Key information
Decision type: Assistant Director
Directorate: Good Growth
Reference code: ADD2832
Date signed:
Date published:
Decision by: Elliot Treharne, Assistant Director of Transport, Infrastructure and Connectivity
Executive summary
Despite huge progress, London still exceeds the WHO ’s recommended health-based guidelines for both NO2 and particulate matter. Transport remains the largest single source of London’s air pollution – but, following the Mayor’s interventions, its contribution has dropped significantly. There now needs to be more focus on other sources, such as construction and buildings. The Mayor’s Cleaning London’s Air Delivery Plan sets out interventions to address air pollution, including from construction which the London Atmospheric Emissions Inventory (LAEI) 2022 names as the largest source of PM10 emissions.
In 2015 the Mayor of London introduced specific emissions standards for the machinery used on construction and demolition sites. These standards, based on EU Emission Stages, apply inside the Non-Road Mobile Machinery Low Emission Zone (NRMM LEZ), which relies on Mayoral and borough planning powers to control emissions from NRMM on construction sites.
The NRMM website was developed to help enforce the NRMM LEZ, by enabling construction site operators to register machinery and demonstrate compliance with planning conditions. The register is used by London boroughs to monitor such compliance; and by the GLA to issue exemptions and monitor compliance with GLA Group NRMM contractual requirements.
Essential upgrades to Java and Spring are required for the website to remain live and operational; and to meet minimum security requirements. The GLA’s Digital Experience Unit recommended rebuilding the website with up-to-date programming solutions. This would enable the NRMM register to meet the ongoing needs of the construction industry, which must use zero-emission machinery by 2040.
Whilst maintenance of the NRMM website is included under Section 2.2 in the Cleaning London’s Air Delivery Plan, overall costs for this project are not listed within the table of resources. Therefore, this decision seeks approval to spend up to £200,000 from the Air Quality Capital budget to deliver this work. Paragraph 1.18 of MD3400, states that the SRO may take expenditure decisions relating to projects to reduce key sources of air pollution identified in the LAEI 2022. We are seeking a change to the Delivery Plan through the change control process to reflect this budget for the rebuild of the NRMM website.
Decision
That the Assistant Director of Connectivity, Air Quality, Transport and Infrastructure approve spending up to £200,000 from the 2026-27 Air Quality Capital budget to design and rebuild the Non-Road Mobile Machinery website.
Part 1: Non-confidential facts and advice
1.1. Construction, including non-road mobile machinery (NRMM), is a significant contributor to air pollution and carbon emissions in London. According to data from the London Atmospheric Emissions Inventory (LAEI) 2022, the construction industry accounts for 25 per cent of particulate matter emissions; 5 per cent of nitrogen dioxide (NO2) emissions; and 2 per cent of carbon dioxide (CO2) emissions.
1.2. In 2015, the Mayor of London introduced emissions standards for the machinery used on construction and demolition sites. These standards apply within what is known as the Non-Road Mobile Machinery Low Emission Zone (NRMM LEZ).
1.3. The NRMM LEZ uses Mayoral and borough planning powers to control emissions from NRMM on construction sites. It does so by requiring machinery to meet specific emission standards, based on the EU Emission Stages. The NRMM standards are designed to become progressively tighter; by 2040, only zero-emission NRMM will be permissible at London’s construction sites. The Cleaning London’s Air Delivery Plan sets out four work strands. The second of these is “Cutting pollution from all sources to improve health outcomes and reduce health inequality for Londoners”.
1.4. A key intervention from this second work strand is “2.2 Delivering, tightening, and enforcing the NRMM LEZ”. This involves ensuring compliance through an ongoing audit of construction sites as part of the pan-London NRMM programme and maintenance of the NRMM register and exemption system.
1.5. The NRMM register is hosted on the NRMM website. The register is used to enable:
• the GLA to make policy decisions and grant exemptions for non-compliant NRMM
• London construction sites to register their machinery – a requirement of their planning conditions
• London borough officers to gather data for their statutory Air Quality Reporting, as part of their Annual Status Reports
• site auditors to audit sites across London, to ensure compliance
• GLA group users who procure NRMM to demonstrate compliance with the Responsible Procurement Implementation Plan.
