MD2340 Mayor’s primary schools & nurseries air quality audit programme

Improving air quality is a public health priority. Air pollution is contributing to thousands of premature deaths caused by long-term exposure. There is also strong scientific evidence of the acute health effects of short-term exposure to very high levels of pollution, like those experienced during an air pollution episode. It is essential that coordinated action is taken to reduce exposure, especially amongst those most at risk such as school children, children attending nurseries and the elderly.

To tackle exposure specifically by primary school children, who are often the most vulnerable to the effects of air pollution, the Mayor has undertaken a new Primary School Air Quality Audit Programme under MD2096. Under this £250,000-programme, 50 primary schools received detailed air quality audits carried out by an experienced transport and environment consultancy WSP. The audits reviewed ways to lower emissions and reduce exposure of London’s primary school children to nitrogen dioxide (NO2) and other pollution, including on their journeys to and from school.

The 50 selected primary schools were chosen following an application process which asked eligible London Boroughs to use guide questions and a scoring matrix to select up to two eligible primary schools which they felt should receive air quality audits.

The GLA, working in partnership with TfL, then considered the submissions from eligible boroughs and confirmed schools selected for an audit within four weeks of the deadline for applications.

School eligibility was determined by the NO2 annual averages per school using data from LAEI 2013. To select the top five schools per borough, schools with annual mean NO2 concentrations 40ug/m3 were considered, factoring in exposure by considering maximum number of pupils per school in each borough separately.

The audits identified the most effective local solutions to improve air quality and reduce exposure by understanding the travel behaviour of parents/carers, children, staff and other suppliers/services visiting the school and assessing the quality and accessibility of the physical environment surrounding the school. Examples of solutions identified by the audit recommendations included running active travel promotion and ‘no engine-idling’ campaigns around the schools, installing green infrastructure, for example trees to ‘shield’ walking routes or more significant changes to road layouts or road closures near the schools. By engaging with the borough and school community, the audits also increased awareness about local air pollution and made recommendations for changing behaviour.

The audits have been widely praised, including by the Government’s Chief Medical Adviser. However, it is essential that the audit reports do not just “sit on a shelf” and a good cross section of the recommendations are implemented. In working with the boroughs and the selected primary schools to deliver the audit programme it has become clear that there is a lack of spare capacity and/or technical knowledge at both school and borough level to effectively implement the audit recommendations. Unless further support is offered, there is a real risk that the audit recommendations will not be taken forward.

Consequently, officers are recommending a three-pronged strategy to ensure that a good cross section of audit recommendations are taken forward. First, each of the selected 50 primary schools will receive a £10,000 starter grant to take forward some of the non-transport recommendations (following consultation and agreement by GLA officers). Since the audits were completed, the Mayor has announced the £10,000 ‘starter grant’ for each of the participating schools. More information about the Programme can be found here: /press-releases/mayoral/mayor-launches-air-quality-audits-and-1m-fund.

Second, WSP, the consultancy who completed the 50 primary school audits, will provide specialist technical advice to the primary schools and borough air quality and transport officers based on their audits to assist with assessing the feasibility of implementing the recommendations and prioritisation of the recommendations (See 1.9 below).

Third, a staff member or consultant will be appointed by the GLA to support to the 50 primary schools such as support with accessing-funding streams, assist with establishing school air quality audit implementation plans for the 50 audited primary schools and gather data on the implementation of the recommendations. The support offered will enhance (not substitute) the existing support provided by borough air quality and transport officers and increase the likelihood that a good cross section of the audit recommendations will be taken forward.

Officers acknowledge that section 9 of the GLA’s Contracts and Funding Code requires, where the expected value of a contract for services is between £10,000 and £150,000, that such services be procured competitively or called off from an accessible framework. Section 10 provides however, that an exemption from this requirement may be approved where the proposed contractor has had previous involvement in a project/programme or is to continue existing work, which cannot be separated from the new project/programme work. Officers propose that WSP are contracted to undertake the additional consultancy work to provide specialist technical knowledge, assist with assessing the feasibility of implementing the recommendations and prioritisation of the recommendations. As WSP completed the 50 primary school audits, this represents work that cannot be separated from the recent work they have provided.

The staff member selected to support the 50 primary schools will be a Grade 8 or external consultant appointed on a fixed term contract for 12 months. The post will be appointed as soon as possible, subject to the fulfilment of the usual STAF process and associated appointment processes. The cost for this is estimated to be £55,000 (at midpoint Grade 8 salary scale and including on costs) for a year and will be covered by the 2018-19 Air Quality Programme Budget.

