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The strategic gap in air-quality management
Journal of Environmental Management (2000) 60, 289–300 doi:10.1006/jema.2000.0385, available online at http://www.idealibrary.com on
The strategic gap in air-quality management G. Cannibal†* and M. Lemon‡
The successful management of atmospheric pollution is best achieved when the benefits of controls can be clearly demonstrated to those who the controls affect. There is a need to demonstrate to a population that change will benefit the social and biophysical aspects of that population’s environment as a whole. This paper suggests that policy-makers need to demonstrate clearly the advantages of a change in behaviour for the local environment while concurrently minimising the life-style costs of the people whose co-operation is needed to bring that change about. This requires an improved understanding of the activities affected and the message and media by which environmental benefits can be communicated in the light of that understanding. Using the example of tropospheric ozone, this paper argues that air-quality management requires close regional co-ordination which can facilitate the establishment and implementation of local policy options. The ability of the UK National Air Quality Strategy to achieve this in its present form is discussed and the existence of a strategic gap between the current approach to air-quality management and the major issues surrounding air quality considered. 2000 Academic Press
Keywords: ozone, UKNAQS, culture, policy, behaviour.
Introduction ‘A strategic gap is a condition of imbalance between where management would like to be with regard to its aspirations, and goals. Its a measure of the perennially imperfect fit between an institution and its external environment’ (Harrison, 1989). The original United Kingdom National Air Quality Strategy (UKNAQS) described itself as ‘‘a watershed in the history of measures to improve the quality of air in the United Kingdom’’ (DoE, 1997). The main stated aim of the act was to bring together the concepts of sustainable development and recent advances in the understanding of air pollutants and the methods for tackling them. However, when one looks closely at the strategy and the accompanying 1995 Environment Act, Part IV, which operationalises many of the aims of the strategy it may be seen that this new framework does little more than bring together approaches first developed under Email of corresponding author: [email protected] 0301–4797/00/120289C12 $35.00/0
the Clean Air Acts; extending the concept of the local authority controlled smoke control areas with those laid out in the 1990 Environmental Protection Act and soon to be implemented Pollution Prevention and Control Act (1999) (both of which are a direct descendants of the Alkali Acts); concerning the technical control of emissions at source, and developments within European legislation on emission and fuel technology, under one roof. The UKNAQS and 1995 Environment Act (EA) can be seen as a modification of past air-quality management frameworks rather than a radical change in approach. The dominant tools for air-quality management remain; the use of licensing (first adopted under the Alkali Acts, 1863–1874); financial coercion and incentive to change behaviour (from the Clean Air Acts of the 1950s and 1960s) and the technical reduction of motor-car and industrial emissions (Langston, 1990). These are all targeted at the attainment of generically set UK and European ambient air quality standards and as such are essentially oriented towards
Ł Corresponding author † School of Environmental and Applied Sciences, University of Derby, Kedleston Road, Derby, DE23 1GB, UK ‡ INTA/SIMS, University of Cranfield, Cranfield, MK43 AOL, UK Received 21 December 1998; accepted 23 August 2000 2000 Academic Press
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fixed end-states. Policy approaches tend to be static; they are aimed at improving environmental baselines to what are seen by central government as desirable goals. These standards are subsequently imposed on local authorities whose borders have been defined around historical settlement patterns and bear no relation to natural biophysical flows (Cannibal and Hadfield, 1997). The co-ordination of local government approaches to environmental management and economic development occurs through what is essentially a top-down framework of legislation and policy guidance issued from central government (McAuslan, 1980), a structure that is reflected in the UKNAQS. Contemporary issues of air quality are, however, fundamentally different from those that past legislation and approaches were designed to deal with. The motor car is widely recognised as being the main contributor to deteriorating air quality, especially in the southern part of the UK. Unlike past issues, dominated by industrial pollution, the activity is discrete but is an unintended consequence of widespread and legitimate behaviour providing basic criteria are met regarding emissions. Transportation patterns are implicitly linked to our way of life, the shape of our cities and the wellbeing of our economy as well as the sense of personal freedom and security we all enjoy (Lowe, 1992). This paper reviews the suitability of the present air-quality framework for the management of a complex secondary pollutant (tropospheric ozone) arising in large part from this legitimate activity. It draws upon the findings of research into tropospheric ozone and associated issues in the area to the north of London and pays particular emphasis to the perception of how local authorities can respond to such a framework (Cannibal and Hadfield, 1997; Cannibal et al., 1996; Hadfield and Cannibal, 1996; Cannibal, 1998). Using an issue led, interdisciplinary approach (Pablo, 1994; Lemon and Longhurst, 1998) the paper highlights the constraints imposed on the management of by biophysical and social processes in its origin (including those associated with the pollutants precursors), transportation, transformation and reception. This is further compounded by the structure of the management framework
itself and it will be argued that the combination of these constraining factors form the basis of the strategic gap which is identified in the title of the paper.
Tropospheric ozone as a regional and behaviourally derived pollutant In the context of this paper a central feature of tropospheric ozone is that it while it can have a local influence, the greater impact of this pollutant tends to occur downwind. It crosses administrative and legislative boundaries and affects areas that are often quite different in nature to those of its source (Chameides, 1993; Huess and Wolffe, 1993; Hadfield and Cannibal, 1996). The problems presented by the transportation of this pollutant can be explored by breaking down the phenomenon into three key subsystems (Cannibal, 1998): (1) a biophysical system, involving migration and synergy that changes the qualitative as well and the quantitative nature of the issue over different temporal and spatial scales; (2) a social system of conflicting personal needs and wishes for mobility and clean air; and (3) a tiered management system that is fragmented both between and within these tiers, and where the issue of air pollution as a whole is just one of many that are addressed on a day to day basis. The management of the issue must account for the nature of each of these sub-systems as well as their spatial and temporal variation. Each of these sub-systems will now be dealt with in turn.
Atmospheric processes: the bio-physical sub-system The issue of tropospheric ozone can be viewed from two distinct bio-physical perspectives. The first is the propensity for the main precursor pollutants, the non-methane volatile organic compounds and nitrogen oxides (NMVOCs and NOx ), to gather in localised pockets, at particular periods of time (such as rush hours) and to produce so called ‘pollution hot spots’. The second is for these precursors to be transported considerable
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Sunlight intensity Stratospheric ozone
Prevailing and/or occasional wind direction and wind speed Precursors NOx: VOC @ 8:1
Transport and oxidation
NOx
VOC
Essentially anthropogenic approx. 75% road transport 25% power generation
Natural plant metabolism anthropogenic road transport, stationary combustion solvent use
Figure 1.
Tropospheric ozone
People/ Health effects
Plants and buildings economic effects
A summary of the biophysical components of tropospheric ozone production.
distances and via complex synergistic reactions, involving other factors such as climatic and chemical catalysts, to transform into tropospheric ozone (see Figure 1). Both of these issues are relevant to air-quality management in many, but not all regions, of the United Kingdom. The 1995 Environment Act Part IV requires local authorities to recognise and manage localised areas with raised air pollution concentrations (hot spots). The encouragement for local authorities to co-ordinate across departments in an attempt to integrate transport, planning, and health concerns is a significant step towards the development of strategies which allow for the setting of consistent targets and the avoidance of policy clashes (Longhurst et al., 1996). In dealing with hot spots, the and the 1995 Environment Act are justifying the claim to be a watershed in air quality legislation (DoE, 1997). The suitability of this framework for the management of regional air pollution is less satisfactory, a view which is supported by the fact that the requirement to meet ozone standards was removed from remit set in the 1995 Environment Act (Air Health Strategy 1996) by the 1997 Air Quality Regulations (DoE, 1997). Ozone tends to form complex regional patterns (Cannibal, 1998; Kankidou
and Crutzen, 1993) and manifests the following characteristics (Chung, 1977; McKendry, 1993; Bower and Stevenson, 1994; Chameides, 1993; Wolf and Lioy, 1980): ž It is generated downwind from urban areas of high traffic density, and forms in areas where background emissions of these precursors are low. The substance generally forms an urban plume impacting on more rural areas, forming the phenomena that has come to be known as an ‘ozone river’. ž The result of this transformation and transportation process means that effects of ozone, such as impacts on human health and damage to economic resources such as crops, tend to be felt distant from the source of the pollution. ž The optimum period for ozone formation has been identified as being about 3–5 hours and the production generally occurs at low level wind speeds of about 4–5 ms 1 . Peak ozone resulting from urban precursor emissions therefore generally occur 50–60 km downwind of the source. However, it is readily scavenged by nitrogen oxide that may result from short term emissions in areas where, overall, NOx concentrations may be generally low (for example from rush-hour traffic).
