Glasgow City Council currently has its draft Air Quality Action Plan out for public consultation till Wednesday March 20th. You can access it via this link
The action plan contains 7 key priorities and 18 actions, many of which we’ve been helping to push over the years including improvements to monitoring, transport, neighbourhoods, energy, and more. We welcome the action plan however, we’ve also provided the below responses that we feel will help to strengthen the current draft.
If you agree - please feel free to submit all or some of the below as part of your response to questions 4 and 6 in the consultation:
4. Do you agree that the seven key priority actions identified within the AQAP are the main actions in respect of reducing air pollution levels within the City Centre Air Quality Management Area?
Yes however, I wish the following points to be considered for inclusion within the AQAP.
On targets, Glasgow City Council should be clear that there is no acceptable level of air pollution. While recognising that the current Scottish legislative framework sets specific targets for different pollutants, the Council should go further than this statutory minimum standard and expressly set the World Health Organisation’s guidelines as our target. Glasgow has the most polluted air in Scotland so we need to have the most ambitious targets. There should therefore be an additional measure for Council officers to undertake an analysis of what policy interventions would be needed in order to hit the WHO guidelines; this will allow councillors to make informed decisions on what we need to do to deliver clean air. It is not enough for the Council to ‘take cognisance’ of the World Health Organisation; we must follow the science and deliver clean air for all in Glasgow.
GCC should also work with other local authorities and partner organisations to lobby the Scottish Government so that the next version of its Cleaner Air for Scotland strategy adopts the WHO guidelines, and delivers the powers, resources and political leadership to deliver those targets.
On monitoring, while a review of air quality monitoring with a focus on priority sites is welcome, that review must be followed by action. Schools, hospitals and care homes are not the only sites with high numbers of the people most vulnerable to ill health as a result of air pollution. The scope of the priority sites should be extended to include all educational and healthcare settings, for example, covering nurseries and childcare settings, hospices, and health centres.
Each such priority site should have a diffusion tube passive monitor placed on the grounds or on the perimeter, with more detailed monitoring arrangements to be introduced at the most polluted sites. While recognising the limits of the current statutory framework, the Council should adopt its own advisory targets for pollutant levels at these sites, with an aim of WHO guideline compliance with interim targets, timelines for delivery and regular reporting.
The review should consider the potential for the Council to work with other organisations in the city also working on air quality to develop as broad a monitoring network as possible and to help inform the deployment of the Council’s own monitoring.
On transport, it is not going to be possible to meet both climate and air quality objectives without radically transforming the way people move in and around Glasgow. The Glasgow Transport Strategy must be delivered in full and as quickly as possible, including but not limited to the Clyde Metro public transport network, the City Network of widespread and integrated active travel infrastructure, the reform of Glasgow’s bus network through the Glasgow Bus Partnership, and the implementation of low-traffic neighbourhoods and 20-minute communities through the Liveable Neighbourhoods programme. In particular, the Council ought to work with SPT, the Glasgow City Region, transport operators and the Scottish Government to prioritise funding to deliver bus priority corridors on major routes in and out of Glasgow, building on the initial feasibility work carried out by the council. Space on Glasgow’s streets must be reallocated away from private cars and towards public transport and active travel, with specific plans for the transformation of the city-centre stretch of the M8 and the reprofiling of other major road infrastructure such as the Clydeside Expressway and Shieldhall Overpass.
On schools, while Measure 7 to “Establish a pilot example school for the promotion of good air quality and travel practices” is welcome, the Council must go much further than this to ensure clean air around Glasgow’s schools, given the comprehensive body of evidence showing children and young people are more at risk from air pollution. Following any pilot, good air quality and travel practices must be rolled out across every school in Glasgow, with a clear timetable to deliver this. These measures must be developed and implemented through quality, respectful communication and engagement between the Council, parents, young people, teachers and other key stakeholders working on air quality around schools, like the Glasgow City Parents Group and Parents for Future. The Council should also consider working with external organisations who are already doing quality work to learn from their expertise, and adopt and support delivery of their programmes.
While the commitments from the Administration to re-establish a version of the last session’s School Streets Governance Group is welcome, the AQAP should include a specific measure to maintain such a group as a permanent standing group of the Council to consider school transport which brings together Education officers, NRS officers including from the Transport and Parking teams, councillors, education professionals, young people, parents and carers, police and other key stakeholders, like the Glasgow City Parents Group, Parents for Future, Sustrans and Bikeability. As a minimum, this group should: consider ways to more effectively enforce the current School Streets programme; support education, communication and engagement with staff, young people. parents and carers to promote compliance with School Streets compliance; support schools to develop and deliver revised School Travel Plans, covering staff as well as learners; promote active travel infrastructure in and around schools, including bike provision, bike storage, appropriate clothing and more; work with Bikeability to drive up uptake rates of cycling training and education; support the expansion of bike bus and walking bus schemes, where appropriate; and develop innovative new approaches to promoting sustainable transport options.
On freight, the Freight and Delivery Management action from Appendix B must be included as part of the AQAP. While noting the work on freight in the City Centre Transport Plan, reducing reliance on heavy goods vehicles in favour of greener freight alternatives must take place across the full GCC area. A network of freight hubs, introduced following meaningful engagement with local communities, must be completed with the expansion of existing cycle hire schemes with cargo bike and cargo e-bike options.
