EIR - Air Quality Management & Annual Status Reports [Mar 2024]

Your request 

1. Please could you copy me the link to the Statutory Guidance for Local Authorities in London, regarding Air Quality management and measurement, if there is any. Or to the non statutory guidance if there is none.
2. If not outlined in the guidance above, please could you advise what the route of action is for Lambeth residents, to press for their LA to produce the overdue AQ report. Or confirm whether this is the role of the GLA, and if so, whether the GLA have done so already and provide details of this.
3. Please could you provide copies of any communications between the GLA and Lambeth concerning the overdue May 2023 AQ ASR and concerning AQ monitoring in Lambeth from 1.1.2020.
4. Could you confirm how many London Local Authorities have not yet provided the GLA with the ASR that was due in May 2023 and which LAs they are. Are there any consequences for LAs that do not perform this statutory duty, and if so could you confirm whether there has been for Lambeth Council.
5. Lambeth Council “sponsor” a number of Airly monitors throughout the borough. Could your department outline whether the GLA considers the contribution to AQ monitoring provided by such organisations as Airly and Breathe London sensors to be of a sufficient standard to be a liable/legitimate option for monitoring. Nb: At present a large number of Airly sensors are showing as offline "unplugged".
6. Who is the person and department at the GLA who oversees the Local Authority operations with regard to AQ monitoring and management? Please could you supply their name, department, address and contact email. What is the name, title and department of the person at Lambeth Council that the GLA liaises with in relation to AQ. I assume it is not the Cabinet Member for Clean Air - Ms Rezina Chowdhury, rather a more technical member of staff in the Lambeth Environmental team.
7. Please confirm whether the GLA expects to receive a Air Quality Annual Status Report (for 2023) from Lambeth Council in May 2024.

Our response

(1) The Mayor’s London Local Air Quality Management (LLAQM) framework is the statutory
process used by local authorities to review and improve air quality within their areas. The link to the statutory guidance for local authorities in London for LLAQM is found here: Working with the London boroughs | London City Hall

(2) Through the LLAQM, boroughs are required to submit a draft Annual Status Report (ASR) in May every year to the GLA. Lambeth submitted the ASR on the 1 June 2023. The GLA reviewed the ASR and provided feedback to Lambeth. As outlined in the LLQM framework, it is the responsibility of Lambeth to publish the final ASR.

If you feel that the council is not taking the appropriate action you can use the council’s
internal complaints procedures to escalate the matter internally or, ultimately, you can contact the Local Government Ombudsman who may be able to investigate further.

(3) Lambeth’s ASR was submitted 2 days after the deadline. As the ASR was not significantly late, no email communications were required to request Lambeth to submit the ASR.

Regarding AQ monitoring correspondence, from our preliminary assessment, we will not be able to answer your request in full without further clarification and we need further information in order to identify and locate the specific information you have asked for.

(4) Hillingdon is the only London borough which has yet to submit a draft ASR to the GLA for the 2023 reporting deadline. Officers have been in contact with Hillingdon to ensure they are aware of their statutory duties. The Mayor’s London Local Air Quality Management (LLAQM) framework is the statutory process used by local authorities to review and improve air quality within their areas, as outlined in the Environment Act (2021). Local Authorities who consistently do not meet the statutory duties risk receiving a Mayoral Direction.

Lambeth Council submitted their draft ASR on 1 June 2023, and therefore no further action is required from the GLA.

(5) Monitoring requirements required as part of the LLAQM are outlined in the LLAQM technical guidance found here: llaqm_technical_guidance_2019.pdf (london.gov.uk)

The measurements of air pollutants disseminated as part of the London Air Quality Network provides measurements which can reliably used to assess exposure, affect government policy and keep the public informed.

The Breathe London Network is run by the Environmental Research Group at Imperial College London - the same group who run the London Air Quality Network - and is funded by the Mayor of London. The Breathe London Network aims to offer affordable, easy-to-install and maintain air quality sensors to anyone to make air quality monitoring data accessible to citizens and community groups. However, it is important to note that these small sensors are not as accurate as reference-grade analysers used by the London Air Quality Network but are useful to support citizen science and for people to measure their own pollution exposure.

There are cheaper, less accurate methods of measuring some of the gaseous pollutants, such as nitrogen dioxide, using diffusion tubes. These cost only tens of pounds and each tube can be kept in place for a few weeks and then sent to a laboratory for analysis. However, each tube only provides an average concentration over a short period, which may not be representative of ‘typical’ conditions. There are specific procedures in place for the use of diffusion tubes to allow results to be compared to national air quality standards and results of monitoring carried out by local authorities: Air Quality Assessment | LAQM (defra.gov.uk)

(6) The Air Quality Team within the GLA work closely with boroughs on policies, programmes and statutory duties relating to air pollution. They can be contacted at [email protected]

To contact a member of the Lambeth environment team regarding air pollution, please email them at [email protected]

(7) The GLA expects to receive the draft ASR from all London boroughs in May 2024, as set out in the LLAQM framework.

Further information 

Regarding the content of the 2022 AQS report submitted to GLA by Lambeth Council in June 2023. Table 1.2 p17-23 of a (year by year) “Comparison of Monitoring Results with AQ Objectives” shows that much of the 2021 AQ findings data have been replaced with different (lower) readings in the 2022 report. There is no explanation that I can see, in this or the 2021 report, for the “switch” of these figures. Bias adjustment happens in the year in question, not a year later. No other/previous year’s data has changed, and some figures are unchanged. For example: the 2021 data (in the 2021 report page 15) showed the readings for Sites DT1, 2&3 to be 58.7. whereas the 2021 data (in the 2022 report page 18) shows this reading to be zero. Clearly an explanation for why so many of the 2021 readings have been changed/ lowered - would need to be in the report to account for this. The changes include results for receptors shown as exposed to annual mean concentrations above 60ugm3 in 2021 - now revised to show below that, for 2021.

Please could you:

1. Confirm that the amendment of the 2021 figures in the 2022 report was noticed when the 2022 AQ report was submitted to the GLA in June 2023.
2. Confirm whether the reasons for the retrospective change/lowering of many of the 2021 figures are/were clear to you and are technically valid.
3. Explain the reasons they have been changed and where/whether an adequate explanation is given in the 2022 report.

Our response

1. The GLA approves the Annual Status Reports, focussing on the latest year of data and the actions taken to improve air quality. The GLA approved the 2021 ASR
2. The GLA does not appraise the preceding years of data as part of the LLLAQM ASR process.
3. London boroughs are responsible for monitoring and reporting on their air quality data on an annual basis in line with the London Local Air Quality Management (LLAQM) guidance.