1.6. The GLA’s Digital Experience Unit (DEU) needs to carry out essential upgrades to Java, Spring (the development framework for Java sites) and Velocity (the library used for the NRMM website front end). These upgrades, made to the NRMM website, will enable the site to remain functional. They are significant, especially as Velocity is no longer supported. Rebuilding the NRMM portal, and improving its functionality, has therefore been identified as a way to achieve value for money – rather than replacing individual outdated components.
1.7. Ensuring the website remains functional:
• allows the GLA and London boroughs to meet their planning, statutory and policy duties
• improves the user experience for all stakeholders
• maintains and improvs website security.
These upgrades will help the construction industry to meet the Mayoral policy of zero-emission machinery by 2040.
1.8. The NRMM website is part of the GLA Digital Estate and has been identified as an essential project. Delivery will be led by the DEU using approved delivery partners; and will take place in two phases:
• phase 1: discovery and design (stakeholder research, prototyping, testing and design)
• phase 2: build (development of the final website).
1.9. A supplier for phase 1 (discovery and design) has been selected. The work will be delivered under an existing DEU call off contract, procured through a competitive process via the GLA’s approved G Cloud 14 framework. The supplier for phase 2 (build) will be selected following completion and review of the discovery phase, and confirmation of the build platform. The DEU expects to appoint a supplier using the same framework process as phase 1. All procurement has complied with the GLA Contracts and Funding Code, and the terms of the G-Cloud 14 framework, using a competitive process open to all eligible framework suppliers. No exemptions were sought during the procurement of these contracts.
1.10. The existing contract values are expected to be sufficient to deliver the rebuild. The ongoing nature of the GLA Digital Estate activities were clearly communicated with TfL Procurement during the early stages. Therefore, no additional approval is required.
1.11. GLA officers are seeking approval to spend up to £200,000 from the Air Quality capital budget to deliver this work.
2.1. The main objective of this project is to rebuild the NRMM website and register, to:
• ensure that it remains accessible and secure – product support recently expired, which poses an immediate data security risk if no action is taken
• improve user experience for all users including the construction industry, the GLA Group, local authorities and NRMM auditors
• improve functionality and adaptability, which will enable website modifications as the NRMM LEZ standards progressively tighten leading up to 2040.
2.2. Any bugs and fixes will be addressed through manual testing after each sprint. Any performance issues will be reviewed and resolved after the website relaunches. An accessibility audit will take place once the website updates have been completed, to ensure it is meeting accessibility guidelines.
2.3. Specifically, the outcomes of the project are to:
• rebuild the NRMM register to use supported back-end development, resulting in a secure website
• provide new GLA front-end capabilities – this means website updates can take place without further back-end development as NRMM LEZ standards tighten leading up to 2040.
• improve the website experience for GLA Group users; construction site users; local authorities; and NRMM auditors
• update dashboards and user journeys, so users need less help using the site
• improve the process to log in and create accounts; this will make the website more secure, and stop it from acting as a barrier to compliance with planning conditions
• enable better-quality data, to support policy evaluation and improve the accuracy of LAEI (which uses data from the NRMM register).
2.4. The project will be delivered using the following DEU-approved processes:
• discovery and design phase: stakeholder research; design, delivery and testing of prototype
• build phase: producing the website
• manual testing: smoke testing of the new user functionality by specialists
• penetration testing – robust testing of the NRMM website before going live, to ensure that it is secure and meets the GLA’s security requirements
• accessibility testing and audit – there is a legal requirement to ensure the website meets the Web Content Accessibility Guidelines 2.2 AA, which is monitored by the Cabinet Office.
3.1. The GLA and other public authorities must have due regard to the need to eliminate unlawful discrimination, harassment and victimisation; and to advance equality of opportunity, and foster good relations, between people who share a protected characteristic and those who do not, under section 149 of the Equality Act 2010. This involves:
• having due regard to the need to remove or minimise any disadvantage suffered by those who share a relevant protected characteristic
• taking steps to meet the different needs of such people
• encouraging them to participate in public life or in any other activity where their participation is disproportionately low.
