Freedom of Information
Four Freedom of Information questions and answers has confirmed that
IBC/SCC currently have no plan to reduce air pollution any time soon.
IBC raise £3m a year from car parking fees.
The air pollution reduction from the new IBC electric fleet is so negligible they don’t bother measuring it.
The CEO of IBC is not leading, and coordinating action to reduce air pollution as is required by government guidance and, again, confirms that IBC have no plans to address the main source of air pollution.
IBC has granted itself outline planning permission for a £7m car park without having done any business planning or taking into consideration whether it may become a stranded asset, and doesn’t respond to public questions or allow public scrutiny. IBC only produce a business case when about to place a contract but are unable to provide any example business cases.
Two new requests were sent to IBC and SCC on 1st February to better understand Suffolk County Council’s past and current interventions to reduce air pollution
1 This FoI confirms that IBC/SCC currently have no plan to reduce air pollution and that the impact of buying an electric fleet is so small they didn’t try to calculate it.
Freedom of Information Request to Ipswich Borough Council 22 November 2020 reference number FOI275429616
Question/Answer: IBC’s electric vehicle fleet are frequently quoted by IBC when asked about air pollution. Electric vehicles is positioned as a key intervention in the 2019-24 Air Quality Action Plan. I’d like to know;
1 Cost: Incremental cost of buying the electric vehicle fleet - when compared to purchasing the most economic petrol or diesel vehicle alternative. Answer: Information not held
2 Grants: Did IBC use any government grant to help pay for the new electric fleet? Answer: Ipswich Borough Council did not use any government grant to help pay for the new electric fleet.
3 PREDICTED IMPACT: The expected reduction in air pollution from using the electric fleet? Answer: Information not held
4 ACTUAL IMPACT: The actual reduction in air pollution observed so far from using the electric fleet? Answer: Information not held
Also, 5 What are the top 3 interventions planned and being implemented (ie those actions that will have most impact on air pollution) in Ipswich’s Air Quality Action Plan 2019/24? For each intervention; what’s the predicted impact on air pollution, when will the impact take effect, when is the impact being measured, what budget has been agreed? Answer: Information not held
2 This FoI confirms that IBC have a £3m income from providing car park spaces which provides a motivation to maintain and encourage vehicles in Ipswich rather than encourage the necessary vehicle reduction.
Freedom of Information request FOI214965386:
Questions
1 How many car parking spaces are owned by the council?
2 The income made from car parking for each of the last 5 years?
Answers
2015/15: Spaces 1576 Car park income £2,203,017
2016/17: Spaces 1646 Car park income £2,440,033
2017/18: Spaces 1746 Car park income £2,425,084
2018/19: Spaces 2259 Car park income £2,745,261
2019/20: Spaces 2259 Car park income £3,092,833
3 This confirms that the CEO of IBC is not leading, and coordinating action to reduce air pollution as is required by government guidance. It, again, confirms that IBC have no plans to address the main source of air pollution.
IFOI20201130 1 November 2020
In 2008 Ipswich declared Air Quality Management Areas and produced an Air Quality Action Plan. In 2020 Air Quality Management Areas remain and the 2020 annual status report (AQAP) is the latest incarnation
https://www.ipswich.gov.uk/sites/www.ipswich.gov.uk/files/asr_2020.pdf
All “section” quotes, below, in this Freedom of Information request relate to; Part IV of the Environment Act 1995 Local Air Quality Management Policy Guidance (PG16) April 2016
https://laqm.defra.gov.uk/documents/LAQM-PG16-April-16-v1.pdf
Question 1
Can you let me know the chair and members of the Steering Committee in its various forms since 2008, to date. In particular can you let me know the roles the IBC Chief Executive has played in these Steering Committees and how he has ensured that all parts of the local authority are working effectively together to tackle air pollution.
The following sections are relevant to this question.
· Section 2.14: As soon as an air quality issue has been identified it is recommended that a steering group is formed to include all the main parties involved in developing either Action Plans or Air Quality Strategies. It is recommended that the Chair is of sufficient seniority to ensure that the outputs from the group are being taken forward. Where significant action is required from a county council to resolve the air quality issues, it would be beneficial to have a senior county council representative as co-chair. Membership of the group could include the Environment Agency, Highways England and local businesses and interest groups. Once the strategies and Plans have been published, the steering group can be retained to monitor progress and troubleshoot if necessary, should difficulties in implementation arise. More information on the role of the steering group is provided in LAQM.TG16.
