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Improving our air quality


Ensuring that everyone can breathe clean air is one of the most fundamental issues facing us today and an issue that we must all address, together.

Last year, we were the first Combined Authority in the country to declare a climate emergency. But we are not content to just talk about taking action; we’re already taking firm steps. Addressing poor air quality is a really important part of that and I have charged our newly established Climate Partnership to come up with a Climate Action Plan to draw up our region’s roadmap for tackling climate change.

During the first lockdown, we got a glimpse of what a greener future could look like. We all appreciated the reduction in traffic on our streets and the improved air quality that came with it, and we were reminded how valuable our green spaces are.

Our region has ambitious plans to become net zero carbon a whole decade before national targets and are already making progress through projects that replace polluting buses with greener hydrogen models, through retrofitting homes to make them more energy efficient and encouraging people to ditch their cars in favour of a 600km walking and cycling network we’re building.

Best of all, we’re developing plans to harness the power of the River Mersey, our region’s lifeblood for centuries, through a tidal scheme that has the potential to generate enough clean, predictable energy to power up to one million homes.

It is part of our plans to establish us as Britain’s ‘Renewable Energy Coast’, building on the impressive energy mix we already have in our region, from offshore wind to hydrogen and solar.

We know that we cannot tackle these issues alone. Our Air Quality Task Force is made up of representatives from across the six local authority areas of the city region and is already showing the power of collaboration.

It is through that collaboration that we have drawn up this plan, with suggested actions for the Combined Authority, for our local councils and other partners, for residents, communities and businesses and actions we need from central government and its agencies.

We all need to change the way we live, work and do business to improve air quality both for ourselves and for future generations. Now is the time for action

Steve Rotheram – Metro Mayor of the Liverpool City Region

Liam Robinson – Liverpool City Region Combined Authority Portfolio Holder for Transport and Air Quality



The aim of this action plan

1.1 This document supports existing action by our local authority partners and other bodies across the city region to tackle the problem of poor air quality. It sets out a vision and series of actions to improve air quality.  The Combined Authority, as a strategic body, has both direct and indirect influences and powers in this area.  But the fundamental principle that only through joint commitment and co-ordinated action can we solve this longstanding problem.

1.2 This plan supports and supplements the Economic Recovery Plan: Building Back Better developed by the Combined Authority in and its partners in July. This addresses the significant challenges – and also the opportunities and ‘green shoots’ – that present themselves from the COVID-19 pandemic.

1.3      There is consensus locally, nationally and internationally around the need to take urgent action to address the significant challenges presented by poor air quality, and nitrogen dioxide specifically.   This is a problem affecting most major towns and cities globally as a result of traffic and transport emissions in the main.  Equally, the challenges presented by particulate matter (PM), especially from domestic sources and industry pose significant dangers, if not to the same extend at a city regional level.

1.4      Public Health England reiterate that air pollution has a significant impact on our health; between 28,000 – 36,000 deaths each year are attributable to human-made air pollution in the UK and that more action is needed.  More specifically, Public Health England also estimate that air pollution contributes to around 800 deaths a year in the Liverpool City Region.

1.5      In the spring of 2018 the Combined Authority’s Overview and Scrutiny Committee convened a task and finish group to examine the issue of poor Air Quality across the Liverpool City Region.  This work entailed the collation of a detailed body of evidence on the causes and effects or poor air quality locally and the range of options to tackle the problem.  This work drew on presentations by, and discussions with a large number of expert witnesses.  This action plan does not seek to reproduce this important context in the interests of brevity, but the hyperlinks throughout the plan link to sources of further information.

1.6      The Overview and Scrutiny Committee developed a report and a series of recommendations.  These were presented the Combined Authority in June 2018 and were unanimously agreed. A summary of these recommendations is set out in the Appendix.

1.7      Of the recommendations agreed by the Combined Authority, one commitment related to the development of this action plan.  This was considered vital to clearly set out the Combined Authority’s approach to taking action on a Liverpool City Region footing.  Allied to this was the importance of working collaboratively with the constituent local authorities, local partners and central government to tackle the problem.

1.8      More specifically, it was agreed that this collaborative approach would be formalised through an LCR Air Quality Task Force, convened by the Authority, comprising elected members and officers from the local authorities, Combined Authority and Merseytravel, key government agencies and from business, to progress the actions needed in order to improve air quality.  The establishment of this group recognised that, irrespective of legal responsibilities, no individual body holds all of the powers needed; effective actions to tackle the problem are dependent upon a co-ordinated, collaborative approach.  This is also an approach that’s better able to secure value for money and economies of scale when it comes to delivery or action.

1.9      An interim plan was developed in October 2019 to coincide with the Air Quality Task Force’s initial 6-month work programme.  The intention was for the plan to be refined further ahead of the end of the financial year and updated in light of new considerations affecting the city region.  This also allowed time for the plan to be progressed through the governance and reporting structures of the Task Force’s partner authorities, including the Combined Authority’s Fairness and Social Justice Advisory Board (FASJAB) and Overview and Scrutiny Committee.  This was to secure the buy-in and alignment that is vital to deliver practical change.

1.10    At the time that the interim plan was being finalised, one of the most prominent considerations includes the “mandated” air quality study within Liverpool City Council that the Combined Authority is fully engaged with, but which was still underway at the time of drafting.  Other emerging considerations include potential air quality legislative changes, budgetary changes locally and nationally, the growing number of “Climate Emergency” responses, and the development of the Local Industrial Strategy (LIS).  These are highlighted in more detail in the sections that follow.

1.11    But of course, the biggest change and influence has stemmed from the Covid-19 virus pandemic that struck, culminating in the UK’s eventual “lockdown” in March and the restrictions imposed on non-essential travel.  This also entailed the closure of workplaces, schools, leisure facilities, the hospitality sector, and many shops.   The impact of the pandemic on air quality is extremely significant, given that traffic and trip levels fell drastically, reducing air quality and carbon emissions, boosted by a surge in walking and cycling for essential exercise and travel.  Cleaner air and quieter roads formed a positive ‘green shoot’ from the crisis that ensued, and whose effects will be felt for considerable time yet.

