Decision details

Greater Manchester’s Clean Air Plan - Tackling Nitrogen Dioxide Exceedances at the Roadside - Outline Business Case

Decision Maker: Health, Schools and Care Overview and Scrutiny Committee, Cabinet

Decision status: Recommendations Approved

Is Key decision?: Yes

Is subject to call in?: No


To summarise the key features of Greater Manchester’s feasibility study and its Outline Business Case (OBC) to reduce nitrogen dioxide exceedances in Rochdale Borough and across Greater Manchester in the shortest possible time. This OBC has been developed by Rochdale Council collectively with all Greater Manchester local authorities and the GMCA, and co-ordinated by TfGM in line with Government direction and guidance.


Cabinet considered the report of the Director of Neighbourhoods that summarised the key features of Greater Manchester’s feasibility study and its Outline Business Case (OBC) to reduce nitrogen dioxide exceedances in the Rochdale Borough and across Greater Manchester in the shortest possible time. The OBC had been developed by Rochdale BC collectively with all Greater Manchester local authorities and the GMCA, and co-ordinated by TfGM in line with Government direction and guidance.


Cabinet were informed that the Health Schools and Care Overview and Scrutiny Committee had considered the report at a meeting on 13th March and had asked a number of questions and were supportive of the proposals.


Alternatives considered:


Following the issue of the Strategic Outline Case (SOC) in March 2018, a process of refining the shortlisted measures and developing a range of options that combine the measures in different ways has been undertaken. This was overseen by the GM Steering Group, to understand the type and scale of intervention needed to reduce NO2 to within legal Limit Values in the “shortest possible time” across Greater Manchester.


A best performing option was recommended within the Outline Business Case (OBC) for further consideration and discussion with stakeholders and the public to aid the development of the Full Business Case.


The core goal of the GM Clean Air Plan was to address the legal requirement to remove ALL exceedances of concentrations of NO2 that have been forecasted to exceed the legal Limit Value (40 ?g/m3) identified through the target determination process in the “shortest possible time” in line with Government guidance and legal rulings.


Options had been assessed against the UK Government’s Primary Critical Success Factors:

·         Reduction in NO2 emissions: likelihood that the measure/option will contribute significantly to a reduction in NO? concentrations to achieve compliance with the EU Limit Values

·         Feasibility: likelihood of measure being implemented in time to deliver desired NO? reduction and achieve compliance.


Where modelled options deliver compliance in the same year they have been further assessed against Government’s Secondary Critical Success Factors, as set out in the SOC:

·         Strategic fit with local strategies and plans: ensuring the alignment of the option with longer term economic, social and environmental goals and that the risk of unintended consequences is minimised.

·         Value for money: a high-level indication of the costs and benefits of each option.

·         Distributional impact: in order to understand the potential impacts, both positive and negative on different groups within society, with a particular focus on the most vulnerable. It is of vital importance that the plan does not result in disproportionately negative economic or social impacts for the region or those living, working or doing business within it.

·         Deliverability of the options, in terms of the affordability of the cost of implementation, the supply-side capacity and capability to deliver the measures outlined in the options, and the achievability of delivering the option.


The SOC identified that the fundamental causes of the exceedances were variable in terms of the source of emissions and that these sites were interconnected in complex ways. Therefore, any effective proposals would need to comprise of a package of measures, able to tackle the overall problem holistically.


A series of six options comprising of different packages of measures was developed initially in response to the problem as revealed by local modelling. These measures have been assessed and refined further from the shortlist in Table 1 of the report.


The assessment process involved further modelling and analysis of the effectiveness of measures, both individually and as a package; this included engagement with stakeholders and professional experts, and the use of a Multi-Criteria Analysis (MCA) tool to assess the performance of each option against the success factors and relative to each other. In this way, the measures and packages of options have been assessed and refined into a preferred option that best secures the required objectives.




That the feasibility study undertaken to date be adopted;


1.    It be noted that further stakeholder engagement and public consultation is an essential part of the process to help inform and refine ongoing work to produce a Full Business Case by the end of the calendar year;


2.    That the Outline Business Case (OBC) be approved (for submission to the government's Joint Air Quality Unit) as appended to the submitted report;


3.    That the Government be required to provide the financial support necessary to enable the Council to meet its legal limits for nitrogen dioxide;


4.    That it be noted that despite this council being required to address nitrogen oxide exceedances the government has not yet addressed this issue for its own assets, including Highways England and the motorway network;


5.    That the commencement of the public conversation and engagement activity from 15 May 2019 be approved;


6.    It be noted that further reports will be submitted to Cabinet on:

·         the proposals for statutory consultation, informed by the outcome

of the public conversation and engagement;

·         formal approval of the Full Business Case;


7.    That TfGM continuing with the activity to produce the Full Business Case on their behalf under the direction of the Greater Manchester Clean Air Steering Group be approved; and


8.    That authority be delegated to the Director of Neighbourhoods in consultation with the Cabinet Member for Health and Wellbeing for the approval of submission of supplementary information.


Reasons for the decision:


Taking action on air quality is not optional. The severe and long lasting health implications of poor air quality as well as the legal obligations placed on Greater Manchester local authorities’ means that authorities need to act decisively and swiftly to reduce harmful air pollutants, and nitrogen oxides in particular.


Greater Manchester authorities in deciding to work together to respond to this vital issue are demonstrating collective leadership, which is essential to help clean the air for our combined population of nearly three million residents. Analysis reveals that locations of damaging roadside nitrogen dioxide concentrations can be found in every district.


Given that air pollution does not respect boundaries, this coordinated approach is also the most effective way to deal with a problem that affects all parts of Greater Manchester, and cannot be remedied on a site by site or district by district basis


The ten authorities, supported by Transport for Greater Manchester, have now developed a draft package of co-ordinated and robust measures in a very short period of time that complies with the highly prescriptive Government guidance for tackling NOx emissions.


However, much more work is required to flesh out some of the measures to ensure that they achieve their intended purpose, and to ensure that the measures proposed to support affected businesses and individuals are fair and effective, and that the socio-economic impacts of measures are understood and can be mitigated


This is why further engagement with stakeholders and affected parties to refine the measures, in addition to full public consultation, are vital next steps in the process toward developing the Full Business Case by the end of the year.


The Greater Manchester approach, set out below, will require significant government funding. Without full financial support, the package of measures which was devised in the context of guidance that identified Implementation


Funding and Clean Air Plan funding is unlikely to deliver the intended results. In a scenario of inadequate government support, the most obvious outcomes are a failure to reduce exceedances as quickly as required, and economic damage, for example to local businesses who are left unsupported but required to upgrade their vehicle fleet.


By taking a combined approach, Greater Manchester’s bid for the substantial funding required to deal with this key public health priority can only be strengthened.


Eligible for call in - yes

Report author: Nicola Rogers

Publication date: 26/02/2020

Date of decision: 18/03/2019

Decided at meeting: 18/03/2019 - Cabinet

Accompanying Documents: