The recent calls from motoring and freight bodies for the Government to bring greater consistency regarding clean air zones (CAZ) are welcome and timely (‘DfT urged to sort out ‘mess’ of emission-based traffic zones’ LTT 24 Jan). However, it’s important to recognise that local authorities are often operating with one hand tied behind their back – shaping business cases and solutions without sufficient clarity and guidance from central government.
There’s a lot at stake. Central and local government need to set up CAZ projects for success. This calls for a consistent framework – from outline business case to roll-out – in order to deliver the improved environmental and societal outcomes our cities need.
We need Government to take an active programme management approach, similar to the roll-out of major infrastructure programmes. There have been good intentions and an ambition to do this through the Joint Air Quality Unit (JAQU), but there remains greater scope for on-the-ground improvement. I know from personal experience of developing CAZ business cases for three local authorities that there are times when information is not consistent or forthcoming, impacting the ability to make informed decisions. Whilst collaboration is desired, engagement is only seen as an activity at a point in time.
I understand that the desire for a programme management approach doesn’t easily align with the different challenges and opportunities that councils face in developing CAZ models. However, there are five steps that an evolved Government-led programme management approach should consider.
Central government must better appreciate and recognise the funding and bidding dichotomy that councils face. The ability of councils to lever-in funding becomes a function of their capacity and capability to write a bid.
Step one is the creation of a culture of trust and collaboration. Trust is key on all successful programmes and needs to be rebuilt. The Government has not always been forthcoming with approving or declining outline business cases submitted by the second tranche of local authorities and this has undoubtedly affected programmes. Unfortunately, the process also hasn’t followed the Treasury’s Green Book guidance and therefore confidence has waned. Continuity of personnel has additionally been a hindrance, as some local authorities develop their business case working with multiple government account managers.
The second step is to learn lessons and evolve framework guidance. There’s an appreciation on all major programmes that lessons will be learnt and changes will need to implemented, but these need to be taken on board and reflected in up-to-date framework guidance. The reality is that the Clean Air Zone Framework guidance document has not been updated since May 2017 and no longer reflects the most up-to-date information, leaving councils that are new to schemes to face the same challenges as previous applicants.
Against the backdrop of a climate emergency, learnings must transcend CAZs too. Lessons from the CAZ framework should help inform central and local government’s approach to achieving net zero emissions. The Government must learn from this to identify better ways for local authorities to gain approvals for solutions, obtain funding and develop procurement routes to achieve their environmental goals.
The third point requires Government to fix the moving targets and deliver a level playing field. The CAZs’ main engine, the vehicle checker being developed by the Driver and Vehicle Licensing Agency (DVLA) has not been fully finalised and as such this will require changes to Birmingham and Leeds councils’ charging orders. This will mean additional work and cost for some local authorities as a result of the Government still developing its preferred solutions and guidance.
There are also too many grey areas where information on potential funds is either evolving or a specific scheme is not available in one part of the country. This refers particularly to the Clean Air Fund. I’ve seen instances where guidance is available for one council, and then for another there is a lack of clarity about specific aspects.
Inconsistency between the available schemes is also a challenge when assembling the business case. Why does London have a van scrappage scheme yet for other cities this isn’t always available?
That leads to the fourth point: central government must better appreciate and recognise the funding and bidding dichotomy that councils face. There are myriad funds available but all are generally bid and award-based. This means the ability of councils to lever-in funding becomes a function of their capacity and capability to write a bid. Put simply, councils without the resource lose out. Bidding is naturally a competitive process that inhibits information sharing and results in ‘wheel reinvention’ – a double whammy the sector cannot afford. For these reasons there is a need to understand whether a bid-based system ultimately works.
The fifth and final point requires the Government to be better informed about the sector’s capacity to deliver. Good programme management is about understanding the sector’s maturity, skillset and resource to deliver at a given time. This is not to put-off the challenge of delivering a CAZ and kick it into the long grass, but the programme needs to understand what resource is available to deliver. At feasibility study stage there are a limited number of air quality specialists in the market who know how to work with the Government and translate realtime air quality results into financial modelling. Equally there is a limited pool of business case writers with the ability to explain the environmental and social benefits of a CAZ, and specialists able to develop and agree a back office function that is aligned with the JAQU’s evolving guidelines.
We need central government to embrace the opportunity to do things differently with CAZs. A new way of working based on improved management is possible and will be key to setting up the programme for success.
Vinny Naga is an associate director at Turner & Townsend. She was the programme manager for Birmingham City Council’s CAZ feasibility study, leading on its business case submissions to JAQU. She is currently providing subject matter expert support to other local authorities on their CAZ programmes.
Find out more about clean air zones at Workplace Parking Levy and Clean Air Zones at The Council House, Nottingham, on 29 April
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