1.12    However, the wider impacts of the pandemic are equally significant in helpful to validate the actions in this plan.  The pandemic and its ongoing implications on daily life act as a stark reminder of the direct link between health and society as a whole.  Pollution, poor health and economic growth are most definitely not inevitable consequences as was once tolerated.  Harmful air – caused by the virus rather than air pollution in this case – has changed society, the economy and way of life overnight and unfortunately, the consequences of the pandemic are set to adversely affect the city region for a considerable time yet.

1.13    But addressing poor air quality and capturing some of the benefits seen during lockdown in air quality terms are now be critical components of our approach to recovering from the pandemic as set out in our Economic Recovery Plan and its focus on “Building Back Better”.

1.14    To reiterate, the original objectives and actions set out in this plan have been further validated and strengthened – rather than needing to be re-written – by the post-pandemic environment that we now live and work within and this plan will complement these wider recovery plans.



Recap – what do we already know?

2.1      Responsibilities

2.1.1   Action to monitor and manage air pollution is governed by legislation stemming from European Directives.  In legal terms, the main pollutant exceeding these defined standards across the LCR is nitrogen dioxide.  However, as noted, particulate matter (PM), comprising microscopically small particles from combustion, vehicle brakes, tyres and road surfaces, chemical reactions, construction or agricultural processes, for example, is also a harmful pollutant affecting the city region.

2.1.2   Most nitrogen dioxide emissions stem from transport emissions from the combustion of petrol and diesel. The Scrutiny Panel’s report contains more detail on these emissions and where Air Quality Management Areas have been declared.  As transport movements are not confined to local authority boundaries, neither do the sources of these emissions follow or respect local authority boundaries.

2.1.3   At present, the Combined Authority is not specifically covered by local air quality management legislation.  However, members have agreed that the Authority can and must act in response to the problem and in order to raise the profile of the issue.  Importantly, as the main nitrogen dioxide emissions locally stem from transport sources, and given the Combined Authority’s statutory responsibilities for transport policy and funding, our policies and priorities have a direct bearing on transport, on transport emissions and local air quality.  Equally, the Combined Authority’s emerging economic strategies, spatial plans and housing plans, as examples, affect atmospheric emissions and air quality.  The added value of the Authority as an “enabler” across a bigger area, and in being able to engage a wide range of partners is also critically important in terms of securing co-ordination and synergy and in helping to avoid any unintended consequences locally.

2.1.4   Under the emerging Environment Bill, there is the potential for statutory responsibilities for tackling poor air quality to be amended.  There is a strong possibility that the Combined Authority will be mandated with a duty to co-operate with other parties as part of this process.  This would formalise the collaborative approach to tackling poor air quality to date (aligning powers, funds and delivery) in a way that is similar to land use planning legislation that places a duty for local authorities to co-operate with one another on strategic cross-boundary matters.

2.2    “Mandated” work on Clean Air Zones

2.2.1   Many cities across the UK have been mandated by Defra to undertaken detailed studies to bring air quality within the prescribed limits within the shortest possible time.  These mandates include a requirement to investigate Clear Air Zone options.  Liverpool City Council is subject to this mandate.  A highway link in Sefton was identified as being potentially problematic, but in the authority’s 2019 Targeted Feasibility Study, concluded that the road link was compliant and that at this time, no further mandatory action is needed from Defra’s perceptive.

2.2.2   At the time of writing this report, the Clean Air Zones study in Liverpool is still in development, and implications will be addressed in a later iteration of the Action Plan.  Sefton MBC are also considering options around how best to improve air quality within the borough.  However, dependent upon the options that are ultimately shortlisted or mandated, these interventions are likely to be highly significant in both scale and impact.  Delays have arisen to these studies locally and wider as a result of the Covid-19 emergency.

2.2.3   The Combined Authority is continuing to actively support Liverpool City Council with the development of options development and potential delivery as part of the process of developing an outline business case submission to Defra.

2.2.4   Other major towns and cities across the UK are also developing air quality plans in response to similar Defra mandates, notably Greater Manchester as the city region’s nearest neighbouring city region.  Discussions are underway to understand cross-boundary impacts (e.g. the displacement of ‘clean’ vehicles or other unintended consequences) and to understand and minimise the negative impact of their clean air plans on Liverpool City Region.

2.3      Best practice

2.3.1   The LCR Air Quality Task Force has identified a wealth of opportunities and best practice to address our air quality challenge. Some of these are ongoing activities, others would be new.  And in many instances these actions need to apply more consistently across the city region. These include, but are not limited to the following examples under four main categories:-


Political commitment·      Most of the local authorities in the Liverpool City Region have declared climate emergency, including the Combined Authority itself.  These declarations stems in response to the pressing threat of climate change and the urgent need to take action of climate change, air quality and the environment.  For the LCRCA, this will build on the net zero carbon target of 2040.  Tackling climate change and poor air quality are considered as two sides of the same coin.·      Local partners are actively supporting LCR Year of the Environment 2019 and which includes the issue of air quality as one of its eight priority themes.

·      The development of effective partnerships to take collective action in response to complex problems and challenges, including the LCR Bus Alliance, the collaborative approach to Year of the Environment 2019, a technical group of expert air quality officers led by Wirral Council, and the Air Quality Task Force itself.

·      The Metro Mayor and Combined Authority have clear visions around a net zero carbon agenda and the role of clean growth, clean, renewable energy and clean fuels.  Halton and St Helens Councils are also important sources of hydrogen as an alternative fuel source for vehicles, to support these aims.

·      The Combined Authority’s impetus to “Build Back Better” from the Covid-19 pandemic, outlined below, is a further, very salient example of commitment to change our approach to growth and development.  This reiterates the fundamental need to protect and improve health and quality of life as part of an inclusive growth strategy.

·      Many local authorities have proactive approaches to enforcing emissions from vehicles, including buses and taxis, together with actions to clean and retrofit vehicle fleets through e.g. taxi licensing regimes and Sefton’s Council’s ECOStars goods fleet accreditation scheme.·      The Combined Authority is exploring the pros and cons of devolved powers available under the Bus Services Act in respect of bus service operations
·      Many local authorities use planning guidance to tackle or mitigate against poor air quality (e.g. standards for new developments or assessments of proposals in air quality)·      Access to £172.5m over the next four year to enhance sustainable travel through the Transforming Cities Fund.