3.2. The protected characteristics and groups are age, disability, gender reassignment, pregnancy and maternity, race, sex, religion or belief, sexual orientation, and marriage/civil partnership status. Compliance with the Equality Act 2010 may involve treating people with a protected characteristic more favourably than those without one. The duty must be exercised with an open mind, and at the time a decision is taken in the exercise of the GLA’s functions. Conscientious regard must be had that is appropriate in all circumstances.
3.3. In June 2023, the GLA published updated analysis on exposure to air pollution. This showed not only that there are huge health impacts of pollution, but also that these fall disproportionately on the most vulnerable Londoners; more deprived people; and Black, Asian and Minority Ethnic communities. It also established that those who contribute the least to poor air quality suffer the most from it. This means that improving air quality is fundamentally about tackling social injustice and health inequalities.
3.4. UK construction and demolition sites, including roadworks, can be a significant contributor to local particulate levels if they are not well managed. These projects can last several years, and at times will be in the same area. This generates significant emissions, which adversely affect local residents’ health.
3.5. The NRMM LEZ aims to control emissions from construction sites, with a goal of reaching zero emissions by 2040. This is helping to improve London’s air quality; and reduce exposure to poor air quality for millions of Londoners who live and/or work near construction sites.
Risks and issues
4.1. The key risks and issues, and their mitigating actions, are outlined in the table below.
Links to Mayoral strategies and priorities
4.2. This programme directly contributes to the Cleaning London’s Air mandate; and the associated delivery plan, which has four key intervention workstreams. This work directly contributes to two of these:
• cutting pollution from all sources, to improve health outcomes and reduce health inequality for Londoners
• working with London boroughs and other partners, to take effective action to reduce exposure and emissions.
4.3. This programme will also contribute to delivering the Mayor’s London Environment Strategy, the London Plan, and the Mayor’s Equality, Diversity and Inclusion Strategy – as detailed at paragraphs 4.4 to 4.8, below.
London Environment Strategy
4.4. Proposal 4.2.3a states:
“The Mayor will work with government, TfL, the London boroughs, the construction industry and other users of Non-Road Mobile Machinery (NRMM), such as event organisers, to prevent or reduce NRMM emissions.”
4.5. Proposal 4.2.3b states:
“The Mayor will work with industry and other partners to seek reductions in emissions from construction and demolition sites.”
The London Plan
4.6. Policy SI 1: Improving air quality states:
“In order to reduce the impact on air quality during the construction and demolition phase development proposals must demonstrate how they plan to comply with the Non-Road Mobile Machinery Low Emission Zone and reduce emissions from the demolition and construction of buildings following best practice guidance.”
The Mayor’s Equality, Diversity and Inclusion Strategy
4.7. The Mayor’s Equality, Diversity and Inclusion Strategy sets out how he will work to create a fairer, more equal, integrated city where all people feel welcome and able to fulfil their potential.
4.8. Objective 4 of the Equality, Diversity and Inclusion Strategy is to:
“Improve Londoners’ air quality and access to green space and lower the city’s carbon emissions so that inequalities in exposure to harmful pollution and climate risks are reduced.”
Conflicts of interest
4.9. There are no known conflicts to declare regarding those involved in the drafting or clearance of this form.
5.1. This decision requests approval to spend up to £200,000 to redesign and build the NRMM website and register.
5.2. As the NRMM website forms part of the GLA’s Digital Estate, the work will be undertaken by one of DEU’s contracted suppliers. A contractor has been appointed for phase 1 (discovery) following a competitive bidding process that went out to all suppliers on the Framework Agreement. The decision on the contractor for phase 2 (build) will be made once discovery has been completed, outputs have been reviewed and the build platform is confirmed.
5.3. This expenditure will be funded from the Air Quality Programme capital budget, within the Mayor’s approved budget for 2026-27.
5.4. All spend will be incurred by the end of 2026-27. All appropriate budget adjustments will be made.
6.1. The project will be delivered according to the following timetable:
None.
Signed decision document
ADD2832 Non-Road Mobile Machinery (NRMM) website design and rebuild