I think it is indisputable that the requirement for action on NO2 is a Central Government requirement.
2to1 seems to take issue with my statement that all 10 councils failed the standard
He has replied by referring to 2017 - though there was no reference.
Perhaps some explanation will help
That was how the compliance data existed back in 2017 and NO2 data was limited as it was based on the national PCM model which uses a limited sampling methodology with GIS extrapolation.
Here is the big technical document on the methodology used back then.
This now outdated and limited methodology reported that 7 areas in GM failed the NO2 standard and thus these 7 areas formed the basis for the original Government Directive.
However, given the accepted limitations of the National PCM model, further local testing and modelling was required and so this was then undertaken.
Oldham was then found to breach limits in 2018 and so it was also served with a Ministerial Directive from Central Government.
Thus by 2018 we had 8 breech areas.
Subsequently, when more comprehensive detailed local surveying was undertaken the remaining 2 councils were also found to breach the standard required, although the breaches were quite limited in these 2 remaining areas and Rochdale and Wigan Councils were not compelled to act on these through a ministerial Direction, but were asked to address their breaches in the the Target Determination exercise.
The Target Determination exercise revealed 250 points of exceedance across 152 road links across all ten districts in2020/21
Thus in summary you seem to be citing out of date data that was found on subsequent detailed testing to be too optimistic.
I was using the up to date data on much more robust methodology.
It is worth noting that currently exceedance is measured against the standard of 40 microgram/ M3 rather than the more recent recommended WHO standard which is a far more stringent 10. The WHO standard for NO2 is due for further consideration by Central Government later this year. Hopefully they will stick with the current standard!
You can see information and data here:
Back in 2017 the Government served a Direction on seven Greater Manchester local authorities requiring them to produce a feasibility study, in accordance with the HM Treasury’s Green Book, in which they must identify the option which will deliver compliance with legal limits for nitrogen dioxide in the area for which the authority is responsible in the “shortest possible time”
Here is the supporting document:
An outline plan and outline business case is then drawn up locally and has then to be passed back to Government for approval to ensure that it will meet the NO2 standards required. Following approval a detailed business case is prepared.
Note that Government documentation is clear that in many urban areas especially ones as badly polluted as GM that a CAZ is the only one that will deliver the required degree of NO2 improvement.
The Government stipulation that compliance is required in the shortest possible time - in the Manchester case by 2024 is the root of the problem as it gives too little notice or time for change and too little notice for a substantial proportion of vehicles affected to be already compliant especially as Manchester has a relatively high proportion of older vehicles.
In reality as cleaner vehicles are built and old ones replaced the overall trend line for NO2 levels has been downward for some time so a more relaxed timetable would have been better.
Belatedly, there has been recognition that the timetable of working to a 2024 deadline is simply unworkable because this timescale is too compressed and the ability of people to adapt has not been adequately considered.
In addition, the pandemic has substantially added to the problem since it has created a situation where new vehicles are simply not available due to supply chain issues.
Finally, the relatively measly financial package especially for an urban area beset by significant levels of deprivation is a problem that needs to be addressed.
Hopefully, a solution can be found in the coming days.
That’s me “over and out” on this one.
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