·      LCR has extensive experience of bidding for and securing funds that tackle poor air quality, and to support the uptake of cleaner engines and fund sustainable travel options, including grant aid from sources such as the Office for low Emissions Vehicles

·      The adoption of robust policy frameworks that promote clean growth have clean growth, modal shift and air quality and resilience at their core, including the Combined Authority’s Transport Plan and agreement around a vision for bus to secure a  sustainable network that delivers commitments to air quality and health improvements.

·      Knowsley Council operates the Warm Homes scheme, focusing on those at risk of fuel poverty and who do not have gas-fired heating and entailing the installation of new boilers with better emissions.

·      The Government’s associated commitments and new funds made available during the summer of 2020 to boost the role of walking and cycling, as clean, healthy ways in which to travel and recover from COVID-19 restrictions further validate the transport-related air quality priorities set out in this plan.

·      The development of educational materials for schools and engagement with schools and parents (e.g. Sefton’s Clean Air Crew initiatives through its EcoCentre and an educational pack led by St Helens Council).·      Engagement with, and support for businesses, to tackle the problems and highlight the benefits of greener forms of transport, clean growth and clean air

·      The delivery of a range of campaigns, communications and events (e.g. on Clean Air Day and Car Free Day)

·      The Better By Bus Campaign to make the bus a more attractive option and to encourage a switch form private car usage

·      The use of innovative means of communicating complex public health messages to the public to raise the profile of the issues and target action


2.4      Building the evidence

2.4.1   As the Task Force was in the process of being established, the Combined Authority was concluding a high level study to better understand, and gauge the relative impacts of various measures available in which to tackle air quality problems.  This was developed by AECOM consultancy.  The final report was shared with the LCR Air Quality Ask Force at its first meeting in March 2019 and provided a valuable source of material in the identification of potential “quick wins” and longer-term actions, pilots or developmental work.

2.4.2   The report outlines the technical details, and potential impacts of implementing a range of interventions to improve air quality. 40 potential transport and non-transport interventions were identified and were scored and ranked by AECOM as follows as per the tale in Appendix Two.

2.4.3   This helped to identify a number of “quick wins” versus more complex, policy, delivery or funding-led approaches.  These quick wins can be highlighted below, and several are behavioural or regulatory in their nature and align closely with many of the examples of best practice in section 2.3.1 and in the action plan that follows:-

  • Engagement & Education
  • Bus Fleet Upgrades
  • Mersey Tunnel Tolls
  • Fleet Management
  • Travel Cards
  • Web Resources
  • Domestic Solid Fuel Burning
  • Tackling the effect of diesel generators

2.4.4   A number of other high-scoring measures are more complex in their scope, but will have the potential to make significant improvements to local air quality.  Measures like better urban traffic control traffic control systems, enhanced bus corridors and enhanced cycling infrastructure or piloting hydrogen fuelled buses are now being progressed via current funding opportunities (e.g. Transforming Cities Funding.  There are also aspects identified that may form future asks of government as part of the development of the Local Industrial Strategy or as part of the Spending Review process.  These are referenced in the action plan that follows.

2.4.5   Importantly, the study highlighted the importance of securing better data and evidence as a first step, together with enhanced air quality modelling capability for both the Combined Authority and the local authorities.

2.4.6   Allied to the mandated work” that is ongoing now (as set out in para 2.2), the AECOM study recognised the role of Clean Air Zones, and which a number of local authorities (including Liverpool) are considering as a measure to bring forward compliance with legal limits for nitrogen dioxide in the shortest possible time, and which entail a form of charging mechanism for non-compliant (“dirty”) vehicles.

2.4.7   From the high level study, CAZs were afforded a lower initial priority score by AECOM, preliminary areas that may be suitable for the implementation of a CAZ focused around Liverpool and Sefton, the greatest potential benefits may be achieved in terms of improved air quality and health.  Critically, the need for a better level of data on vehicle classes and engine types was highlighted, to understand better how the application of the CAZ scenario may affect local and regional emissions.  This is now reflected in the detailed business case being developed by Liverpool City Council and the options being explored by Sefton Council.

2.4.8   In March 2019, at the time that the task force was being established, Public Health England produced a further piece of timely evidence on the health risks arising from poor air quality and the interventions that would best address this – a “Review of interventions to improve outdoor air quality and public health”.

2.4.9   It provides evidence-based advice on actions available locally and nationally to reduce air pollution and its impact on our health.  It also challenges the view that actions to reduce air pollution run counter to economic growth and development, arguing that this is an opportunity for better air quality and economic prosperity to go hand in hand.  This is consistent with the emerging vision in the Local Industrial Strategy around health and wellbeing, linked integrally to clean growth.

2.4.10 The following are highlighted as effective interventions to address traffic-related emissions:-

  • Reducing emissions from existing vehicles (e.g. retrofitting)
  • planning for active travel and public transport use
  • Promoting low emission vehicles and reducing demand for more polluting forms of transport.
  • Using the planning process to reduce sources and exposure to pollution. (e.g. reducing the need for vehicle use by design and increasing the use of public transport and active travel)

2.4.11 Public Health England’s highlighted interventions align closely with issues identified in 2018 by the Overview and Scrutiny Committee and high-level recommendations to the Combined Authority. They also add further weight and validity to the measures identified in this action plan.

2.5      Climate Action Plan and relationship to improved air quality

2.5.1   In the summer of 2019, the Combined Authority declared a Climate Emergency.  This built on the Metro Mayor’s commitments to become a net zero carbon city region by 2040 and set ambitious targets for tackling climate change and to developing a Climate Action Plan.  Furthermore, as a legacy from the 2019 Year of the Environment, the Combined Authority committed to establish a Climate partnership for the city.  This would comprise key stakeholder and partners to play their part collectively in achieving the city region’s goals to address this global issue.

2.5.2   The Liverpool City Region Climate Partnership has proposed production of a ‘year one’ climate action plan to set out short term actions and targets. This aims to ensure that actions commence rapidly in line with the nature of the Climate and Ecological Emergency, whilst allowing time for full participation in developing the longer term plan.

2.5.3   The purpose of the Climate Action Plan is to create a clear framework for actions to achieve the city region climate and sustainability goals. The Climate Partnership has proposed a set of principles that will apply to both the Year One and longer term Climate Action Plans, recognising that the people who are most vulnerable to the impacts of climate and ecological breakdown are often those who are least likely to have contributed to the human causes of the emergency. These principles ensure that the Climate Action Plan will be driven by ‘climate justice’, putting fairness, equality and inclusion at the heart of the city region’s response.

