20 years now, I have agreed with this and I am not going to change my tune now. However, I think that the simple ‘commitment from the top’ approach is not sufficient in itself. The top level commitment must be meaningful and well communicated if it really is going to help success.

In the mid-1990’s, the UK Government ran an initiative called Making a Corporate Commitment (MACC). This was aimed at increasing the energy efficiency of some of the country’s largest companies. A Secretary of State wrote to the Chief Executives of companies in the FTSE 100 asking them to make a commitment to improving energy efficiency. At the time, the Energy Efficiency Best Practice Programme (EEBPP) was in full swing and producing good savings for many companies. Unfortunately, the EEBPP didn’t really get much board level attention; it was successful at targeting technical managers but this tended to lead to incremental changes, not systemic ones. It was felt, probably rightly, that senior level commitment might lead to more fundamental changes in approach.

Few people would now remember MACC without prompting, if they remembered it at all. It wasn’t a great success, although some aspects of it worked well. Having a minister write to chief executives did increase board interest for a little while and a number of major companies signed up to MACC. The trouble is, few of the companies used this to change how they managed energy.

I remember speaking to the environment manager of a multinational about a year after MACC was launched. He told me that he had just learnt that his chief executive had signed up to MACC six months before. I would say that he was not amused in how long it took for him to learn about it, but that would probably be wrong. He seemed to find his lack of knowledge only too predictable and had a wry smile on his face.

You’ve probably spotted by now that top level commitment doesn’t just mean the chief executive saying that they are committed to doing something! It has to be backed up by management action. This includes the boring part of reviewing the current position, planning actions, do the actions, measuring progress and then repeating the cycle. Yes – it involves embedding the commitment into management systems.

Being committed also involves providing resources. One of the early case studies on the old Envirowise programme was about a chemical company that had saved money by improving resource efficiency. It had started reusing chemical containers and giving people more responsibility. The environment manager leading the initiative was given the verbal and written support of the managing director. However, when speaking about it, he would say that it took a bit longer to get the time of the people he needed to deliver the initiative.

Since the mid-1990s, things have moved on quite a bit and a lot of companies with senior management commitment have turned that into real action. This moves us on to the next part of the equation for success: communication. My earlier friend, the corporate environment manager, was pretty effective at communication but could only communicate what he knew. I think a lot more attention is paid to communication of sustainability than was the case for energy efficiency in the 1990s. The trouble now is that there is so much being communicated that the important issues can get lost.

If you are like me, you probably get over 80 emails every day. So anyone trying to communicate has a lot of competition. I do read the emails sent from the boss (usually) and feel that is probably true for most people. So, if the boss really has made a corporate commitment, perhaps one of the most important things they can do (after ensuring the management systems do what they should and providing the resources) is lend their name to important internal and external communications about sustainability. After all, it has got to be more interesting talking about sustainability than filling in all those questionnaires about corporate governance.

What's the solution to the Somerset floods?

Carol Somper

Technical Director

There have been several news reports and articles over the last few weeks about the Somerset floods, with raging debates as to whether dredging the local River Parrett is essential, or a colossal waste of time, effort and money. Good scientific evidence developed by the University of Bristol shows that it’s invariably the latter as the sediment gets washed back up-river almost as soon as it’s been removed at vast expense to the tax payer. So what can be done about the costly flood damage to homes and the misery inflicted on those living in affected areas? Swift and effective compensation is vital, but how to prevent it happening again, year after year, especially with wetter winters and more extreme weather events coming at us? 

The Parrett catchment and Somerset Levels is a very good example of where ‘sticking plaster’ solutions and knee-jerk reactions need to be ditched in favour of something much more radical, but ultimately more sustainable. If housing is to remain in what has historically been marshland, drained in recent centuries for farming, then we need different housing models, using raised platforms and stilts, with space underneath for boats and not just cars. We need more resilient transport infrastructure and utilities that can cope with excess storm-water and the hazards it brings. Until we get the design solutions right by using a systems-based approach, we must stop building the wrong type of development in the wrong place, largely ignoring how natural systems work. Local planning in any area must take into account how to manage and make space for water, for when we have too much at once, and to store it for times of drought when we have too little. 

