Elected Member Briefing - Air quality consultations in Perth and Crieff

About this Briefing Note

Report by: Oliver Law & Lynne Reid, Air Quality Officer and Environmental Health Technical Officer

Date: 4 November 2024

EMBN Number: 098-24

Subject: Consultations for Perth Air Quality Action Plan and Revocation of Crieff Air Quality Management Area

Responsible Officer: Oliver Law & Lynne Reid, Air Quality Officer & Environmental Health Technical Officer, Environmental Health

Details

Purpose 

To inform Elected Members of the upcoming consultation for both the Perth Air Quality Action Plan and the Revocation of the Crieff Air Quality Management Area. 

Briefing information

1. Perth's Updated Air Quality Action Plan 

Background 

Perth was declared an Air Quality Management Area (AQMA - see Figure 1 below) in 2005 due to exceedances of air quality targets (nitrogen dioxide and particulate matter PM10) in certain hot spot areas around the city centre, primarily due to traffic congestion. 

To tackle these levels of pollution Perth's Air Quality Action Plan (AQAP) was subsequently published in 2009.  

The plan contained a suite of improvement measures which have been progressed since. These include: the creation of the Cross Tay Link Road; optimisation of Atholl Street traffic signalling to reduce congestion, and integration of air quality into the Council's planning process. The improvement measures in this plan and implemented thereafter, along with the emergence of cleaner vehicles, have currently reduced pollution to acceptable levels.  

However, such levels require to be sustained, and in recognition of the potential impacts of a developing city, along with significant changes in travel activity, a full review and update of the Action Plan has now been completed by Environmental Health. 

This plan aims to formally address current and predicted air quality impacts, through the introduction of an updated suite of improvement measures. These measures have been created through consultation with all relevant internal and external stakeholders, covering a broad range of associated topics including transportation, roads/infrastructure and active travel.  

Public Consultation 

Prior to publication of the AQAP Scottish Government guidance requires a minimum of six weeks of public consultation conducted by Environmental Health by undertaking the consultation through a combination of online surveys (Consultation Hub) and in-person drop-in events in Perth (to be arranged). This consultation will begin on Monday 4 November 2024 and run for six weeks until Monday 16 December 2024 at https://consult.pkc.gov.uk/communities/draft-perth-aqap.  

Experience suggests that too long or complex a survey will cause participants to lose interest and not complete the survey, which is why the Perth AQAP survey will be kept as simple as possible with only three main questions: 

• Overall, to what extent do you agree/disagree with the measures to improve air quality set out within the Perth Air Quality Action Plan? (Scale from "Strongly Agree" to "Strongly Disagree" 
• If there any areas within the AQAP which you disagree with or feel need to be changed, please tell us which these are (multiple choice of the 7 improvement measure groups, followed by an open text box) 
• Do you have any other comments on the overall AQAP? (open text box question) 

In addition to these questions, a small number of profiling questions will follow (age group, location, reason for interest in consultation etc.)  

The Council's Communications and Design Team will assist with the promotion of this consultation and have created a Communications plan setting out what promotion will be carried out to ensure senior management, Elected Members, the public, businesses, and Community Councils are briefed on the proposed AQAP process and upcoming consultation. 

Any questions/feedback raised during the process will be referred to the Air Quality Officer, Environmental Health for response. 

Next steps 

Once the consultation is completed, the responses will be collated, analysed, and included within the Perth AQAP as an appendix. Should the consultation identify any areas of the Action Plan which need to be changed/updated/added to, this will also be done at this stage in conjunction with relevant stakeholders.  

Once complete, the Perth AQAP will go to Senior Management and/or Committee for approval before being published on the Council website, Scottish Air Quality Website and DEFRA LAQM website. 

2. Proposal for the Revocation of Crieff's Air Quality Management Area 

Background 

The Air Quality Management Area (AQMA) in Crieff was declared on 14 April 2014 due to exceedances in air quality targets (Nitrogen dioxide and Particulate Matter (PM10)) due to traffic congestion within the main street.  

The Crieff AQMA covers the area between the Y-Junction at Perth Road and Dollerie Terrace, follows the A85 trunk road east to East High Street, the Cross, High Street, James Square then on to West High Street stopping at the junction of Galvelmore Street and Lodge Street and north up to Comrie Street to Y-Junction at Coldwells Road and midpoint of Comrie Street. See Figure 2 below for a map of Crieff's AQMA. 

Section 4 'AQMA' of Part IV of the Environment Act 1995 states: "There are no set criteria on which an AQMA amendment or revocation decision will be based, and the Scottish Government considers each request on a case-by-case basis. A minimum requirement however will normally be at least three consecutive years where the national air quality standards of concern are being achieved and where monitoring data demonstrates that further exceedances of the objectives are unlikely to occur." 

Measured concentrations within Crieff's AQMA have shown a downward trend over recent years and compliant with the national air quality standards for 5 years. The last exceedance was 2018. 

Perth & Kinross Council were advised on the review of their Local Air Quality Management Annual Progress Report for 2023 by the Scottish Environment Protection Agency (SEPA) and the Scottish Government to seek the revocation of Crieff's AQMA. On this basis, Perth & Kinross Council are proposing to revoke Crieff's AQMA (NO2 and PM10 annual mean exceedances).  

The Detailed Assessment, which provides evidence in support of the revocation and gives confidence that future exceedances are unlikely to occur is located at: https://www.pkc.gov.uk/media/52695/Crieff-AQMA-revocation-report/pdf/Crieff_AQMA_Revocation_report_1smlw3qxlftg9.pdf?m=1715689742893 

This assessment has been verified and approved by the Scottish Government and SEPA. 

Consultation 

Unlike the public consultation required for Perth's AQAP, Crieff's revocation consultation only requires statutory consultees, businesses, members of the public and other interested parties in the vicinity of AQMA to be notified. A communication plan has been created in order to do so, including the link to the above Detailed Assessment which clearly supports the revocation proposal. The period for feedback is scheduled to run from Monday 4 November 2024 to Monday 25 November 2024 with those wishing to comment invited to email EH@pkc.gov.uk. 

The plan will be implemented to ensure senior management, Elected Members, the public, businesses, and community councils are notified of the proposed revocation process. Any questions/feedback received will be referred to the Council's Air Quality Officer, Environmental Health for response. 

Legal Services will draw up a formal AQMA Revocation Order which will be submitted to Scottish Government and SEPA before uploading to the UK Air and Air Quality in Scotland websites. 

Next steps 

Following the recommendations within the relevant policy guidance, Perth & Kinross Council will continue to implement, post revocation, the measures as set out in the Crieff's Air Quality Action Plan (AQAP) and any other actions deemed appropriate.  

Monitoring of air quality in Crieff will continue for a further 3 years before further reviewing a possible curtailment.  

Further information 

If possible, given the different processes and potential timelines, a coordinated notification of both Perth's AQAP consultation and Crieff's AQMA revocation will be implemented. 

Long-term, Perth and Kinross Council is looking to create an Air Quality Strategy which will provide an overview of the Council's commitment to improving local air quality and reference all agreed and ongoing AQAP improvement actions.