2.5.4   The Year One Climate Action Plan will ensure that opportunities for early action are not missed, enabling early achievements in the City Region to be captured without detracting from the important goals that must form part of the longer term action plan. The early delivery of this short-term action plan will allow the inclusion of projects and initiatives that will form part of the LCR Recovery Strategy, ensuring that the city region Grows Back Greener from the tragedy of the COVID-19 pandemic, discussed further in the next section.

2.5.5   The nine themes identified will form a framework for climate action have been proposed which encompass the breadth of environmental concerns across the City Region, aligned to the United Nation’s Sustainable Development Goals. Critically in relation to this plan and underlying body of evidence, it will be appreciated that Air Quality features clearly as one of the nine priorities:-

2.5.6   Integrating air quality considerations into the climate action plan will help to avoid policy tensions or unintended consequences.  For example, incentives to shift from petrol to diesel powered cars in recent years have supported carbon reduction objectives but not air quality objectives, due to higher Nox emissions from diesel.  Similarly, the popularity of domestic wood-burning stoves have the advantage of being carbon neutral, but create air quality problems from the production of smoke.

2.6      Covid-19 impacts and responses

2.6.1   The unprecedented threat and national response in the spring of 2020 from the spread of the Covid-19 virus has a significant bearing on this updated plan.  The pandemic has highlighted the vulnerability of people and the economy from health and environmental factors and reasserted the clear link between good health and all aspects of daily life.  Clean, safe air is not an optional extra or a trade-off in the pursuit of economic growth and social development.  The pandemic has reaffirmed the importance of the measures in this plan and the imperative to tackle poor air quality and address its harm to health.

2.6.2   More fundamentally, the stark and disproportionate effect of the Covid-19 crisis on the LCR has become fully apparent.  The impact of the disease in an area with historically high deprivation, poor health, and poor air quality has been devastating, with higher rates of infection and fatalities locally in relation to comparable areas and the national average causing pain and suffering to families and communities across the region.

2.6.3   The link between COVID-19 symptoms and poor air quality were recognised by the Air Quality Expert Group in their report from June 2020:-

“Long-term exposure to air pollution is associated with increased morbidity and mortality from chronic diseases, some of which have also been identified as increasing the risk of severe COVID-19 symptoms. Given this, it would not be surprising if there was a link between exposure to air pollution (past or present) and the occurrence or severity of COVID-19 infection….”.

2.6.4   However, moments of disruption and emergency can often result in progressive change. The lockdown and the unusual circumstances that resulted at can be described as some ‘green shoots’ and positive trends – trends that need to be sustained beyond Covid-19 and restrictions on movements or travel.  This stemmed from the dramatic impact of lockdown on travel has been dramatic, with one of the most striking features of the crisis being the significant reduction in motor traffic on the City Region’s roads.  At the height of the restrictions in the spring, it was reported that nationally road traffic levels have fallen by 73%, to levels not seen since 1955, when car ownership numbered around 5 million, compared to today’s figure of 36 million.  This supported the surge in numbers of trips made by foot and by bike, with quieter, safer roads being conducive to walking and cycling for leisure and essential trips.

2.6.5   At the same, time, reductions have been experienced locally and nationally in harmful atmospheric emissions, serving as a reminder of the link between motorised transport trips and harmful carbon dioxide, nitrogen dioxide and particulate matter emissions.  The graph below from London helpfully tracks changes in nitrous oxide emissions from traffic – the main contributor to poor air quality within the Liverpool City Region, against the various lockdown phases:

Source: Air Quality Expert Group

2.6.6   However, social distancing requirements, coupled with reduced demand for bus and rail services are resulting in much reduced bus and rail capacity and patronage.  This was especially the case during the early stages of lockdown.  The graph below highlights these changes, viewed against the much higher levels of growth in of car traffic levels as lockdown conditions were eased.  This remains an ongoing challenge and risk in the event the trips previously made by bus and rail transfer to private cars, and which would undermine the objectives of this plan:-

2.6.7   With social distancing seen as the most effective tool in reducing the risk of catching the virus, active travel, and cycling in particular, have become increasingly important forms of travel, and instructed local authorities to make provision for “socially distanced” walking and cycling.

2.6.8   In May, government announced a new £250 million Emergency Active Travel Fund to support the rapid implementation of measures to allow people to walk and cycle safety.  These include ‘pop-up’ bike lanes, widened pavements, and cycle and bus-only corridors.  Liverpool City Council was the first authority locally to re-purpose main roads for pedestrians and cyclists, followed by Wirral.  This was followed by an initial award of £1.9 million to roll-out similar measures across the wider city region.  A larger sum of funding – £7.9 million – has also been secured under a second tranche to progress these measures further and to make temporary measures permanent.

2.6.9   This funding represents the first part of a longer-term cycling and walking programme, announced through the £5 billion buses, cycling, and walking package on 11 February.  In July, the Government published Gear Change: A bold vision for cycling and walking setting out major ambitions in this field.  This again reflects on how COVID-19 restrictions have profoundly impacted the way people live, work and travel as evidenced by the public’s desire to be more active, and the rise in popularity of cycling and walking.  The new strategy seeks to embed those changes in people’s travel behaviour, increase active travel, and transform how many people move around, particularly in towns and cities.  The strategy includes explicit references to air quality benefits amongst the many benefits associated with the shift to active travel:-

2.6.10 The strategy seeks to secure £2 billion of new investment in addition to existing funding is to be provided over the next five years, the majority of which will be channelled through local authorities and which is highly relevant to the aims and actions set out in this plan.

2.7      “Building Back Better”

2.7.1  As noted, a local Economic Recovery Plan: Building Back Better has been developed in response to COVID-19 and the disruption to almost every business across the country. It sets out an innovative set of local interventions needed to deliver effective, targeted support and finance, filling local gaps in provision.  This is complemented by ambitious, deliverable economic infrastructure projects capable of providing an economic stimulus now and delivering long term uplifts to ‘level up’ the North.   It sets out how an investment of £1.4bn will unlock £8.8bn worth of projects that can begin in the next 12-months across the city region

2.7.2   The plan is based on the firm belief that the long-term opportunities set out in the draft Local Industrial Strategy still exist, that our vision for a globally competitive, environmentally responsible, socially inclusive economy remains still valid and that addressing health, inequality and the climate emergency are critical to achieving this vision.