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ž It is affected by the ratio of background concentrations of precursors; climatic factors such as UV intensity and wind speed. ž Ozone rivers may form tiered multi-scalar structures which complicate the simple cause and effect model of urban plumes, where one ozone generating plume may lay inside the area of a larger scale plume (Cannibal, 1998).
Ozone and the social sub-system ‘It is argued that the policy-makers in the past have ignored the role of local values, ethics and ideologies in the design of environmental policy: these factors can severely affect the policy outcomes and thus need to be integrated more fully in the policy-making process’ (Ahuja, 1996). Cheap and accessible transport has facilitated living and working patterns and their associated needs and expectations in a mutually reinforcing way (Lowe, 1992). This is shown by dispersed patterns of occupation and the growth of leisure activities reflecting the willingness to commute (Wagener, 1993). With the exception of motor sport, driving is not a discrete activity but is tightly intertwined with people’s working, social and leisure activities. The growth in ownership, and more important, use of the motor car has been linked to its relative inexpensiveness. Over the last three decades this has facilitated more accessible transport which in turn has changed the way people regard mobility and the way in which they order their lives (Lowe, 1992). The emphasis in the Environment Act and the UKNAQS on mechanisms to induce people to change their behaviour has largely taken the form of financial penalties on parking (at a local level) and increases in vehicle tax and fuel duty (at the national level). Research suggests that the cost of private compared to public transport has little to do with the individual’s decision to use the motor vehicle but that features such as flexibility, safety and accessibility are much more important (Lowe, 1992; Cannibal, 1998). Financial disincentives can only be introduced in an equitable way if consideration is paid to these needs. If costs are imposed to a point where they exclude lower paid members of the community from the use
of private transport the question of equity is raised and a fundamental principal of the air quality strategy, freedom of choice (DoE, 1996), compromised. In light of these findings it is easy to see why the proposed government policy of the 90’s of a 5% annual increase in vehicle taxation and 3% increase in fuel duty has been shown to be inefficient in reducing car usage (National Society for Clean Air (NSCA), 1994; Air Health Strategy, 1997), is generally seen as a revenue raising device (Burke, 1997) and has resulted in much disquiet in amongst the electorate. This issue is further complicated when the variation with which the utility of car use is considered along spatial and social dimensions. For example reducing the cost of public transport (or increasing the cost of private) in one area may work better than in others and or for some parts of the population than others. However it may be less effective in places where access is of great importance (e.g. in more isolated communities), or for groups of the population (e.g. women) where security is of concern. It is likely that any revenue raised through transport management plans will be ill received by the public if it is not reinvested in transport infrastructure and improved alternative modes of travel that can respond to these concerns (ENDS, 1996). Where they fail to respond, alternatives are likely to be unsuccessful. For example, an experiment of running cheap buses for seven weeks in Whitley Bay by Tyne and Wear Council failed to win over any additional passengers in what is described as a very car dependent area (Air Health Strategy, 1997). Those approaches that do not recognise these needs are likely to be ignored or resented (Ahuja, 1996; O’Riordan, T., 1996, pers. comm.), especially where air quality is perceived as good, and enforced change will only affect particular sectors of the community (DoE, 1997). The problem of resentment within the local population has potentially serious, and more far reaching, implications. This is illustrated by the following statement from a local authority engineer: ‘Counties now have new powers to restrict peak area traffic. For instance in a case where there is high pollution levels—but this will result in them screwing up [i.e. degrading] their town’s economies—people would just go to Milton Keynes (the nearest city).’
The strategic gap in air-quality management
Driving behaviour can be seen as an activity that is re-enforced every time someone uses their motor car (Hillman, 1992), in many cases this is on a daily basis. At the same time concern over air pollution can fade rapidly after the public have been exposed to the issue (Hadfield, 1997), a serious issue when one considers the seasonal nature of ozone. These observations mean that consideration must be given to the process by which the issue of transport derived air pollution can be made salient to individuals in their everyday lives (Ahuja, 1996) in much the same way as the activity of car driving is. This implies that any public education program must be an on-going process of awareness raising rather than provision of, for example, one off publications informing the public how to improve a car’s environmental performance (DoE, 1996). There needs to be a concerted campaign to raise public awareness that is easily to accessible to all. To expect a population to make great efforts to discover an issue that is not considered relevant to their everyday concerns may be overlay optimistic. The issue needs taking to the population. In summary, for a strategy aimed at changing behaviour to be effective, the issue must be both understandable and relevant to the individuals whose behaviour is to be targeted (Ahuja, 1996, O’Riordan, T., 1996, pers. comm.; North, 1984). As a consequence, one must consider approaches aimed at the reduction of tropospheric ozone in terms of the behaviour that causes the problem, i.e. the production of precursor pollutants through activities of driving, and intensive energy use.
The management sub-system The administrative structure, and its related culture, is the third sub-system to be considered in the tropospheric ozone process. The spatial and temporal disparity between bio-physical flows and administrative boundaries and between the social aspects of the source and receptor populations of this pollutant have been discussed. These will now be considered in terms of intra and inter authority integration before the final section of the paper looks at some of the policy implications arising from this discussion as a whole. The following section is supported by
interview data for which confidentiality was a condition of the research. Interviews where carried out during 1995 with local authority officers in an area that has a recognised urban ozone problem. Intra-authority integration For the first time attempts to tie transport derived air pollution to environmental health on a district-by-district basis, through the establishment of local consortia, has linked the planning and health functions of local authorities. The granting of powers to close roads, establish management schemes and set localised targets can also be significant for improving the communication and co-operation of local environmental management (Longhurst et al., 1996). This is implied by the following statement: ‘meaningful outputs tend to produce co-operation. However insular behaviour alienates other groups. In [this town] we tend to have all the main departmental groups consolidated into one group and this can work, corporate working can lead to communication.’ (a District Borough Engineer). The strong departmentalised structure within local authorities has, however, led to distinct approaches and value-sets being brought to the collaborative process (Bate, 1996). The following examples drawn from the same Borough Council illustrate that each of the departments essentially see their role as communicating their area of expertise and knowledge to a central process rather than contributing to the development of an integrative approach. ‘The way we’re organised in the Borough Council is basically on specialist lines’ (Chief Environmental Health Officer). ‘There is a need to integrate Traffic Policy/highways planning and land-use planning’ (Borough Engineer). ‘I think our role is to primarily collect information, and to monitor the environment. I think decisions will be made upon the data we collect’ (Senior Pollution Control Officer). As a consequence, the central process and responsibility for it, seems less certain. ‘[the] job plan falls to the Director of Environmental Health and Housing’. (Borough Engineer). ‘Given that transportation policies and land use policies are going to bring more information to improving the environment. I think
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that the lead role, will be in those areas, not necessarily in ours. Traditionally, our role is to collect data’ (Senior Pollution Control Officer). The approach that is evolving emphasises the individual functions of the respective departments concerned with management of air quality. In other words ‘what do we do and how do we apply it to air-quality management?’ rather than ‘how should we as a group manage air quality?’ A final point to be made is raised by both Bate (1996) and Mohr (1982). It is not only the explicit working relationships that can act as a constraint in the ability of each department to collaborate, but also the nature of individual working relationships which may require attention. This is an important consideration when we are considering the management of an issue such as tropospheric ozone, which has direct implications for environmental health, transport planning and land-use planning departments of a local authority, when viewed within a tradition of hard departmental segregation (Floyd, 1987).
Inter-authority integration at the national level The departmental structure of central government policy making in the UK is typified by competing interests (Commission for the European Communities, 1993). Each department sets their own agenda within the overall acceptance of cabinet, but with a high degree of independence, albeit within a framework that has become dominated increasingly by the Treasury over the last 20 years (Burke, 1997; Jones, 1991). The segregation of each department operating according to their own agenda has been described as a mechanism for managing conflicting concerns (Commission for the European Communities, 1993). It is also recognised that the older more established departments, as well as those whose interests are more in line with the philosophy of the ruling political party tend to dominate at the expense of others (Committee for the National Institute for the Environment Proposal, 1994; Bailey, 1990; Axelrod, 1994) a feature that can be seen in the dominance of the Treasury in all areas of policy-making over the last 20 years or so (Bell & McGillivary, 2000).