· Section 2.15: The public health impacts of poor air quality are well documented. We would expect the highest level of support from local authorities (e.g. Chief Executive and Council level) to ensure that all parts of a local authority are working effectively together. The public can be given further confidence that the work being taken forward to tackle air quality is supported at the highest level through engagement in and sign-off of.
Answer: Ian Blofield (Head of Housing and Community Services at Ipswich Borough Council) is usually the chair.
The current Chief Executive of Ipswich Borough Council, Russell Williams, does not sit on the steering group. The Council holds no further information relevant to your request.
Question 2
Given the serious and persistent nature of air pollution in Ipswich identified through AQMAs since 2008, why haven’t the actions taken by the local authorities reduced pollution in 12 years and when will a plan be produced, in line with government guidance, to reduce the pollution to legal and government target levels?
The following sections are relevant to this question.
· Section 5.1: …The Action Plan should take a practical approach towards focussing on what really matters – identifying the nature of the problem whilst detailing measures that are or will be actively implemented to improve air quality and quantifying their impact over time.
· Section 5.2: Action Plans should include the following: · Quantification of the source contributions (e.g. HGVs, buses, taxis etc.) responsible for the exceedance of the relevant objective. Knowing the source of the problem will allow the Action Plan measures to be effectively targeted; · Quantification of the impacts of the proposed measures – including, where feasible, data on emissions and concentrations (either locally obtained and/or via national monitoring/modelling statistics). It is important that the local authority shows how it intends to monitor and evaluate the effectiveness of the plan; · Clear timescales, including milestones and expected outcomes which the authority and other delivery partners propose to implement the measures within the Action Plan; and · How the local authority, including transport, planning and health departments, and other external delivery partners, will take ownership of the problem and in what capacity they will work together to implement the Action Plan.
· Section 5.3: Local Authorities should aim to produce their Action Plan within 12 months of an AQMA being declared.
Answer: The Council has an Air Quality Action Plan (AQAP) that has been appraised by DEFRA.
Question 3
Given that Ipswich AQAP should target the main sources of air pollution to maximise effectiveness (Reference Section 5.2, as quoted above) and that 80% of roadside NO2 concentration comes from road transport, why haven’t practical and effective interventions been planned and implemented for the last 12 years, and when will this happen?
The following sections are relevant to this question.
· Section 8.1: Road transport, in particular diesel vehicles for NO2, is the major source of roadside air pollution in the UK, as with other European countries. As such, transport should play a significant role in solving these problems and improving air quality and public health. It is estimated that road transport contributes 20-30% of national emissions, and 80% of roadside NO2 concentrations, where the UK is exceeding limits, are due to road transport.
· Section 8.5: A number of practical measures are available to local authorities to reduce levels of pollutants from vehicles, either directly or indirectly. These can basically be divided into three categories: a) Reducing traffic levels - e.g. through controls on the most polluting vehicles; behaviour change programmes to encourage travel alternatives and improved loading/occupancy of vehicles;
· Section 8.6: The most polluting vehicles can be discouraged through a number of interventions. The concept of Clean Air Zones was introduced in the Air quality plan for nitrogen dioxide (NO2) in the UK24 . The Clean Air Zone framework aims to provide a consistent approach to access controls.
· Section 8.7: Clean Air Zones are areas where only the cleanest vehicles are encouraged to operate to improve air quality. They are geographically defined areas allowing action and resources to be targeted to deliver the greatest health benefits. Local authorities can adopt Clean Air Zones as a way to focus their actions to improve air quality. There are different classes of Clean Air Zone. Each successive class includes more vehicle types to bring about a larger reduction in emissions. Vehicle owners will be required to pay a charge if they enter a zone and their vehicle does not meet the required emission standard. Local authorities may also wish to implement a Clean Air Zone operating on a voluntary basis (i.e. without charging). Such a Zone would raise public awareness and act as a focus for targeting additional action to improve air quality. Further detail is available in section 3.5 of the UK overview document of the Air quality plan for nitrogen dioxide (NO2) in the UK25 .
Answer: Information not held
4 This FoI confirms that IBC has granted itself outline planning permission for a £7m car park without having done any business planning or taking into considering whether it may become a stranded asset, and doesn’t respond to public questions or allow public scrutiny. IBC only produce a business case when about to place a contract but are unable to provide any example business cases.