2.7.3   The Green recovery programme in the plan recognises the significant changes required to achieve carbon-neutrality and to deliver the green industries and jobs of the future. This includes projects like Mersey Tidal Power, an ambitious housing retrofit programme and a long-term green investment in hydrogen.

2.7.4   But vitally, the plan does not advocate a return to “business as usual”.  It notes how lockdown restrictions over the past few months have improved air quality, reduced traffic noise and increased appreciation for local green spaces.  As the economy starts to reopen and lockdown restrictions ease, it is important the benefits we have achieved so far are not lost.  It provides an opportunity to maintain the behaviours we have practiced over the past few months to improve the health and wellbeing of our residents and achieve the 2040 net zero carbon target.



Structuring this into an action plan

3.1      In considering the initial action plan in early 2020, members of the Overview and Scrutiny Committee noted the absence of targets and objectives in the plan and made important recommendations about the inclusion of performance objectives to frame this plan.

3.2      In practical terms, it will be appreciated that the air quality situation varies by local authority area.  Air Quality Management Areas exist in most but not all local authority areas, and Liverpool City Council has been formally mandated to address its air quality exceedances in the shortest practical time.  Different timescales exist for the implementation of Clean Air Zones in cities and city regions outside the LCR.  Each constituent local authority thus has statutory responsibility for achieving compliance, as noted in the context, and which makes the development of a composite city region-wide target difficult, and of limited added value.

3.3      Equally, the inability for EU-defined targets to be achieved across the UK (e.g. the requirements for local authorities to achieve air quality targets as for Nox as long ago as January 2010) suggests that target-setting in itself is not the best means to secure compliance and action.  This has resulted in the recent focus in pursuing more radical changes in the form of Clean Air Zones.

3.4      The focus in this plan is on raising awareness and commitment in response to a longstanding problem, by leading a partnership-led approach to the concerted actions set out in this plan.  A core recommendation and action in this plan entails working with partners to improve air quality monitoring and the quality of the datasets on air quality, to allow the impacts of measures to be assessed and modelled more rigorously, and to allow scenarios to be tested .  This priority action will also in itself help to target actions and interventions much more effectively that by setting potentially arbitrary targets in this plan.

3.5      That said, the need to set objectives is considered an important component of this plan as one that the Combined Authority and its partners can el to support the local authorities and partners in their statutory and civic responsibilities relating to clean air:-

The Objectives of this Action Plan

  1. To support the Liverpool City Region’s local authorities in their mandate to reduce harmful atmospheric emissions to within statutory levels in the shortest possible time, as a minimum, and preferably, to better and exceed these minimum target standards. This is in tandem to achieving the net zero carbon target by 2040.
  1. To support the local authorities in the revocation of Air Quality Management Areas in the shortest possible time.
  1. To avoid the need to declare new Air Quality Management Areas across the city region in respect of nitrogen dioxide emissions or any other harmful pollutants.

3.6      Drawing the above considerations together, the action plan that follows is divided into four main sections:-

  1. Actions by the Combined Authority
  2. Recommended actions to local authorities and our partners
  3. Actions for the LCR’s residents, communities and businesses; and
  4. Recommended actions to Central Government and its agencies

3.7      Where appropriate these are then divided into short term and longer term actions:-

  • Short term – for action or delivery immediately or within the next 12 months
  • Longer term – for action or delivery with the next 24-36 months

3.8         Importantly, this plan remains it is an important start in drawing together partners across the city region as a whole together, and coalescing around a shared vision and action plan.




SHORT TERM ACTIONS (WITHIN THE NEXT 12 MONTHS)Supporting our partners to clean the air·      We will work with Liverpool  on the development of options around poor air quality and potential clean air zones as part of the “mandated” work with Defra, and seek to secure synergies and common approaches

·      We will work with our colleagues at the Greater Manchester Combined Authority to understand the impact their clean air plans on the Liverpool City Region, to support complementary proposals.  This will seek to avoid any unintended consequences, such as displacement and avoid adverse effects on the Liverpool City Region

·      We will undertake a skills map of all local authority and Combined Authority staff working in the air quality area to identify where there is potential to share resources and support peaks in workloads or demand across the area.

·      We will foster stronger links with the health sector to develop collective approach to measuring and taking action in response to poor air quality across the city region, building on the preventative principles and a shared approaches to data and evidence

·      Through our Economic Recovery Plan and in the forthcoming Comprehensive Spending Review in the autumn of 2020, we will support our partners in the pursuit of funding to support measures that aid recovery from impacts of COVID-19 in ways that embody the principle of improving health, air quality and net zero carbon

Better data to support decision-making·      We will supporting our local authorities in their duties to monitor and improve air quality, and seek to foster a more “high tech”, consistent and extensive air quality monitoring regime across the LCR.  This will include air quality modelling (including modelling of carbon emissions) and data management capabilities, to allow scenarios to be tested and to inform decision-making processes.

·      With Public Health England, we will develop a more nuanced local model for air quality impacts that can be run to forecast the likely outcome of numerous policy choices and provide greater certainty about impacts on air quality in decision-making processes

·      We will help to build evidence around other potential pollutants of concern, including particulate matter (PM) and sulphur dioxide from all relevant sources (including shipping) and which could present future risks or problems

Effective plans and strategies to create clean, liveable and healthy places, served by a range of travel choices and avoiding reliance on private car use·      In the pursuit of our Economic Recovery Plans and the underlying principle of “building back better”, the enhancement of the quality of the air and improvements in health will form underpinning criteria in our plans and actions

·      In developing our plans and projects as a Combined Authority, we will ensure that issues of air quality are not considered in isolation and are fully woven into conversations and actions how we will deliver low carbon, clean and inclusive growth.

·      Specifically, we will do this as a core part of our emerging Local Industrial Strategy, which will be focused around four priorities

o   Good work, health and wellbeing for all;

o   Vibrant and connected communities;

o   More businesses innovating and growing;

o   Clean growth

·      These principles will be considered and woven fully into the development of other key strategies, such as the Spatial Development StrategyHousing Statement and a future Mayoral Transport Plan to ensure that strong and effective frameworks exist for constituent local authorities, especially on spatial planning matters and where a clear strategic rationale is needed to carry weight at a local level.