This structure has had a two-fold effect on the development of the UKNAQS. First, the objections to limits and targets made by the Department of Transport and the Department of Trade and Industry severely delayed the publication of the UKNAQS. This was eventually released as a white paper over a year late without official endorsement by then Department of Transport (Air Health Strategy, 1996d), with a reduced emphasis on the setting of VOC limits (Brown, 1996) and an increase in the role played by the application of least cost over best practice (Air Health Strategy, 1996d). This in turn raised the level of insecurity felt by the local authorities whose job it is to implement the strategy through the 1995 Act (Air Health Strategy, 1996b). The second effect of this approach has been that guidance emanating from other government departments over issues of local development can often be in contradiction to the UKNAQS, at least in the eyes of local authority officers who are meant to implement them. This is pointed out in the following statement from a local authority transport engineer: ‘[The] context of our remit (concerning air-quality management under the 1995 Act) is set within a range of policies, set by central government, for example PPG’s 12 and 13 [Planning policy guidance notes on development plans and transport respectively], these state for example that settlement should be situated around transport corridors. However that leads to worsening air quality for residents along those corridors as traffic increases. Then there’s privatisation of public transport. . . Central government is inconsistent and this leads to a main issue of cynicism of central government at district level.’ The problem of what a local authority would be allowed to do within this framework is of particular relevance when one considers the wide range of powers open to the Secretary of State (DETR, 1997, 1999). For example the ability to censure air-quality management plans, even in designated AirQuality Management Areas and to decide the funding for traffic management plans on the basis of the perceived merits of packages (DoE, 1996). This can result in a situation where local polices aimed at improving air quality are constrained or contradicted by
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other legislation passed down from the centre to local authorities (Pas, 1986; Roberts and James, 1990; Hillman, 1992; Air Health Strategy, 1996c). Inter-authority integration at the local level Similar problems of integration and collaboration are manifest between local authorities as those discussed above between the centre and the local. In addition to the requirements of managing within their own disciplinary framework, local authority officers also have to consider general quality of life issues and the need to respond to the local population, and significant resource constraints. ‘We’re spending most of our time on complaints, even if the members wanted something they wouldn’t be able to have it because if you go out and do some monitoring, or whatever, then you come back and there’s a stack of complaints and angry people because you haven’t responded’ (District Council Environmental Health Officer). Furthermore, we can see a situation similar to that shown in intra authority communication where historical relationships may also constrain the willingness of different local authorities to work together. If, for example, one authority sees another as a threat to their independence: ‘. . .do not historically get on with neighbouring districts, most of these small districts do not want to be a part of a bigger. . .’ (Borough Engineer). Alternatively in assigning a co-ordinating role to another authority different degrees of commitment to that authority may be apparent. ‘Well I don’t think that anyone has thought about regional strategies, if you did you would have to do that through SERPLAN the South East Regional Planning Group’ (Country Council Green Space Officer, 1996). ‘SERPLAN is a joke. It is appointed by government to a degree, to keep the lid on problems, not to deal with them’ (Borough Engineer). Explicit and implicit constraints, such as personal commitment and time, the available resources and the past working practices of an authority can lead to considerable variation in the active commitment to air-quality assessment and management. This variable commitment inevitably causes problems for the management of a regional phenomenon.
The lack of assured funding is likely to deter local authorities from entering long term arrangements with other authorities and with other departments within the same authority especially with the emphasis on adopting least cost approaches which was evident in the Air Quality Strategy (DoE, 1996). The absence of a firm commitment from central government to adequately fund air-quality management programs for all local authorities (district and council) and worries about committing resources to what may be an overlay controlled process may impede any action from being taken. ‘Central government is good at passing the buck—but not dealing with the causal problems. This leads to a certain cynicism on behalf of local authorities—they see that the policy will not work and therefore do the minimum to appease central government’ (Borough Engineer). Coordination between government tiers, control or subsidiarity A stated need for air-quality management to be affective, in the UK governments opinion is that the concept of subsidiarity should be applied, which is defined as that: ‘Action should be taken to improve air quality at the most appropriate level, be it international European, national or local’ (The UK Air Quality Strategy for England, Scotland, Wales and Northern Island, Draft DETR, 1999:7). The UK National Air Quality Strategy (DoE, 1996) also stated that for this concept to be effective, then there is need for: ‘confidence that the parties involved must have the willingness and ability to meet set targets’. However, this need is stated as applying to the relationship between national and European levels of government and does not appear to apply between national and local levels. The present framework for airquality management can be described as top-down and prescriptive. The setting of standards and the framework prescribed by the UKNAQS as well as the tight budgetary constraints are essentially imposed on local authorities. Local authorities have no role in prescribing air-quality standards, which remains the domain of the central governmental research body, the Expert Panel on Air
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Quality Standards (DoE, 1994, 1995, 1996, DETR, 1999, 1995 Environment Act). In a similar way, they have little say concerning the amount of funding made available other than representation through local authority associations. The approach shown in the UKNAQS forces authorities to manage in accordance with what are perceived as the contradictory concerns of central government. Without the freedom to raise their own budgets and to implement management strategies relevant to local needs and those of other authorities with common pollution concerns then the ability of local authorities to improve air quality will be severely limited (Air Health Strategy, 1996c). While much of the responsibility for achieving the aims of air-quality management rests on the shoulders of the local authorities, there is very little they can do other than effect very localised change. The recognition of this fact may well be responsible for the dropping of ozone standards from the 1997 Air Quality Regulations (DETR, 1997) and the growing tendency to concentrate on localised pollution hot spots. The effect of this approach on the confidence of local authorities’ ability to meet these standards was summed up in the following quote: ‘Central government pushes its view on the local through the funding arrangements (local government gets about 70% of its funding from central government) and its non-consultation style. Presently the approach is to exercise financial and policy control over local government’ (a Borough Engineer).
Policy implications for monitoring and managing tropospheric ozone The previous sections of the paper have looked at tropospheric ozone in terms of biophysical, socio-cultural and institutional subsystems. A number of policy and management implications have arisen from this discussion and will be developed further in the next section.
Influencing driver behaviour The UKNAQS recommended restricting the use of the motor-car through the education of
fleet operators and the general public about their ‘environment responsibilities’ combined with a range of financial incentives and disincentives. These included the introduction of an annual increase in road tax (5%) and were designed to place more of the real environmental cost onto the consumer (DoE, 1995). Attempts to restrict or discourage the use of private transport at the local level have focused on new powers given to local authorities to limit parking space, close certain roads to motorised traffic and to encourage long-term infrastructural changes in planning and transport policies. The latter of which are intended to reduce both the need to travel and reliance on the motor-car (DoE, 1997; Longhurst et al., 1996). The promotion of improved traffic management, mixed with central government financial incentives (or disincentives), and environmental education may, however, be of limited success because of a failure to adequately comprehend the cultural focus of the car as an essential feature of urban and rural living (Wagener, 1993). The aim of the first of the approaches applied at national policy level, influencing the behaviour of people’s use of the motor-car was justified by the DoE in the following quote: ‘An important part of the Government information service is provision of advice at different levels of pollution, and in particular, when air quality becomes ‘‘poor’’ or ‘‘very poor’’ according to the current system’ (DoE, 1995). (nb this systems has been now modified to new banding system low, moderate, high and very high, with assigned two tier information and alert thresholds. The strategy then goes on to state that the purpose of improved information is to raise the general profile of air quality and to encourage the general public to change their behaviour in response to this both as producers and recipients of pollution. Not withstanding the difficulties of relating local air quality standards and monitoring to actual exposure, the effectiveness of information strategies must also be considered. Research carried out on the levels of public knowledge concerning local air-quality information suggests a low level of awareness about what is provided by local authorities (Air Health Strategy, 1996b). One reason for this may lie in the fact that the media
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employed tend to be inaccessible to the majority of the population at which it is aimed (such as internet pages that still can not be easily accessed by the majority of the population). Furthermore, when targeted populations are made aware of periods of poor air quality, most people, even those who belong to identified ‘at risk’ groups, have responded poorly to advice informing them how to avoid, or limit, exposure. This is understandable since there is little evidence to suggest that any changes in behaviour will lead to any health benefits (Schwela, 1996) and similar reservations exist about the ability to influence driver behaviour through the provision of information (Acury and Christianson, 1992). While people are willing to accept that air pollution is a concern it may often be short lived particularly when the pollutant shows strong seasonal trends (Hadfield and Cannibal, 1996). Furthermore, issues of air pollution do not exist in isolation, but are a part of an individual’s perception of themselves within their social and physical environment. It has been shown that while on a societal level people agree that there should be changes in driving behaviour to improve air quality, this does not necessarily translate into action (Acury and Christianson, 1992). An additional point is highlighted in the National Air Quality Strategy which points out that air pollution in the United Kingdom is only a perceived threat to sensitive groups (DoE, 1995), and not to the population as a whole. Therefore the majority of people who benefit from car ownership perceive that they are doing so at little or no cost to their health. It may be optimistic to expect people to change their employment, the place they live, their way of life, or feeling of security for an improvement in air quality. Furthermore with the promotion, in the UKNAQS of the catalytic converter as a significant panacea to modern pollution problems (DoE, 1997), it is unlikely that air quality will be considered by present day motorists to be more of a threat to their well being in the future than it is at present.