The Parrett catchment draining the Somerset Levels is a complex river system with strong tidal flow and the situation is exacerbated by complex and fragmented land ownership. The big question is whether those people living in homes built in the 20th century and in the last decade or so should be re-homed elsewhere on drier, higher ground. Ultimately, the costs of doing so would be less than the ongoing costs of dredging, repair to homes and insurance premiums and pay outs (if they can be had).

Our planning system has the potential to make this vital space for water, to aid catchment management and to help secure future water supplies for people and commerce without increasing flood risk. If our planning system is to work as well as it can in this respect, we still need to take a systems approach, factoring in how land is farmed and managed, especially in the upper catchments.  A strategic combination of flood storage and Sustainable Urban Drainage (SUDs) measures supported by catchment sensitive farming, such as that undertaken by Natural England in the Parrett, is becoming an increasing necessity, not just a nice to have. But is this strategic approach really happening in other than a piece-meal and ad-hoc way? 

The Value of Independence

Robert Slatcher

Principal Consultant

The provision of environmental and sustainability services is dominated by large multi-disciplinary consultancies who offer clients a ‘one-stop shop’ for all of their consultancy requirements from design to environmental assessment. The one tender, one contract, one organisation, system from a client procurement and management perspective is obviously an enticing one. A question remains, however, over the extent to which many organisations procurement teams fully understand and quantify the value of employing independent environmental assessment service providers, separately from those providing the main design services. There are benefits that can be achieved through an independent environmental and sustainability team that at present may not be considered when developing procurement mechanisms for major projects or consultancy frameworks.

The value of using an independent environmental consultant is the ability to critically review and challenge design development to ensure a robust final scheme design. Much emphasis is placed on collaborative teamwork, which has many benefits, but what is perhaps not considered is the value of intra-project challenge. Differing perspectives, opinions and ways of doing things, don’t have to be seen as a negative; it can be the driver for improved performance, the push to go beyond the norm and can be the difference between a good and a great project. What is the likelihood of all stakeholders sharing the same opinion and solutions as the team designing a project? Major innovations and forward leaps in thinking are very rarely the outcome of a business as usual mentality. An independent voice within a project can shake up that mentality.

Major infrastructure projects are often challenged on environmental grounds and as such a robust project development phase should enable a project to minimise the risk of a successful challenge to consent approval. As a minimum, a robust scheme development and environmental assessment undertaken prior to a consent application would reduce any delays to programme that may arise from retrospective rework required to defend challenges. The ability to challenge and push a design team could be difficult to achieve internally within a single organisation as infrastructure projects tend to be led by the engineering division of the organisation, who then manage all elements of the project with the environment and sustainability work often internally procured as an additional service. With engineering teams acting as an internal client, it can be difficult for environment and sustainability teams to challenge work their organisation has undertaken especially when it would then necessitate additional work to investigate or change.

An independent environment team introduces an interface between organisations that otherwise would not exist. This interface between environment and engineering provides a transparency of communication to the client, which is unlikely to be easily evidenced when occurring within a single organisation. This should give the client peace of mind that sustainability and environmental rigour is being implemented into the project without the need to develop key performance indicators (which in reality would be unlikely to provide the detail they require) or other methods to gain visibility of the internal processes within the supplier organisation. It also provides the client with the opportunity to input into the process, where necessary, in a timely manner rather than after the decision or work has been implemented.

Through the management of the interface, which can be undertaken by either of the teams or collaboratively, a clear evidence base of the sustainability and environment work implemented in the design can be captured. This evidence can be essential when defending scheme decisions under challenge, writing the scheme justification and alternatives sections of Environmental Statements and supporting CEEQUAL applications.

The onus on driving the sustainability agenda within the project can also be taken on by the independent environment and sustainability team relieving the client of the need to undertake this role. This is especially useful if the client team does not have the resource or an individual with the environmental expertise to undertake this task.

It is noted that for those in procurement, the issuing and management of two contracts would appear to be more onerous upon the client and perhaps this has been an obstacle to more projects being undertaken in this manner. It is also likely that it is considered that communication within an organisation would be much more effective than that between two separate organisations. However the additional effort in managing two contracts can be more than compensated in the following ways:

  

• through a reduction in the client management requirement to implement and drive environment and sustainability in the project;
• the increased likelihood of achieving a final scheme design that is not only feasible from an engineering perspective but environmentally and socially acceptable to stakeholders;
• the ability for the client to easily track performance and progress;
• through the proactive management and reduction in project risk; and
• reduced risk for retrospective re-work.