·      We commit to championing the delivery of agreed policy statements (e.g. the 2019 Combined Authority Transport Plan) on the imperative to deliver sustainable transport enhancements and create a shift from polluting forms of transport to clean, zero carbon forms of transport as significant contributors to better air quality locally.

Boosting active travel (walking and cycling) levels, especially for short trips·      We will deliver urgent measures through the Emergency Active Travel Fund (EATF) aimed at repurposing streets and places, to allow people to walk and cycle safely and in a socially distanced way.  This is to support the relaxation of lockdown conditions, and to ensure that the capacity restrictions on public transport as a result of social distancing to not lead to growth in car usage.

·      We will commission and support the delivery of a radical and comprehensive programme of walking and cycling upgrades within the next 4 years, linked to the Transforming Cities Funding programme and the development of a Local Cycling and Walking Infrastructure Plan (LCWIP).  The focus will be on a network of dedicated cycle routes, which are segregated from traffic, to encourage the switch from cars to bikes for short journeys.

·      We will investigate measures to boost investment in behavioural change campaigns and initiatives to complement this investment, and which will include the Rethinking Travel initiative that is supporting travel demand management in the relaxation of COVID-19 restrictions.

Through the £1.9m secured from Tranche 1 of EATF and the £7.9 million secured form Tranche 2This will be commissioned through the £172m Transforming Cities Funding programme, through the £2 billion of new investment committed over the next five years set out in the Government’s Gear Change strategy and through the LCR’s submission to the CSR in autumn 2020.

This work will also be supported by our LCR Cycling and Walking Commissioner

We are working to identify additional staff resources and sources of expertise amongst our local authority partners
  1. LONGER TERM ACTIONS (WITHIN THE NEXT 24-36 MONTHS)A well-managed Key Route Network·      We will help develop and deliver improved urban traffic control systems across the city region to better co-ordinate traffic movement and give intelligent priority, particularly for public transport and for active travel users.

    ·      We will test and use our co-ordinating and funding powers over a Key Route Network to better plan and deliver measures across the city region that prioritise clean forms of transport over polluting forms of transport and that support modal shift to sustainable forms of travel.

    Joint working with Highways England to reduce emissions on the Strategic Road Network·      We will investigate the potential expansion of the electric van pilot (under “Promoting clean fuels and technologies”) into a hydrogen HGV pilot, reflecting the LCR’s role as a major port and logistics centre

    ·      We will work with HE on a programme to develop prominent signage to Park and Ride sites from the strategic road network, to complement the development of new transport facilities and services (e.g. at Birkenhead North, Bidston, Newton-le-Willows and Maghull North) and to maximise the success of the new Merseyrail train fleet that is being introduced in 2019/20

    Bus, rail and ferries as the modes of choice for longer distance trips·      We are in the process of investigating alternative models of bus delivery to best serve the needs of the city region and improve air quality and will begin to implement the preferred option over the lifetime of this action plan

    ·      Through the Transforming Cities Fund’s Green Bus Route proposals, we will develop a new, holistic approach to bus quality, convenience and punctuality, by giving buses the right priority on our highways to make bus travel a more attractive opportunity

    ·      We will explore lower-cost ways to cross the river by bus.

    ·      We are procuring new cleaner, greener Mersey Ferries vessels that will replace the existing, 60-year old vessels and which provide a vital link between Wirral and Liverpool, especially for cyclists

    ·      As part of the introduction of the new Merseyrail rolling stock, we will further enhance the Merseyrail cycle locker scheme to encourage many more short trips to rail stations to be made by bike

    ·      We will work to integrate new and existing cycle hire schemes within the new smartcard and ticketing system in development, to allow people to pay for their journeys quickly and easily and to ‘mix and match’ with other forms of travel

    ·      We will investigate and implement where appropriate, new park and ride sites or extend existing sites where these remove or reduce polluting journeys by private car by intercepting vehicles from the strategic road network

    Vehicle scrappage and incentives to use clean vehicles, esp. taxis & light vans·      We will investigate options for an LCR scrappage scheme, working with LAs to look at phasing out dirty vehicles.  This will include the examination of a scrappage scheme for taxis, private hire vehicles, and light goods vehicles, targeted at small local businesses.  These could take the form of a leasing scheme, whereby clean vehicles are procured centrally, whether by the CA/LAs, a joint venture or privately, and leased to local business, to incentivise uptake and usage.

    ·      We will champion greater consistency of taxi and private hire vehicle standards across the city region, to create higher environmental standards overall, building on earlier scoping work led by Knowsley MBC in 2018.

    Tackling domestic emissions to clean the air·      We will investigate options and measures to improve our housing stock and domestic emissions.  Potentially, this could be around an energy retrofit programme and LCR domestic boiler scrappage scheme to help local residents reduce domestic consumption and tackle particulate matter emissions, supported by promotional messaging.  This would also be through an approach targeted to help least affluent residents first, in order to address fuel povertyReducing freight emissions·      We will develop with local authorities a local approach to make freight and logistics as sustainable as possible.  This will include joint work with the National Infrastructure Commission and the development of local pilots linked to e.g. local supermarket delivery chains and last mile logistics, to explore the scope for rationalisation or increase uptake of shopping deliveries to home instead of car trips to supermarkets.  This will also include actions to promote locally-sourced goods and produce that reduce ”food miles”

    ·      As part of the above, we will investigate models for urban consolidation for movement of goods focusing on options for ‘last mile’ delivery. This will be related to the collection of detailed evidence on freight movements to understand the state of freight”

    ·      With partners, we will seek to take forward a city region-wide vehicle accreditation schemes being effectively applied in selected local authorities, notably scheme in Sefton.

    Joined-up communications and campaigns·      Collectively, we recommend developing and delivering a consistent marketing campaign on Air Quality, including public information and an agreed calendar of events linked to consistent press and PR messaging (e.g. ‘Let’s Clean the LCR’s Air’).  This will be fully embedded and integrated with actions on climate change, to be joined-up and avoid duplication.