Technical responses to managing pollution A further response to traffic derived pollutants has been through the development and
diffusion of technologies intended to control vehicle emissions. ‘Improvements in vehicle technology are seen as the main contribution to improving air quality, in line with the principle of cost effectiveness’ (DoE, 1997). There are, however, well documented problems with this reliance on the technical fix. In brief, these are: ž the tendency of new technologies, such as the catalytic converter, aimed at controlling one aspect of a complex system, to bring new and unanticipated emergent problems in their train (Sperling, 1984). This feature has been found to be applicable to the problem of tropospheric ozone since the selective reduction in NO2 in vehicle exhaust has led to policy which restricts future transport emission legislation to vehicles using this technology and may also produce urban tropospheric ozone problems (Nuttall, 1995). ž the development of policy based on a restricted set of technological developments, such as increasingly sophisticated catalytic converter, can block developments of other innovations that do not initially meet the standards designed around the existing technology. These may however have the potential for producing better long-term outcomes, a feature that essentially restricts policy options (Sperling, 1984; Viessman, 1988). Increasing evidence indicates that the anticipated effect of the catalytic converter on automobile emissions of NO2 may have been overstated (Air Health Strategy, 1996c). Nearly all predictions state that within 25 years or so the unabated growth in car use will outweigh any benefits brought about by improvements in technology. As a result transport related air pollution can be seen as an example of ‘a no technical solution problem’ (Hardin, 1968).
Local management responses Any management plan aimed at reducing tropospheric ozone needs to recognise the complex relationship between it and its precursors. It will require a monitoring approach that allows for the analysis of precursor and ozone concentrations across large areas. Linked to this the management framework needs to identify which precursors
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should be managed where (Huess and Wolffe, 1993; Chameides, 1994). In the absence of a integrated approach to monitoring regional considerations may well be sacrificed for a fragmented approach which is designed around local air flows and according to the different priorities of local authorities (Air Health Strategy, 1996g). Despite the 1995 Environment Act and the UKNAQS recognising the regional nature of air pollution there is little in either of these documents to promote either a formal or informal, regional monitoring strategy. The approach of the UKNAQS essentially ties local authority monitoring to local problems. Within the context of tropospheric ozone this requirement is restricted to an assessment of whether areas will exceed standards set for NOx and the VOCs 1-3butadiene and benzene. Monitoring is carried out by individual authorities or through area consortia. These are supported by statutory commitments to the monitoring of hot spots where single pollutants will be in excess of air quality targets by the year 2005. As has been seen this limited local response is compounded by the emphasis upon a least cost approach (Air Health Strategy, 1996d; September) and the restriction of central government funding to the compliance with specific legal requirements; a feature noted by a local authority Chief Environmental Health Officer (1996): ‘the DoE has clearly stated that there won’t be funding for anything which is not statutory’. Any additional monitoring or assessment work carried out by local authorities will reflect the political will of that local authority to carry it out and the allocation of resources to support it. This varies greatly from one authority to another and leads to inconsistency in the monitoring of similar phenomena in different areas (Cannibal, 1998; Hadfield and Cannibal, 1996). As a consequence, locally oriented monitoring is poorly equipped to provide the information which is necessary to establish the relationship between tropospheric ozone and its precursors in any one area (Allen and Foley, 1993; Chang and Rudy, 1993; Bower and Stevenson, 1994). This situation is compounded by two additional factors. First, the low cost diffusion tube monitoring carried out independently by local authorities is not compatible with the luminescence monitoring carried out by
the national monitoring network, NETCEN. Second, the jurisdiction of the Environment Agency is restricted to the functions that it assumed under the 1990 Environmental Protection Act and the 1993 Water Resources Act (Air Health Strategy, 1996a) rather than any new agenda of co-ordinating air quality data. This situation has meant that any regional analysis of ozone must rely on either expensive independent monitoring programmes or the adaptation of locally designed air quality monitoring data on a best-guess basis (Cannibal, 1998). The latter approach lacks the resolution of data to allow for the finely coordinated management of regional VOC and NOx needed for ozone management (Huess and Wolffe, 1993).
Conclusions Tropospheric ozone poses a complex problem for air-quality management, in addition to its bio-physical characteristics the sense of wellbeing that individuals derive from private car ownership is deeply embedded within societal values of freedom and accessibility. Cars are a product, and formative characteristics, of modern culture and values surrounding their use show qualitative and quantitative variation from place to place and through time. This paper argues that the evolution of airquality management has lagged behind the changes in both the biophysical and social systems which cause pollution issues they wish to address. There is a distinct strategic gap (Harrison, 1989), or cultural incongruity (Hassard and Sharifi, 1989) between the social and biophysical sub-systems that lead to high levels of tropospheric ozone and the management systems in place to deal with them. The constraints presented by the topdown single pollutant approach to air-quality management, laid out in the UKNAQS ties managers into dealing with localised problems of air quality that are amenable to local solutions, and is inapplicable when dealing with regional problems involving multiple interacting pollutants. A key objective of airquality management has been stated as the reduction of summer smogs, where ozone is a strong component (Air Health Strategy, June, 1996). However the strategy underpinning the management framework (Bate,
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1996) is not appropriate for in meeting these objectives. It has been argued that the approach to air-quality management is highly localised and still reflects attempts to manage domestic smoke or point source industrial emissions. Air-quality management must recognise that any attempt to change driver behaviour should be acceptable and applicable to the population at which it is aimed (Ahuja, 1996). In the context of transport related tropospheric ozone this means ensuring that transport and lifestyle alternatives respond to the requirements for flexibility, accessibility, privacy and security that people derive from private car-use. In other words there must be a net perceived benefit to the public from changes in their behaviour on an individual level, and consistent applicable methods for communicating these benefits need to be identified. To understand these issues we need to lean research towards understanding the needs aspirations and requirements of the populations with regards to air quality as well as the behaviour which causes its deterioration in the respective locations. We need to be able to identify the range of interests involved in the production of such a pollutant as well as methods of resolving any conflicts that may arise in such a way that they fit the context of both the social and atmospheric systems. It needs to be recognised that it is the interaction of these systems that has resulted in the issue in the first place. In summary, it is stated that research concerning the management of regional and behaviourally derived pollutants such as tropospheric ozone requires information to be utilised and integrated from the social as well as the natural sciences, both within and between regional localities. Finally, it should be noted that the tight budgetary constraints applied to local air-quality management may well restrict local authorities to those procedures for which it can ensure funding. This will inevitably hinder innovative work towards developing a regional strategic approach.