The City of London has been trialling new filtration systems at Sir John Cass Primary School. While not scientifically rigorous, initial assessment suggest a reduction in NO2 concentrations within the classroom of up to 50 per cent. This is worth investigating further so it is proposed that a filtration system trial is built into the new nursery audit programme and, where suitable, 5 sites will be identified for deployment of filtration systems.

Given the success of the Primary School Air Quality Audit Programme, the GLA is keen to expand this concept to other at-risk groups, namely children attending nurseries. Modelling will be undertaken to assess the exposure levels by children, attending nurseries, to NO2 and will include consideration of PM10, PM2.5 pollutants.

Analysis show that there are 80 state-funded local authority nurseries in London (listed at Appendix 1.). Detailed pilot air quality audits, which will include consideration of both indoor and outdoor air quality, will be undertaken for up to 20 nurseries as outlined in the Mayor’s announcement in May 2018. Feasibility assessments of the context and practicalities of installing a filtration system will be undertaken at up to 20 nurseries and installation, trial and monitoring of filtration systems in at least 5 of the nurseries, with particular consideration as to whether the technology is effective and should be rolled out more widely. The smallest children, those attending nurseries, are particularly vulnerable to air pollution exposure.

Building on the learning from the primary school audit concept already developed, the GLA wants to build in funding to implement recommendations from the outset, which is why £250,000 in funding is proposed for the nursery audits.

An indicative allocation of this funding is as follows (remembering that the GLA will be evaluating the value for money represented by all received bids):

• £200,000: £10,000 for each of the 20 nurseries to cover the audit cost and then to provide a ‘starter grant’ to enable some of the recommendations to be implemented.
• £50,000: to enable the installation, trial and monitoring of filtration systems at least 5 suitable nurseries.

The use of the term ‘nurseries’, include

• Maintained Nursery Schools (MNS), i.e. those registered with Ofsted as schools and as early years providers. These are “maintained” providers meaning state-funded but do not have higher classes (only early years, year 1, 2, etc). Often, they have provision for children under three years old as well as three and four-year-olds;
• nurseries attached to schools – provision for three and four-year-olds prior to reception class and state-funded;
• PVI group providers (Private, Voluntary and Independent sector), i.e., provision for children under five-years-old funded by a combination of government funding for free early education and parental contribution (fees).

The emphasis of the Programme will be on pinpointing what is contributing to the pollution within the nurseries and surrounding areas; and to work with the selected nurseries and the boroughs to implement solutions to reduce emissions/exposure and strengthen travel plans of these nurseries.

The cost of the consultant and associated works for the nurseries air quality audit programme will be £250,000 and is to be competitively procured and financed through the air quality programme budget.

The Mayor’s Primary School Air Quality Audit Programme

Objectives

• Support the 23 participating boroughs to ensure that the 50 implementation plans are established, actions are implemented and outcomes achieved. Set up funding arrangement for the GLA’s £10,000 offer to each of the selected primary schools;
• Monitor progress of the implementation plans and outcomes quarterly;
• Produce an annual report highlighting progress and outcomes; and
• Set up the GLA’s Air Quality Schools’ Forum that will see the selected 50 primary schools share knowledge and best practice, disseminate the toolkit to other schools and encourage efficiency savings through joint procurement ventures.

Expected Outcomes

• A number of the recommendations at and in each of the 50 primary schools implemented;
• A significant percentage of ‘other ‘primary schools using the toolkit; and
• At least two good practice case examples produced by the School’s Forum and showcased on the GLA’s website.

 The Mayor’s Nurseries Air Quality Audit Programme

Objectives

• To audit and identify the sources of poor outdoor air quality and exposure by children at state-funded nurseries at up to 20 nursery sites and their surrounding catchment areas;
• To audit and identify the sources of poor indoor air quality and potential exposure by children attending nurseries at up to 20 nursery sites. This will include establishing a baseline of indoor air quality at the selected nurseries;
• To assess the context of and feasibility for installing filtration systems at the selected nurseries’ sites;
• To install, trial and monitor the effectiveness of filtration systems in at least 5 of the nurseries’ sites, following approval by the nurseries and PAG;
• To identify, evaluate and recommend measures within and around the nurseries’ sites that will help a borough to reduce particulate matter and emissions and children’s exposure to poor air quality, which could be delivered as part of the boroughs’ LIP funding schemes, in the case of state-funded nurseries;
• Engage school communities (children’s parents/carers/governors and ward councillors). This will a) include an introduction to Transport for London’s (TfL) STARS (Sustainable Travel: Active, Responsible, Safe) travel plan at selected nurseries, where they are not already engaging in this initiative; and, the Greater London Authority’s (GLA’s) Healthy Early Years London Programme by raising awareness about the impacts of air pollution;
• Engage eligible London boroughs and other relevant stakeholders to inform the context and feasibility of the proposed recommendations. (Funding is already included as part of the delivery plan at each nursery); and
• Provide recommendations and, where applicable, draft design options and costings for the boroughs’ consideration and future implementation.