    ·      This will include a pilot across all local authorities of at least 2 schools per district to reduce the private car school run and associated emissions. A co-ordinated approach will be required to ensure that different approaches and different type of schools are being included (e.g. scoping a trial of staggered school hours to tackle peaks and troughs of demand).  This could lead to a longer term strategy to extend this approach to all schools

    ·      Through our Rethink Travel brand and messaging, we will continue to promote a hierarchy of travel modes and build confidence in walking, cycling and the use of public transport

    Local planning powers and the creation of create clean, liveable and safe places·       We recommend exploring the potential for a common approach to the development of planning policy, conditions and guidance for air quality agreed by each authority e.g. policies around the sustainable design of new developments and means of access, staff and site travel plans, management of car parking and vehicle movements, installation of low emission boilers, electric vehicle charging points, dust suppression controls during building stages etc.   This will also be considered as part of the development of the Combined Authority’s Spatial Development Strategy.

    ·      We consider that the profile of health, air quality and “climate emergency” considerations should be clearly factored into the policies, designations and major planning decisions made by local planning authorities.

    Enforcement of idling vehicles to reduce pollution at source·      We recommend the co-ordination of a consistent and collective approach to enforcing and ultimately, reducing numbers of idling vehicles, particularly around schools and at taxi ranks, to strengthen public messaging, and to tackle a root cause of emissions.
    LONGER TERM ACTIONS (WITHIN THE NEXT 24-36 MONTHS)Green infrastructure and the mitigation of pollution·      We recommend the piloting of an approach to greening development across all districts and where further greening can be part of this approach, e.g. targets for tree planting as part of new development or interventions, green walls, green roofs, tree planting and soft landscaping. This will also be considered as part of the development of the Combined Authority’s Spatial Development Strategy.

    ·      We recommend the investigation of Air Quality Barriers where appropriate on parts of the KRN and or the Highways England’s network that are close to schools and housing

    ·      To work to ‘green’ existing public infrastructure, including bus shelters and railway stations

    ·      To work to mitigate against poor air quality outside schools with greening-up and planting on a consistent footing across the city region

    Speed management to encourage modal shift and cleaner air·      We encourage all LCR local authorities to test and adopt a policy of 20mph on all local residential roads following on from positive outcomes experienced in Liverpool and parts of Sefton, to encourage walking and cycling, especially for short trips.  This will also be considered within the refresh of the Road Safety Strategy in 2020.
    SHORT TERM ACTIONSJoined-up communications and campaigns  – “we’re all doing our bit”·      Through the umbrella of the Air Quality Task Force, we will work together to align our public-facing communication and publicity plans to secure greater targeting of messages and co-ordination of public campaigns, messages and incentives on means to take action to improve air quality.

    ·      The public sector will maintain effective engagement with businesses on the air quality agenda and on the benefits of “responsible business” that reduces air quality emissions.  This will include early and meaningful engagement and consultation on publicly funded proposals that have a significant bearing on movement or business operations across the city region.

    ·      Members of the Air Quality Task Force will work with Chambers of Commerce to seek to establish air quality “consultancy” and awareness-raising sessions for local businesses so that they can understand the need to change behaviour or practices, and the cost and business opportunities associated with this.  This will be aligned with existing business support or outreach activities.

    ·      With our Chambers of Commerce and business support groupings, we will engage local small businesses and end users on clean vehicle fleets and recuing air quality form their activities, linked to the Highways England electric van trial scheme as an example.

    ·      Members of the Air Quality Task Force will support grassroots and community groups with the provision of factual information, advice and joint campaigns and communications in order to take action to improve local air quality (e.g. Car Free Days, walking buses, green infrastructure, home insulation and energy efficiency).

    ·      We recommend joint action to raise the profile amongst residents and businesses of wood burning stoves and their implications on particulate matter emissions, linked to the need for better national regulations on definitions and standards.

    LONGER-TERM ACTIONS (WITHIN THE NEXT 24-36 MONTHS)Joint work with Highways England·      We recommend an investigation into the potential for speed reductions on the local motorway network, to reduce emissions at source, leading to potential ask of Government to implement these, noting trials ongoing for a 60mph speed limit on the M602 in Greater Manchester

    ·      We will engage HE to invest in prominent signage to public transport park and ride sites from the HE network to coincide with the introduction of complementary public transport enhancements

    Long term funding confidence to support clean air interventions and modal shift·      We will work with Government and through our collective network groups to make the case for long-term funding certainty to support the delivery of measures that support clean air and extend above and beyond compliance standards, so as to support wider quality of life and wellbeing objectives.  This includes both capital and revenue spend.Streamlining local enforcement of pollution and emissions·      We will engage with government to encourage the timely introduction of updated national regulations and guidance to address issues such as idling vehicle engines, dark smoke and smoke control areas, as identified in the clean air strategy 2019.  This is to address existing cumbersome legislative provisions that can make local enforcement complex or bureaucratic.Fiscal support for low emission vehicles·      We will make the case for financial incentives to be made available to freight and public service fleet operators to invest in low emissions vehicles, scarp existing “dirty vehicles” or to retrofit existing polluting engines through a targeted programme

    ·      We will work with the government to ensure that taxation and regulatory systems support the uptake of clean vehicles and clean fuels, through regimes such as the Bus Services Operators Grant (BSOG), which currently incentivise the use of diesel rather than hydrogen or electrical power

    ·      We will engage government and industry on initiatives to remove the oldest and dirtiest engines from the vehicle fleet through scrappage schemes or similar for domestic vehicles.  Building on experiences of the past, this must be done in ways that do not lead to unintended consequences (e.g. social exclusion, the creation of incentives to drive or be car-dependent, or that creates displacement from one pollutant to another).

    Aiding co-ordination and communication on clean air·      We will impress upon Government the need to urgently embed air quality and climate emergence more effectively across government departments and on a “prevention is better than cure” principle to actively avoid the creation of emissions at source whether from industry, from homes or from transport.

    ·      We will seek support from central government, NHS and health bodies to bring greater cohesion to LCR health boundaries and a “single voice” with the health sector, to work more effectively across currently complex health boundaries and aligns budgets more effectively

    Cleaner, greener national and inter-city connectivity·      We will reiterate our evidenced work on the importance of national and inter-regional enhancements to our rail networks to facilitate modal switch to rail and reduce emissions, through schemes such as High Speed 2, Northern Powerhouse Rail.  We will reiterate the role that enhanced northern rail capacity and connectivity plays in supporting the rebalancing of the UK’s economy and in reducing wasteful haulage-related emissions from an over-reliance on south eastern ports.