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Jones, S. (1991). The role of economics in environmental policy. Science of the Total Environment 108, 61–69. Kankidou, M. and Crutzen, P. J. (1993). Scale problems in global tropospheric ozone chemistry modelling. Chemosphere 26, 787. Langston, J. (1990). The development of European Economic Community policies for air pollution control. Clean Air 24, 61. Lemon, M. and Longhurst, P. (1998). Integrative Method and Policy Relevant Research. Reading: Garden and Beach. Longhurst, J. W. S., Lindley, S. J. and Conlan, D. E. (1996). The introduction of local air quality management in the United Kingdom: a review and theoretical framework. Atmospheric Environment 30, 3975–3985. Lowe, I. (1992). Social and environmental impacts of road transport. In Proceedings of the 16th ARRB Conference Australian Road Research Board. Australian Research Board, Sydney, Australia. McAuslan, P. (1980). The Ideologies of Planning Law. Oxford: Pergamon Press. McKendry, I. G. (1993). Ground level ozone in Montreal, Canada. Atmospheric Environment 27, 95–103. Mohr, L. B. (1982). Explaining Organisational Behaviour. San Francisco, CA: Jossey-Bass. National Society for Clean Air (NSCA) (1994). Briefing. June 1994. Nonaka, I. (1988). Towards middle-up top-down management: accelerating information creation. Sloan Management Review Spring, 9–17. North, D. (1984). Transaction costs, institutions and economic history. Zietschrift fur die Gesamte Staatswissenschaft 140, 7–17. Nuttall, D. (1995). Exhaust cleaners will add to smog problem in the city. The Times 13 July 1997. Pablo, C. L. et al. (1994). A design for an information system for environmental management. Journal of Environmental Management 40, 231–234. Pas, E. I. (1986). The urban transport planning process. In The Geography of Urban Transportation (Hanson, ed.). Guildford: Guildford Press. Roberts, J. and James, N. (1990). Some transport is more equal than others. The Planner 30, 22–25. Schwela, D. (1996). Exposure to environmental chemicals relevant for respiratory hypersensitivity. Toxicological Letters 86, 131. Sperling, D. (1984). Assessment of technological choices using a pathways methodology. Viessman, W. (1988). Technology, institutions and social goals. Water Resources Bulletin 24, 581–584. Wagener, M. (1993). Reduction of CO2 Emissions of Transport by Reorganisation of Urban Activities. WCTR SIG1 Seminar Environmental Challenges in Land-Use Transport Co-ordination. Wolf, G. and Lioy, P. (1980). Development of an ozone river associated with synoptic scale episodes in the Eastern United States. Environmental Science and Technology 14, 1257–1260.
The strategic gap in air-quality management G. Cannibal†* and M. Lemon‡
The successful management of atmospheric pollution is best achieved when the benefits of controls can be clearly demonstrated to those who the controls affect. There is a need to demonstrate to a population that change will benefit the social and biophysical aspects of that population’s environment as a whole. This paper suggests that policy-makers need to demonstrate clearly the advantages of a change in behaviour for the local environment while concurrently minimising the life-style costs of the people whose co-operation is needed to bring that change about. This requires an improved understanding of the activities affected and the message and media by which environmental benefits can be communicated in the light of that understanding. Using the example of tropospheric ozone, this paper argues that air-quality management requires close regional co-ordination which can facilitate the establishment and implementation of local policy options. The ability of the UK National Air Quality Strategy to achieve this in its present form is discussed and the existence of a strategic gap between the current approach to air-quality management and the major issues surrounding air quality considered. 2000 Academic Press
Keywords: ozone, UKNAQS, culture, policy, behaviour.
Introduction ‘A strategic gap is a condition of imbalance between where management would like to be with regard to its aspirations, and goals. Its a measure of the perennially imperfect fit between an institution and its external environment’ (Harrison, 1989). The original United Kingdom National Air Quality Strategy (UKNAQS) described itself as ‘‘a watershed in the history of measures to improve the quality of air in the United Kingdom’’ (DoE, 1997). The main stated aim of the act was to bring together the concepts of sustainable development and recent advances in the understanding of air pollutants and the methods for tackling them. However, when one looks closely at the strategy and the accompanying 1995 Environment Act, Part IV, which operationalises many of the aims of the strategy it may be seen that this new framework does little more than bring together approaches first developed under Email of corresponding author: [email protected] 0301–4797/00/120289C12 $35.00/0
the Clean Air Acts; extending the concept of the local authority controlled smoke control areas with those laid out in the 1990 Environmental Protection Act and soon to be implemented Pollution Prevention and Control Act (1999) (both of which are a direct descendants of the Alkali Acts); concerning the technical control of emissions at source, and developments within European legislation on emission and fuel technology, under one roof. The UKNAQS and 1995 Environment Act (EA) can be seen as a modification of past air-quality management frameworks rather than a radical change in approach. The dominant tools for air-quality management remain; the use of licensing (first adopted under the Alkali Acts, 1863–1874); financial coercion and incentive to change behaviour (from the Clean Air Acts of the 1950s and 1960s) and the technical reduction of motor-car and industrial emissions (Langston, 1990). These are all targeted at the attainment of generically set UK and European ambient air quality standards and as such are essentially oriented towards
Ł Corresponding author † School of Environmental and Applied Sciences, University of Derby, Kedleston Road, Derby, DE23 1GB, UK ‡ INTA/SIMS, University of Cranfield, Cranfield, MK43 AOL, UK Received 21 December 1998; accepted 23 August 2000 2000 Academic Press
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fixed end-states. Policy approaches tend to be static; they are aimed at improving environmental baselines to what are seen by central government as desirable goals. These standards are subsequently imposed on local authorities whose borders have been defined around historical settlement patterns and bear no relation to natural biophysical flows (Cannibal and Hadfield, 1997). The co-ordination of local government approaches to environmental management and economic development occurs through what is essentially a top-down framework of legislation and policy guidance issued from central government (McAuslan, 1980), a structure that is reflected in the UKNAQS. Contemporary issues of air quality are, however, fundamentally different from those that past legislation and approaches were designed to deal with. The motor car is widely recognised as being the main contributor to deteriorating air quality, especially in the southern part of the UK. Unlike past issues, dominated by industrial pollution, the activity is discrete but is an unintended consequence of widespread and legitimate behaviour providing basic criteria are met regarding emissions. Transportation patterns are implicitly linked to our way of life, the shape of our cities and the wellbeing of our economy as well as the sense of personal freedom and security we all enjoy (Lowe, 1992). This paper reviews the suitability of the present air-quality framework for the management of a complex secondary pollutant (tropospheric ozone) arising in large part from this legitimate activity. It draws upon the findings of research into tropospheric ozone and associated issues in the area to the north of London and pays particular emphasis to the perception of how local authorities can respond to such a framework (Cannibal and Hadfield, 1997; Cannibal et al., 1996; Hadfield and Cannibal, 1996; Cannibal, 1998). Using an issue led, interdisciplinary approach (Pablo, 1994; Lemon and Longhurst, 1998) the paper highlights the constraints imposed on the management of by biophysical and social processes in its origin (including those associated with the pollutants precursors), transportation, transformation and reception. This is further compounded by the structure of the management framework
itself and it will be argued that the combination of these constraining factors form the basis of the strategic gap which is identified in the title of the paper.
Tropospheric ozone as a regional and behaviourally derived pollutant In the context of this paper a central feature of tropospheric ozone is that it while it can have a local influence, the greater impact of this pollutant tends to occur downwind. It crosses administrative and legislative boundaries and affects areas that are often quite different in nature to those of its source (Chameides, 1993; Huess and Wolffe, 1993; Hadfield and Cannibal, 1996). The problems presented by the transportation of this pollutant can be explored by breaking down the phenomenon into three key subsystems (Cannibal, 1998): (1) a biophysical system, involving migration and synergy that changes the qualitative as well and the quantitative nature of the issue over different temporal and spatial scales; (2) a social system of conflicting personal needs and wishes for mobility and clean air; and (3) a tiered management system that is fragmented both between and within these tiers, and where the issue of air pollution as a whole is just one of many that are addressed on a day to day basis. The management of the issue must account for the nature of each of these sub-systems as well as their spatial and temporal variation. Each of these sub-systems will now be dealt with in turn.
Atmospheric processes: the bio-physical sub-system The issue of tropospheric ozone can be viewed from two distinct bio-physical perspectives. The first is the propensity for the main precursor pollutants, the non-methane volatile organic compounds and nitrogen oxides (NMVOCs and NOx ), to gather in localised pockets, at particular periods of time (such as rush hours) and to produce so called ‘pollution hot spots’. The second is for these precursors to be transported considerable
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Sunlight intensity Stratospheric ozone
Prevailing and/or occasional wind direction and wind speed Precursors NOx: VOC @ 8:1
Transport and oxidation
NOx
VOC
Essentially anthropogenic approx. 75% road transport 25% power generation
Natural plant metabolism anthropogenic road transport, stationary combustion solvent use
Figure 1.