Produce three groups of reports

• An overarching project report at the completion of the audits and filtration system trials;
• Separate reports setting out the audit findings for the selected nurseries;
• A single report on the installation, trial and monitoring of filtration systems in at least five of the nurseries, with consideration as to whether the technology was effective and should be rolled out more widely; and
• Produce a toolkit that can be rolled out to all non-participating nurseries.

Expected Outcomes

• The nurseries and wider school community at all audited nurseries will be better informed about and engaged on air quality issues in their local areas;
• There will be a greater understanding of the potential health risks of exposure to poor air quality both outdoor and indoor and the best ways to reduce exposure by children attending the selected nurseries as well as how parents, carers and guardians can reduce their own contribution to poor air quality;
• Participating boroughs will support the nurseries to adopt and implement the recommendations detailed in the audit reports;
• Opportunities will have been created to reduce levels of exposure to NO2, PM2.5 and PM10 for children attending the nurseries and on their journey to and from school at the audited nurseries;
• Participating boroughs and nurseries will share best practice with all boroughs and schools in London, using the toolkit that will be produced as part of the programme by sharing their achievements via TfL’s STARS Programme, the GLA’s Healthy Early Years London Programme and by presenting at appropriate forums such as the GLA’s Air Quality Schools’ Forum and other events etc;
• Boroughs and other relevant stakeholders will adopt and roll out the audit programme to other nurseries /boroughs. Boroughs will actively encourage the use of LIP funding to improve air quality in the case of state-funded nurseries; and
• Nurseries and boroughs will use the funding opportunities provided by the GLA to support the implementation of the recommendations.

Both Programmes

Objectives

• Establish the recruitment and selection process to appoint an officer or external consultant to support to the 50 primary schools such as support with accessing-funding streams, assisting with establishing school air quality audit implementation plans for the 50 audited primary schools and gathering data on the implementation of the recommendations.

Expected Outcome

• An officer is in place to start in time for when the Mayor’s Nursery Audit Programme goes ‘live’.

The GLA has published an analysis on exposure to air pollution undertaken by Aether which shows that not only are there huge health impacts of pollution but the way these fall on the most vulnerable means that improving air quality is fundamentally about tackling social injustice.

The updated report considers pollution exposure in London in 2013 and considers how exposure varies by age, indicators of relative deprivation and ethnic groups in London. It also looks at total exposure (broken down by borough) and exposure at schools. Through the research described in this report, City Hall is seeking to understand inequalities in access to clean air in London and to consider how this will be improved by planned air pollution controls.

The research shows on average that the most deprived tenth of the population are exposed to concentrations of NO2 which are 25 per cent higher than the least deprived tenth of the population. It is important to note that hidden within this you also have pockets of extreme wealth with very high levels of exposure, e.g. those living in Westminster or in the Royal Borough of Kensington and Chelsea.

In terms of ethnicity, whereas there is a normal distribution of exposure for ‘white’ people, the pattern shows increasing exposure in areas that have higher percentage of non-white ethnic groups, with a particularly skewed distribution for the Black/African/Caribbean/Black British population. A greater proportion of mixed, black and other ethnic groups are exposed to levels of pollution that exceed the NO2 limit value than their proportion of the total population.

For schools, in 2013, there were 802 educational institutions serving young people which exceeded legal NO2 limits, of which 360 were state primary schools and 78 were state secondary schools. Note: In the previous study published in 2010 it was found that, there were 1777 primary schools in London of which 433 were in locations where average concentrations exceed the NO2 EU limit value. Of these 433 primary schools, 82 per cent were deprived schools. By contrast, of the 1344 primary schools that were not exposed to above EU limit values of NO2, 39 per cent were deprived.

The design of the policies set out in this MD will benefit all Londoners, but due to the unequal impacts of pollution on the most vulnerable Londoners there is likely to be a positive effect in tackling social and health inequality of this programme of activity.