On heat, the Domestic Solid Fuel Burning action from Appendix B must be included as part of the AQAP. While domestic solid fuel burning may not be a significant contributor to city centre air pollution, there will be higher rates of such burning elsewhere in the city and we cannot decide to exclude this from the AQAP before we have gathered that evidence on the city-wide impact. The Council should deliver improved education and awareness raising on domestic heat options, for example including signposting information on pro forma communications in planning and licensing cases. The Council should also work with other councils to review the effectiveness of current legislation and regulation on Smoke Control Areas, and to use this review to inform subsequent national reforms.
On trees, the Council must significantly increase the scale of new tree-planting as outlined as the ambition within the Council Tree Plan, particularly street trees, in order to meet climate, biodiversity and air quality targets. Trees, shrubs and other forms of plant-life can sequester carbon, support nature, improve air quality, promote wellbeing and improve the appearance of our streets, as outlined in the current draft Forestry and Woodland strategy. The AQAP should note the ongoing officer-led review of how we deliver street trees and the recent Budget commitment to reinvest Low Emission Zone penalty income into street trees.
On planning and licensing, the Council must take a strategic approach to our planning and licensing systems to achieve social and environmental benefits, including air quality. The AQAP should reflect this and ensure that the upcoming City Development Plan 2 does not support developments which would have an adverse impact on air quality, such as drive-through retail and hospitality sites which promote engine idling. When consent is sought for development, construction or other related work, e.g. roadworks and work on underground utilities, provision must be made to ensure air quality is not negatively impacted; this could include mandating large developments and roadworks to conduct air quality monitoring to identify potential problems and deploy infrastructure such as low emission energy generators, and ensuring that active travel diversions are prioritised when access would be blocked through construction work. The AQAP should also include an action for the Council to review its current licensing schemes and similar, e.g. the Glasgow Film Charter, to identify opportunities for the promotion of clean air, e.g. phasing out the use of the most polluting diesel generators in favour of cleaner options, potentially through a council-facilitated hire scheme.
On powers, the Air Quality Action Plan should adopt an additional measure which notes the work recently agreed in the 2024-27 Budget to establish a new team in the Chief Executive’s Department to develop and deliver new powers, policies and interventions with a view to income generation, and recognises that many of these powers will also be essential to delivering cleaner air and so should be developed with air quality improvement as an important consideration. For instance, a workplace parking levy and road user charging scheme and their proceeds could all be transformative in delivering the behaviour change and transport modal shift required to reduce the number of private vehicles on Glasgow’s roads. This new team, while doing its detailed consideration of legislative and regulatory frameworks, should consider other potential opportunities for new interventions to be created and implemented and keep relevant committees updated on its work and potential for additional non-financial benefits. Such interventions, such as making engine idling enforcement more effective, may require legislative or regulatory change and so the Council should work with partner organisations and the Scottish Government where necessary to deliver.
6. Do you believe there are any actions, within the remit of Glasgow City Council to deliver, which should be included within the AQAP?
Green asks for additional or changes to actions in response to Question 6:
1. Targets
a) Lobby the Scottish Government to adopt the World Health Organisation’s guidelines as their statutory targets for air quality in the next national review, and to provide the resources, powers and political leadership to deliver
b) GCC to adopt WHO targets, over and above the ScotGov statutory targets, and officers to develop a routemap to show what we would need to do to hit WHO targets
2. Monitoring
a) Expand current wording to “review monitoring especially around education and healthcare settings and other settings with high proportions of the most vulnerable people" to capture nurseries and health centres etc.
b) Include a review of indoor air quality particularly within settings outlined as high risk - education and healthcare settings and investigate possible interventions to improve.
c) A specific actual action to follow the review, eg ensure each site has monitoring in a set range, work with other partners in the city who are already monitoring to share data, look at introducing our own non-statutory targets for those priority sites
3. Transport
a) Expand upon the Glasgow Transport Strategy action point by highlighting key components of strategy as well as the City Network Delivery Plan
b) Support work being taken forward to reduce the impact of the M8 as well as future potential of other major road infrastructure such as Clydeside Expressway and Shieldhall Overpass
4. Powers
a) Build on ongoing work and ensure that air quality is key component when seeking to develop new powers and deliver new interventions to reduce private car usage, e.g. workplace parking levy, congestion charging
5. Schools
a) Expand pilot school action to find a pilot then plan to expand that to all schools, with aim for all to meet set standards, e.g. WHO standards or Clean Air for Schools framework
b) Have an AQAP underpinning for a school transport governance group
c) Look at expanding on the Schools Streets programme so all schools and nurseries in the city have as much of the School Streets intervention as possible, depending on the site
6. Planning and licensing.
a) Set new conditions on eg construction to have their own site monitoring and mitigation measures
b) Support Sustainable Events Strategy to bring in new conditions on event and film operators to minimise pollution, limit use of diesel generators etc.
c) Use the new Local Development Plan to deliver the aims of the AQAP, e.g. build on/embed drive-thru statutory guidance
7. Trees
a) Meet objectives of Council Tree Plan, with a specific focus on codifying how we implement more street trees as well as support the delivery of the upcoming Forestry and Woodland strategy
b) Use air data to help inform where street trees go - e.g. more polluted streets = more trees
8. Freight
a) Build on Circular Economy Plan actions on freight, potentially develop plan for network of freight hubs to minimise HGV use but with clear community buy-in, integrate with a cargobike hire scheme
9.Domestic solid fuel burning
a) Move the actions from the excluded list into the measures
b) Education and awareness raising on eg woodburners and better alternatives
c) Work with other councils to review effectiveness of Smoke Control Areas and work with SG to reform
Please feel free to share any thoughts or questions by reaching out to Green Cllr. Lana Reid-McConnell.