Tropospheric ozone
People/ Health effects
Plants and buildings economic effects
A summary of the biophysical components of tropospheric ozone production.
distances and via complex synergistic reactions, involving other factors such as climatic and chemical catalysts, to transform into tropospheric ozone (see Figure 1). Both of these issues are relevant to air-quality management in many, but not all regions, of the United Kingdom. The 1995 Environment Act Part IV requires local authorities to recognise and manage localised areas with raised air pollution concentrations (hot spots). The encouragement for local authorities to co-ordinate across departments in an attempt to integrate transport, planning, and health concerns is a significant step towards the development of strategies which allow for the setting of consistent targets and the avoidance of policy clashes (Longhurst et al., 1996). In dealing with hot spots, the and the 1995 Environment Act are justifying the claim to be a watershed in air quality legislation (DoE, 1997). The suitability of this framework for the management of regional air pollution is less satisfactory, a view which is supported by the fact that the requirement to meet ozone standards was removed from remit set in the 1995 Environment Act (Air Health Strategy 1996) by the 1997 Air Quality Regulations (DoE, 1997). Ozone tends to form complex regional patterns (Cannibal, 1998; Kankidou
and Crutzen, 1993) and manifests the following characteristics (Chung, 1977; McKendry, 1993; Bower and Stevenson, 1994; Chameides, 1993; Wolf and Lioy, 1980): ž It is generated downwind from urban areas of high traffic density, and forms in areas where background emissions of these precursors are low. The substance generally forms an urban plume impacting on more rural areas, forming the phenomena that has come to be known as an ‘ozone river’. ž The result of this transformation and transportation process means that effects of ozone, such as impacts on human health and damage to economic resources such as crops, tend to be felt distant from the source of the pollution. ž The optimum period for ozone formation has been identified as being about 3–5 hours and the production generally occurs at low level wind speeds of about 4–5 ms 1 . Peak ozone resulting from urban precursor emissions therefore generally occur 50–60 km downwind of the source. However, it is readily scavenged by nitrogen oxide that may result from short term emissions in areas where, overall, NOx concentrations may be generally low (for example from rush-hour traffic).
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ž It is affected by the ratio of background concentrations of precursors; climatic factors such as UV intensity and wind speed. ž Ozone rivers may form tiered multi-scalar structures which complicate the simple cause and effect model of urban plumes, where one ozone generating plume may lay inside the area of a larger scale plume (Cannibal, 1998).
Ozone and the social sub-system ‘It is argued that the policy-makers in the past have ignored the role of local values, ethics and ideologies in the design of environmental policy: these factors can severely affect the policy outcomes and thus need to be integrated more fully in the policy-making process’ (Ahuja, 1996). Cheap and accessible transport has facilitated living and working patterns and their associated needs and expectations in a mutually reinforcing way (Lowe, 1992). This is shown by dispersed patterns of occupation and the growth of leisure activities reflecting the willingness to commute (Wagener, 1993). With the exception of motor sport, driving is not a discrete activity but is tightly intertwined with people’s working, social and leisure activities. The growth in ownership, and more important, use of the motor car has been linked to its relative inexpensiveness. Over the last three decades this has facilitated more accessible transport which in turn has changed the way people regard mobility and the way in which they order their lives (Lowe, 1992). The emphasis in the Environment Act and the UKNAQS on mechanisms to induce people to change their behaviour has largely taken the form of financial penalties on parking (at a local level) and increases in vehicle tax and fuel duty (at the national level). Research suggests that the cost of private compared to public transport has little to do with the individual’s decision to use the motor vehicle but that features such as flexibility, safety and accessibility are much more important (Lowe, 1992; Cannibal, 1998). Financial disincentives can only be introduced in an equitable way if consideration is paid to these needs. If costs are imposed to a point where they exclude lower paid members of the community from the use
of private transport the question of equity is raised and a fundamental principal of the air quality strategy, freedom of choice (DoE, 1996), compromised. In light of these findings it is easy to see why the proposed government policy of the 90’s of a 5% annual increase in vehicle taxation and 3% increase in fuel duty has been shown to be inefficient in reducing car usage (National Society for Clean Air (NSCA), 1994; Air Health Strategy, 1997), is generally seen as a revenue raising device (Burke, 1997) and has resulted in much disquiet in amongst the electorate. This issue is further complicated when the variation with which the utility of car use is considered along spatial and social dimensions. For example reducing the cost of public transport (or increasing the cost of private) in one area may work better than in others and or for some parts of the population than others. However it may be less effective in places where access is of great importance (e.g. in more isolated communities), or for groups of the population (e.g. women) where security is of concern. It is likely that any revenue raised through transport management plans will be ill received by the public if it is not reinvested in transport infrastructure and improved alternative modes of travel that can respond to these concerns (ENDS, 1996). Where they fail to respond, alternatives are likely to be unsuccessful. For example, an experiment of running cheap buses for seven weeks in Whitley Bay by Tyne and Wear Council failed to win over any additional passengers in what is described as a very car dependent area (Air Health Strategy, 1997). Those approaches that do not recognise these needs are likely to be ignored or resented (Ahuja, 1996; O’Riordan, T., 1996, pers. comm.), especially where air quality is perceived as good, and enforced change will only affect particular sectors of the community (DoE, 1997). The problem of resentment within the local population has potentially serious, and more far reaching, implications. This is illustrated by the following statement from a local authority engineer: ‘Counties now have new powers to restrict peak area traffic. For instance in a case where there is high pollution levels—but this will result in them screwing up [i.e. degrading] their town’s economies—people would just go to Milton Keynes (the nearest city).’
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Driving behaviour can be seen as an activity that is re-enforced every time someone uses their motor car (Hillman, 1992), in many cases this is on a daily basis. At the same time concern over air pollution can fade rapidly after the public have been exposed to the issue (Hadfield, 1997), a serious issue when one considers the seasonal nature of ozone. These observations mean that consideration must be given to the process by which the issue of transport derived air pollution can be made salient to individuals in their everyday lives (Ahuja, 1996) in much the same way as the activity of car driving is. This implies that any public education program must be an on-going process of awareness raising rather than provision of, for example, one off publications informing the public how to improve a car’s environmental performance (DoE, 1996). There needs to be a concerted campaign to raise public awareness that is easily to accessible to all. To expect a population to make great efforts to discover an issue that is not considered relevant to their everyday concerns may be overlay optimistic. The issue needs taking to the population. In summary, for a strategy aimed at changing behaviour to be effective, the issue must be both understandable and relevant to the individuals whose behaviour is to be targeted (Ahuja, 1996, O’Riordan, T., 1996, pers. comm.; North, 1984). As a consequence, one must consider approaches aimed at the reduction of tropospheric ozone in terms of the behaviour that causes the problem, i.e. the production of precursor pollutants through activities of driving, and intensive energy use.
The management sub-system The administrative structure, and its related culture, is the third sub-system to be considered in the tropospheric ozone process. The spatial and temporal disparity between bio-physical flows and administrative boundaries and between the social aspects of the source and receptor populations of this pollutant have been discussed. These will now be considered in terms of intra and inter authority integration before the final section of the paper looks at some of the policy implications arising from this discussion as a whole. The following section is supported by
interview data for which confidentiality was a condition of the research. Interviews where carried out during 1995 with local authority officers in an area that has a recognised urban ozone problem. Intra-authority integration For the first time attempts to tie transport derived air pollution to environmental health on a district-by-district basis, through the establishment of local consortia, has linked the planning and health functions of local authorities. The granting of powers to close roads, establish management schemes and set localised targets can also be significant for improving the communication and co-operation of local environmental management (Longhurst et al., 1996). This is implied by the following statement: ‘meaningful outputs tend to produce co-operation. However insular behaviour alienates other groups. In [this town] we tend to have all the main departmental groups consolidated into one group and this can work, corporate working can lead to communication.’ (a District Borough Engineer). The strong departmentalised structure within local authorities has, however, led to distinct approaches and value-sets being brought to the collaborative process (Bate, 1996). The following examples drawn from the same Borough Council illustrate that each of the departments essentially see their role as communicating their area of expertise and knowledge to a central process rather than contributing to the development of an integrative approach. ‘The way we’re organised in the Borough Council is basically on specialist lines’ (Chief Environmental Health Officer). ‘There is a need to integrate Traffic Policy/highways planning and land-use planning’ (Borough Engineer). ‘I think our role is to primarily collect information, and to monitor the environment. I think decisions will be made upon the data we collect’ (Senior Pollution Control Officer). As a consequence, the central process and responsibility for it, seems less certain. ‘[the] job plan falls to the Director of Environmental Health and Housing’. (Borough Engineer). ‘Given that transportation policies and land use policies are going to bring more information to improving the environment. I think
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that the lead role, will be in those areas, not necessarily in ours. Traditionally, our role is to collect data’ (Senior Pollution Control Officer). The approach that is evolving emphasises the individual functions of the respective departments concerned with management of air quality. In other words ‘what do we do and how do we apply it to air-quality management?’ rather than ‘how should we as a group manage air quality?’ A final point to be made is raised by both Bate (1996) and Mohr (1982). It is not only the explicit working relationships that can act as a constraint in the ability of each department to collaborate, but also the nature of individual working relationships which may require attention. This is an important consideration when we are considering the management of an issue such as tropospheric ozone, which has direct implications for environmental health, transport planning and land-use planning departments of a local authority, when viewed within a tradition of hard departmental segregation (Floyd, 1987).