Impact assessment

A comprehensive Integrated Impact Assessment was undertaken to support the London Environment Strategy (LES) which covered air quality, including proposed action at schools and nurseries. The Integrated Impact Assessment (IIA) found that the GLA had considered aspects for improving London’s air quality based on four policy options. This was recognised in the LES IIA as the most effective approach for addressing human health impacts. The LES includes targets for some of the pollutants identified in the IIA recommendations. The GLA agreed that it would look to include specific interventions to improve air quality around schools, hospitals and care homes.

Links to Mayoral Strategies

The London Environment Strategy includes Proposal 4.1.1.b which states:

“The Mayor will aim to do more to protect London’s young and disadvantaged people by reducing their exposure to poor air quality, including at schools, nurseries, other educational establishments, care homes, and hospitals.”

The strategy explicitly recognises that reducing the exposure of young people to pollution is a priority because younger children are among the most vulnerable to its health impacts. Eight and nine-year-olds living in cities with high levels of fumes from diesel cars have up to ten per cent less lung capacity than normal.

This programme is in conformity with and takes forward the commitment set down in the London Environment Strategy.

Mayoral approval is sought for expenditure of £830,000 on the Mayor’s primary schools and nurseries air quality audit programmes. The spend is broken down as follows:

• £500,000 as provision of a £10,000 each ‘starter grant’ to the 50 audited primary schools;
• £250,000 on consultancy services required for the delivery a new nursery air quality audit programme at 19 nurseries, including funding for targeted interventions at each nursery as well as the trial of filtration systems at appropriate sites;
• £25,000 on the continued services of WSP to provide ongoing consultancy support in relation to the implementation of the recommendations from the audited primary schools (contracted via a single source justification); and
• £55,000 to cover the cost of a full-time fixed-term Grade 8 staff member or external consultant for a year to manage the consultancy support set out above and deliver ongoing support to the 50 audited primary schools and 19 audited nurseries to ensure that the proposed recommendations are taken forward.

The cost of this programme is to be funded from Environment team’s 2018-19 Air Quality budget.

The foregoing sections of this report indicate that the activity in respect of which approval is sought may be considered to be facilitative of and conducive to the exercise of the GLA’s general powers to undertake such activity as may be considered to promote the improvement of the environment in Greater London and have complied with the GLA’s related statutory duties to:

(a) pay due regard to the principle that there should be equality of opportunity for all people;

(b) consider how the proposals will promote the improvement of health of persons, health inequalities between persons and to contribute towards the achievement of sustainable development in the United Kingdom; and

(c) consult with appropriate bodies.

Subject always to section 6.3 below, concerning the proposed expenditure on further services from WSP, to the extent that expenditure:

(a) amounts to the provision of grant funding as a contribution to related third party
project costs and not a payment for services to be provided, officers must ensure that the proposed funding is disbursed in a fair and transparent manner in accordance with the GLA’s Contracts and Funding Code and a funding agreement is put in place between and executed by the GLA and any proposed recipient(s) before any commitment to provide the funding is made; and

(b) is to be incurred on the procurement of works, services or supplies, officers must ensure that the works, services or supplies are procured in accordance with the GLA’s Contracts and Funding Code and that appropriate contract documentation is put in place and executed by the successful bidder(s) and the GLA before the commencement of any works, services or supplies.

Section 9 of the GLA Contracts and Funding Code (the ‘Code’) requires the GLA to call off the services required from an accessible framework or conduct a competitive procurement exercise for the same. The Mayor may however, approve an exemption from this requirement under section 10 of the Code upon certain specified grounds. One of those grounds is that an exemption may be approved where the proposed contractor has had previous involvement in a specific current project or the work is continuation of existing work that cannot be separated from the new project/work. Officers have indicated at section 1 of this report that this ground applies. The Mayor may therefore, approve the exemption proposed if satisfied with the supporting content of this report. Should the Mayor be minded to approve the exemption proposed officers must ensure that appropriate contract documentation is put in place and executed by the GLA and WSP before the commencement of the additional services.

Officers must comply fully with all GLA HR/Head of Paid Service protocols in respect of any staffing proposals, in particular the need to gain all necessary approvals for the creation of new posts.

In taking the decisions requested, the mayor must have due regard to the Public Sector Equality Duty; namely the need to eliminate discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010, and to advance equality of opportunity and foster good relations between persons who share a relevant protected characteristic (race, disability, gender, age, sexual orientation, religion or belief, pregnancy and maternity and gender reassignment) and persons who do not share it (section 149 of the Equality Act 2010). To this end, the mayor should have particular regard to section 3 (above) of this report.

Appendix 1:

The following 80 state-funded local authority nurseries have been identified using Edubase