    ·      With other relevant local authorities and alliances, we will formulate an approach to reduce emissions from local aviation and from shipping (freight and cruise liners), particularly through measures that support the use of low emission fuels when taxiing/idling airside or berthed in port, respectively.

    With Transport for the North, industry and with Central Government


Conclusion and next steps

  • This plan has been informed and overseen by the LCR’s Air Quality Task Force and has been developed in two stages, via an Interim Plan endorsed by the Combined Authority in November 2019 and this final plan considered and endorsed in December 2020.
  • The plan is considered a programmatic and robust approach that guides the work of the Combined Authority and its partners in the imperative to tackle the causes and effects of poor air quality.
  • It also forms a key supporting document for other Combined Authority plans and programmes, notably the draft Local Industrial Strategy, Climate Action Plan, Housing Statement and Spatial Development Strategy, as prominent examples.
  • The move from the Interim Plan in November 2019 to this finalised plan has been heavily influenced and framed by the COVID-19 pandemic. The recovery plan developed by the Combined Authority and its partners in response provides a further imperative to “build back better”.  Very clearly, addressing poor air quality and capturing some of the benefits seen during lockdown in air quality terms are critical components of this approach.  This has meant that the original objectives and actions set out in the interim plan have been further validated and strengthened by the post-pandemic environment that we now live and work within.  The actions have thus been refreshed and reframed rather than re-drawn.
  • A critical issue recognised throughout the process of the production of this plan concerns the importance of joint working and a collaborative approach. This stems from the clear realisation that no single body can resolve poor air quality in isolation.
  • The plan and the actions contained within it will be managed and overseen by the Combined Authority, aided by the Overview and Scrutiny Committee. However, constituent local authorities will also be encouraged to report and ratify the plan through their own governance structures. This is to provide the necessary links to the plans and programmes of constituent partners and to help to embed the issues and recommendations contained within this plan more locally.
  • Reflecting the important role of the Overview and Scrutiny Committee in recommending the establishment of this task force in the spring of 2018, this Committee considered the draft final plan in November 2020 ahead of its consideration and adoption by the Combined Authority. Regular updates on the plan’s implementation will be reported to the Overview and Scrutiny Committee at regular intervals so that its delivery can be monitored as appropriate.
  • Finally, the Air Quality Task Force set out to develop this plan on a ‘task and finish basis’ basis and members agreed to conclude the work of the group in September 2020. Critically, however, this was with the intention of embedding this work and action plan with the work of the LCR Climate Partnership and the Climate Action Plan that has been outlined in section 2.5 and as per the Air Quality priority within the Climate Action Plan’s structure, reproduced below:-
  • This integrated approach will support the natural links, and also the synergies needed, between issues of clean air and a zero carbon LCR. It also serves to embed the air quality priorities firmly amongst the Climate Partnership’s constituent members.

4.10    Finally, this plan will also form a key supporting document for other Combined Authority plans and programmes, notably the Economic Recovery Plan, the draft Local Industrial Strategy, Housing Statement and Spatial Development Strategy, as prominent examples.


Recap on Air Quality Recommendations Agreed by LCRCA in June 2018

  1. That the Metro Mayor, on behalf of Combined Authority, acts as a political “champion” for a series of long term measures to improve air quality across the Liverpool City Region, involving a wide range of influential bodies and decision makers. The preliminary air quality feasibility study which is in the process of being finalised, and the action plan that needs to be developed in response, should be formally considered by the Overview and Scrutiny Committee in due course. This will come ahead of consideration by the Combined Authority.
  1. Allied to this, the Metro Mayor and the Combined Authority should champion a communications plan to set out a commitment to engage with people across the LCR. This should be targeted as follows:-
  1. to engage with schools and young people who are particularly vulnerable to the effects of poor air quality, aided by consistent educational materials and best practice across the LCR;
  2. to engage with the public protection and public health sectors to jointly raise awareness, which could be through roadshows and events, as examples; and;
  3. To promote National Clean Air Day and related campaigns.
  1. The communications plan needs to explain clearly that the LCR has a problem and set out what can be done to both alleviate symptoms, and help address the root of the problem.
  1. he Combined Authority needs to fully utilise and align its funding, transport, planning and economic development powers to create an environment where people have reduced reliance on road transport and make greater use of walking, cycling and public transport. For example, this could be linked to the Authority’s emerging digital strategy and the powers that it has over a Key Route Network of local roads. This also needs to be consistently applied through the Authority’s plans and strategies, e.g. through the Freight Strategy and Local Journeys Strategy.
  1. The Combined Authority should use its emerging Spatial Development Strategy to address poor air quality and to raise air quality as a policy consideration.
  1. The Combined Authority should give prominent and consistent consideration to air quality implications in its decision-making processes and in its investment decisions. This could include much better “before and after‟analysis in project and programme evaluations.
  1. The Combined Authority should support the six constituent local authorities in their statutory duties to monitor and address air quality, and seek to foster a more “high tech”, consistent and extensive air quality monitoring regime across the LCR. The Combined Authority also needs to work collectively with the constituent local authorities and with central government to tackle the problems caused by vehicles and engines that create the most pollution. This should take the form of an LCR air quality task force, convened by the Authority, comprising officers from the local authorities, Combined Authority and public health bodies, to progress the actions needed in order to improve air quality.

Appendix 2

AECOM Air Quality Feasibility Study – Ranking of measures

MEASUREUrban Traffic Management ControlSupplementary Planning GuidanceEngagement & EducationBuilding StandardsCross Boundary TravelBus Fleet UpgradesMersey TollFleet ManagementTravel CardsWeb ResourcesDomestic Solid Fuel BurningNRMM ULEZDiesel GeneratorsFleet Recognition SchemeCar ClubsPollution Event ForecastingSegregated Bus CorridorsRed RoutesRenewable Micro Energy GenerationFreight CoordinationTaxi ManagementReal-time Passenger InfoTravel Planning ResourcesGreen InfrastructureCommercial & Domestic BoilersAir Quality NeutralVariable Parking ChargesCycling InfrastructureClean Air ZoneConstruction EmissionsStreet WorksBus Layover FacilitiesSchool AuditsBusiness EngagementShipping EmissionsSustainable ProcurementAlt Fuel InfrastructureShared SpaceAgricultural EmissionsAir Traffic Emissions8

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