FOI20200950
Question: Regarding a proposed IBC £7m multi storey car park - follow on from FOI223768269. Can you confirm that you have proceeded to outline planning application stage without any work being completed on a business case? If so, can you let me know why not, and when you are planning to create the pre-requisite business case to help protect the finances of my council and how that fits in with the planning process.
Answer: It is not necessary for the Council to produce a business case to support a new proposal when submitting a planning application. In this instance, Executive approval was given to the Operations Manager for Major Capital Schemes, following consultation with the Chief Executive, to submit a planning application for a multi-storey car park at Princes Street/ Portman Road (Paper E/18/69 refers).
Generally, and when seeking formal approval to proceed with any major scheme that the Council wishes to undertake, a business case (or similar) normally would form part of the officer report to the Council’s Executive Committee e.g. when seeking authority to place a contract for the works.
In terms of Portman Road Multi Storey Car Park, no officer report has been drafted seeking authority to proceed beyond the planning stage, therefore no specific business case has been provided at the time of writing.
Supplementary questions:
The IBC policy and guidance that ensures the production of consistent quality business cases for Major Capital Scheme investments.
Examples of business cases that have been produced in the past for Major Capital Scheme investments.
The response to my formally lodged objection to progressing the planning application, which concerned questions on how IBC was conforming to its own guidelines.
Answer: As previously advised, no specific business case has been produced to date and therefore officers are unable to assist you or comment further on this matter.
However, I can advise that risk management associated with any significant project is considered as part of the Executive process and duly explored within the relevant Executive report. Risks can be wide ranging i.e. not limited to air quality, and assessments are made as to the nature of risk, risk controls, the probability / impact of risks occurring and any actions necessary to mitigate such risks. Additionally, matters around environment impact assessment are also considered, together with, inter alia, equalities and diversity implications, legal and financial considerations. Accordingly, Executive decisions to proceed (or otherwise) are taken having had regard to a wide range of relevant considerations.
5 Question posed on 1st February 2021 to Ipswich Borough Council
The Environment Act 1995 provides SCC with a statutory responsibility to constructively engage with IBC to produce a combined IBC/SCC Ipswich Air Quality Action Plan to reduce air pollution to legal and government target levels.
Technical Guidance (TG16) February 2018 Section 3.9: Where [IBC] is preparing an Action Plan, [SCC] are obliged under section 86(3) to submit measures related to their functions (i.e. local transport, highways and public health) to help meet air quality objectives in their local area. Under section 3.1 of the Air Quality (England) Regulations 2000, submission of these proposals should take place within at the latest nine months of first being consulted on the Action Plan by [IBC]. Earlier responses from [SCC] are encouraged in order not to delay the completion of the Action Planning process
In 2008 IBC identified illegal air pollution in Ipswich but after 13 years air pollution remains illegally high.
Questions;
Over the last 13 years what measures from SCC have you submitted into the IBC/SCC Air Quality Action Plan?
What was the predicted impact of each of these measures and what was measured in practice?
Are there any measures currently being implemented and if so, what are they, when were they implemented and what was the predicted impact on air pollution?
Given that SCC has 9 months to provide suitable measures, what actions over these 13 years have IBC taken to lobby and then compel – for instance engaging with Her Majesty’s Government Minister - as written in the Act and Guidance?
6 Question posed on 1st February 2021 to Suffolk County Council
The Environment Act 1995 provides SCC with a statutory responsibility to constructively engage with IBC to produce a combined IBC/SCC Ipswich Air Quality Action Plan to reduce air pollution to legal and government target levels.
Technical Guidance (TG16) February 2018 Section 3.9: Where [IBC] is preparing an Action Plan, [SCC] are obliged under section 86(3) to submit measures related to their functions (i.e. local transport, highways and public health) to help meet air quality objectives in their local area. Under section 3.1 of the Air Quality (England) Regulations 2000, submission of these proposals should take place within at the latest nine months of first being consulted on the Action Plan by [IBC]. Earlier responses from [SCC] are encouraged in order not to delay the completion of the Action Planning process
In 2008 IBC identified illegal air pollution in Ipswich but after 13 years air pollution remains illegally high.
Questions;
Over the last 13 years what measures have you submitted into the IBC/SCC Air Quality Action Plan?
What was the predicted impact of each of these measures and what was measured in practice?
Are there any measures currently being implemented and if so, what are they, when were they implemented and what was the predicted impact on air pollution?