Inter-authority integration at the national level The departmental structure of central government policy making in the UK is typified by competing interests (Commission for the European Communities, 1993). Each department sets their own agenda within the overall acceptance of cabinet, but with a high degree of independence, albeit within a framework that has become dominated increasingly by the Treasury over the last 20 years (Burke, 1997; Jones, 1991). The segregation of each department operating according to their own agenda has been described as a mechanism for managing conflicting concerns (Commission for the European Communities, 1993). It is also recognised that the older more established departments, as well as those whose interests are more in line with the philosophy of the ruling political party tend to dominate at the expense of others (Committee for the National Institute for the Environment Proposal, 1994; Bailey, 1990; Axelrod, 1994) a feature that can be seen in the dominance of the Treasury in all areas of policy-making over the last 20 years or so (Bell & McGillivary, 2000).
This structure has had a two-fold effect on the development of the UKNAQS. First, the objections to limits and targets made by the Department of Transport and the Department of Trade and Industry severely delayed the publication of the UKNAQS. This was eventually released as a white paper over a year late without official endorsement by then Department of Transport (Air Health Strategy, 1996d), with a reduced emphasis on the setting of VOC limits (Brown, 1996) and an increase in the role played by the application of least cost over best practice (Air Health Strategy, 1996d). This in turn raised the level of insecurity felt by the local authorities whose job it is to implement the strategy through the 1995 Act (Air Health Strategy, 1996b). The second effect of this approach has been that guidance emanating from other government departments over issues of local development can often be in contradiction to the UKNAQS, at least in the eyes of local authority officers who are meant to implement them. This is pointed out in the following statement from a local authority transport engineer: ‘[The] context of our remit (concerning air-quality management under the 1995 Act) is set within a range of policies, set by central government, for example PPG’s 12 and 13 [Planning policy guidance notes on development plans and transport respectively], these state for example that settlement should be situated around transport corridors. However that leads to worsening air quality for residents along those corridors as traffic increases. Then there’s privatisation of public transport. . . Central government is inconsistent and this leads to a main issue of cynicism of central government at district level.’ The problem of what a local authority would be allowed to do within this framework is of particular relevance when one considers the wide range of powers open to the Secretary of State (DETR, 1997, 1999). For example the ability to censure air-quality management plans, even in designated AirQuality Management Areas and to decide the funding for traffic management plans on the basis of the perceived merits of packages (DoE, 1996). This can result in a situation where local polices aimed at improving air quality are constrained or contradicted by
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other legislation passed down from the centre to local authorities (Pas, 1986; Roberts and James, 1990; Hillman, 1992; Air Health Strategy, 1996c). Inter-authority integration at the local level Similar problems of integration and collaboration are manifest between local authorities as those discussed above between the centre and the local. In addition to the requirements of managing within their own disciplinary framework, local authority officers also have to consider general quality of life issues and the need to respond to the local population, and significant resource constraints. ‘We’re spending most of our time on complaints, even if the members wanted something they wouldn’t be able to have it because if you go out and do some monitoring, or whatever, then you come back and there’s a stack of complaints and angry people because you haven’t responded’ (District Council Environmental Health Officer). Furthermore, we can see a situation similar to that shown in intra authority communication where historical relationships may also constrain the willingness of different local authorities to work together. If, for example, one authority sees another as a threat to their independence: ‘. . .do not historically get on with neighbouring districts, most of these small districts do not want to be a part of a bigger. . .’ (Borough Engineer). Alternatively in assigning a co-ordinating role to another authority different degrees of commitment to that authority may be apparent. ‘Well I don’t think that anyone has thought about regional strategies, if you did you would have to do that through SERPLAN the South East Regional Planning Group’ (Country Council Green Space Officer, 1996). ‘SERPLAN is a joke. It is appointed by government to a degree, to keep the lid on problems, not to deal with them’ (Borough Engineer). Explicit and implicit constraints, such as personal commitment and time, the available resources and the past working practices of an authority can lead to considerable variation in the active commitment to air-quality assessment and management. This variable commitment inevitably causes problems for the management of a regional phenomenon.
The lack of assured funding is likely to deter local authorities from entering long term arrangements with other authorities and with other departments within the same authority especially with the emphasis on adopting least cost approaches which was evident in the Air Quality Strategy (DoE, 1996). The absence of a firm commitment from central government to adequately fund air-quality management programs for all local authorities (district and council) and worries about committing resources to what may be an overlay controlled process may impede any action from being taken. ‘Central government is good at passing the buck—but not dealing with the causal problems. This leads to a certain cynicism on behalf of local authorities—they see that the policy will not work and therefore do the minimum to appease central government’ (Borough Engineer). Coordination between government tiers, control or subsidiarity A stated need for air-quality management to be affective, in the UK governments opinion is that the concept of subsidiarity should be applied, which is defined as that: ‘Action should be taken to improve air quality at the most appropriate level, be it international European, national or local’ (The UK Air Quality Strategy for England, Scotland, Wales and Northern Island, Draft DETR, 1999:7). The UK National Air Quality Strategy (DoE, 1996) also stated that for this concept to be effective, then there is need for: ‘confidence that the parties involved must have the willingness and ability to meet set targets’. However, this need is stated as applying to the relationship between national and European levels of government and does not appear to apply between national and local levels. The present framework for airquality management can be described as top-down and prescriptive. The setting of standards and the framework prescribed by the UKNAQS as well as the tight budgetary constraints are essentially imposed on local authorities. Local authorities have no role in prescribing air-quality standards, which remains the domain of the central governmental research body, the Expert Panel on Air
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Quality Standards (DoE, 1994, 1995, 1996, DETR, 1999, 1995 Environment Act). In a similar way, they have little say concerning the amount of funding made available other than representation through local authority associations. The approach shown in the UKNAQS forces authorities to manage in accordance with what are perceived as the contradictory concerns of central government. Without the freedom to raise their own budgets and to implement management strategies relevant to local needs and those of other authorities with common pollution concerns then the ability of local authorities to improve air quality will be severely limited (Air Health Strategy, 1996c). While much of the responsibility for achieving the aims of air-quality management rests on the shoulders of the local authorities, there is very little they can do other than effect very localised change. The recognition of this fact may well be responsible for the dropping of ozone standards from the 1997 Air Quality Regulations (DETR, 1997) and the growing tendency to concentrate on localised pollution hot spots. The effect of this approach on the confidence of local authorities’ ability to meet these standards was summed up in the following quote: ‘Central government pushes its view on the local through the funding arrangements (local government gets about 70% of its funding from central government) and its non-consultation style. Presently the approach is to exercise financial and policy control over local government’ (a Borough Engineer).
Policy implications for monitoring and managing tropospheric ozone The previous sections of the paper have looked at tropospheric ozone in terms of biophysical, socio-cultural and institutional subsystems. A number of policy and management implications have arisen from this discussion and will be developed further in the next section.
Influencing driver behaviour The UKNAQS recommended restricting the use of the motor-car through the education of
fleet operators and the general public about their ‘environment responsibilities’ combined with a range of financial incentives and disincentives. These included the introduction of an annual increase in road tax (5%) and were designed to place more of the real environmental cost onto the consumer (DoE, 1995). Attempts to restrict or discourage the use of private transport at the local level have focused on new powers given to local authorities to limit parking space, close certain roads to motorised traffic and to encourage long-term infrastructural changes in planning and transport policies. The latter of which are intended to reduce both the need to travel and reliance on the motor-car (DoE, 1997; Longhurst et al., 1996). The promotion of improved traffic management, mixed with central government financial incentives (or disincentives), and environmental education may, however, be of limited success because of a failure to adequately comprehend the cultural focus of the car as an essential feature of urban and rural living (Wagener, 1993). The aim of the first of the approaches applied at national policy level, influencing the behaviour of people’s use of the motor-car was justified by the DoE in the following quote: ‘An important part of the Government information service is provision of advice at different levels of pollution, and in particular, when air quality becomes ‘‘poor’’ or ‘‘very poor’’ according to the current system’ (DoE, 1995). (nb this systems has been now modified to new banding system low, moderate, high and very high, with assigned two tier information and alert thresholds. The strategy then goes on to state that the purpose of improved information is to raise the general profile of air quality and to encourage the general public to change their behaviour in response to this both as producers and recipients of pollution. Not withstanding the difficulties of relating local air quality standards and monitoring to actual exposure, the effectiveness of information strategies must also be considered. Research carried out on the levels of public knowledge concerning local air-quality information suggests a low level of awareness about what is provided by local authorities (Air Health Strategy, 1996b). One reason for this may lie in the fact that the media
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employed tend to be inaccessible to the majority of the population at which it is aimed (such as internet pages that still can not be easily accessed by the majority of the population). Furthermore, when targeted populations are made aware of periods of poor air quality, most people, even those who belong to identified ‘at risk’ groups, have responded poorly to advice informing them how to avoid, or limit, exposure. This is understandable since there is little evidence to suggest that any changes in behaviour will lead to any health benefits (Schwela, 1996) and similar reservations exist about the ability to influence driver behaviour through the provision of information (Acury and Christianson, 1992). While people are willing to accept that air pollution is a concern it may often be short lived particularly when the pollutant shows strong seasonal trends (Hadfield and Cannibal, 1996). Furthermore, issues of air pollution do not exist in isolation, but are a part of an individual’s perception of themselves within their social and physical environment. It has been shown that while on a societal level people agree that there should be changes in driving behaviour to improve air quality, this does not necessarily translate into action (Acury and Christianson, 1992). An additional point is highlighted in the National Air Quality Strategy which points out that air pollution in the United Kingdom is only a perceived threat to sensitive groups (DoE, 1995), and not to the population as a whole. Therefore the majority of people who benefit from car ownership perceive that they are doing so at little or no cost to their health. It may be optimistic to expect people to change their employment, the place they live, their way of life, or feeling of security for an improvement in air quality. Furthermore with the promotion, in the UKNAQS of the catalytic converter as a significant panacea to modern pollution problems (DoE, 1997), it is unlikely that air quality will be considered by present day motorists to be more of a threat to their well being in the future than it is at present.
Technical responses to managing pollution A further response to traffic derived pollutants has been through the development and
diffusion of technologies intended to control vehicle emissions. ‘Improvements in vehicle technology are seen as the main contribution to improving air quality, in line with the principle of cost effectiveness’ (DoE, 1997). There are, however, well documented problems with this reliance on the technical fix. In brief, these are: ž the tendency of new technologies, such as the catalytic converter, aimed at controlling one aspect of a complex system, to bring new and unanticipated emergent problems in their train (Sperling, 1984). This feature has been found to be applicable to the problem of tropospheric ozone since the selective reduction in NO2 in vehicle exhaust has led to policy which restricts future transport emission legislation to vehicles using this technology and may also produce urban tropospheric ozone problems (Nuttall, 1995). ž the development of policy based on a restricted set of technological developments, such as increasingly sophisticated catalytic converter, can block developments of other innovations that do not initially meet the standards designed around the existing technology. These may however have the potential for producing better long-term outcomes, a feature that essentially restricts policy options (Sperling, 1984; Viessman, 1988). Increasing evidence indicates that the anticipated effect of the catalytic converter on automobile emissions of NO2 may have been overstated (Air Health Strategy, 1996c). Nearly all predictions state that within 25 years or so the unabated growth in car use will outweigh any benefits brought about by improvements in technology. As a result transport related air pollution can be seen as an example of ‘a no technical solution problem’ (Hardin, 1968).
Local management responses Any management plan aimed at reducing tropospheric ozone needs to recognise the complex relationship between it and its precursors. It will require a monitoring approach that allows for the analysis of precursor and ozone concentrations across large areas. Linked to this the management framework needs to identify which precursors
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should be managed where (Huess and Wolffe, 1993; Chameides, 1994). In the absence of a integrated approach to monitoring regional considerations may well be sacrificed for a fragmented approach which is designed around local air flows and according to the different priorities of local authorities (Air Health Strategy, 1996g). Despite the 1995 Environment Act and the UKNAQS recognising the regional nature of air pollution there is little in either of these documents to promote either a formal or informal, regional monitoring strategy. The approach of the UKNAQS essentially ties local authority monitoring to local problems. Within the context of tropospheric ozone this requirement is restricted to an assessment of whether areas will exceed standards set for NOx and the VOCs 1-3butadiene and benzene. Monitoring is carried out by individual authorities or through area consortia. These are supported by statutory commitments to the monitoring of hot spots where single pollutants will be in excess of air quality targets by the year 2005. As has been seen this limited local response is compounded by the emphasis upon a least cost approach (Air Health Strategy, 1996d; September) and the restriction of central government funding to the compliance with specific legal requirements; a feature noted by a local authority Chief Environmental Health Officer (1996): ‘the DoE has clearly stated that there won’t be funding for anything which is not statutory’. Any additional monitoring or assessment work carried out by local authorities will reflect the political will of that local authority to carry it out and the allocation of resources to support it. This varies greatly from one authority to another and leads to inconsistency in the monitoring of similar phenomena in different areas (Cannibal, 1998; Hadfield and Cannibal, 1996). As a consequence, locally oriented monitoring is poorly equipped to provide the information which is necessary to establish the relationship between tropospheric ozone and its precursors in any one area (Allen and Foley, 1993; Chang and Rudy, 1993; Bower and Stevenson, 1994). This situation is compounded by two additional factors. First, the low cost diffusion tube monitoring carried out independently by local authorities is not compatible with the luminescence monitoring carried out by
the national monitoring network, NETCEN. Second, the jurisdiction of the Environment Agency is restricted to the functions that it assumed under the 1990 Environmental Protection Act and the 1993 Water Resources Act (Air Health Strategy, 1996a) rather than any new agenda of co-ordinating air quality data. This situation has meant that any regional analysis of ozone must rely on either expensive independent monitoring programmes or the adaptation of locally designed air quality monitoring data on a best-guess basis (Cannibal, 1998). The latter approach lacks the resolution of data to allow for the finely coordinated management of regional VOC and NOx needed for ozone management (Huess and Wolffe, 1993).
Conclusions Tropospheric ozone poses a complex problem for air-quality management, in addition to its bio-physical characteristics the sense of wellbeing that individuals derive from private car ownership is deeply embedded within societal values of freedom and accessibility. Cars are a product, and formative characteristics, of modern culture and values surrounding their use show qualitative and quantitative variation from place to place and through time. This paper argues that the evolution of airquality management has lagged behind the changes in both the biophysical and social systems which cause pollution issues they wish to address. There is a distinct strategic gap (Harrison, 1989), or cultural incongruity (Hassard and Sharifi, 1989) between the social and biophysical sub-systems that lead to high levels of tropospheric ozone and the management systems in place to deal with them. The constraints presented by the topdown single pollutant approach to air-quality management, laid out in the UKNAQS ties managers into dealing with localised problems of air quality that are amenable to local solutions, and is inapplicable when dealing with regional problems involving multiple interacting pollutants. A key objective of airquality management has been stated as the reduction of summer smogs, where ozone is a strong component (Air Health Strategy, June, 1996). However the strategy underpinning the management framework (Bate,
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1996) is not appropriate for in meeting these objectives. It has been argued that the approach to air-quality management is highly localised and still reflects attempts to manage domestic smoke or point source industrial emissions. Air-quality management must recognise that any attempt to change driver behaviour should be acceptable and applicable to the population at which it is aimed (Ahuja, 1996). In the context of transport related tropospheric ozone this means ensuring that transport and lifestyle alternatives respond to the requirements for flexibility, accessibility, privacy and security that people derive from private car-use. In other words there must be a net perceived benefit to the public from changes in their behaviour on an individual level, and consistent applicable methods for communicating these benefits need to be identified. To understand these issues we need to lean research towards understanding the needs aspirations and requirements of the populations with regards to air quality as well as the behaviour which causes its deterioration in the respective locations. We need to be able to identify the range of interests involved in the production of such a pollutant as well as methods of resolving any conflicts that may arise in such a way that they fit the context of both the social and atmospheric systems. It needs to be recognised that it is the interaction of these systems that has resulted in the issue in the first place. In summary, it is stated that research concerning the management of regional and behaviourally derived pollutants such as tropospheric ozone requires information to be utilised and integrated from the social as well as the natural sciences, both within and between regional localities. Finally, it should be noted that the tight budgetary constraints applied to local air-quality management may well restrict local authorities to those procedures for which it can ensure funding. This will inevitably hinder innovative work towards developing a regional strategic approach.
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