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Page 1: SUAQ Modelling and Monitoring working group – final report…  · Web viewLocal emission ANPR ... Note that the SESTRAN regional model currently used in Edinburgh to predict impacts

Colin Gillespie August 2015

SUAQ Modelling and Monitoring working groupFinal Report

Colin Gillespie

Scottish Environment Protection Agency

[email protected]

RecommendationsA number of key recommendations were identified by Modelling and Monitoring Working Group (MAMWG) members.

# Recommendation Suggested Delivery Methodology

1 Engage with specialist consultants in modelling to validate or peer-review the proposed process.

Proposed to have an independent review of the Aberdeen process, the model performance, data analysis and testing tools.

2 Peer-review modelling criteria for LEZ An independent peer review will be undertaken of the criteria, including data collection process.

3 Identify appropriate funding for delivery of the modelling criteria of the LES

Discussions with Scottish Government will continue to establish a national fund for delivering modelling framework.

4 Develop a timescale for committing to LEZs or develop a delivery plan/programme where an LEZ is in place.

Set out a delivery plan from the data of LES adoption that follows:

2 years for data collection across the 4 major cities

3 years for the first timing of an LEZ

3-4 years for the identification and data collection of addition cities/towns

5 The regional model has to be kept up to date on a regular basis.

Develop a central role and a central repository for the traffic data and model outputs and planning developments. This approach would reduce potential error and overall cost, and allow for both national emission factors to be kept up to date on a regular basis and national data input for maintaining model performance.

6 The roles and responsibilities should be set out within the LES.

The SUAQSG have been discussing the potential governance of the LES, this has still to be agreed, with the potential for a TAG.

Table 1 – Key LES Recommendations

IntroductionAt the SUAQSG meeting in December 2014, a series of 6 MAMWG progress meetings were planned for 2015. During late 2014, the MAMWG was identified as 1 of 6 short life working groups required to

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provide input to the Low Emission Strategy for Scotland. Prospective members of the MAMWG were identified following a poster invitation at the STEP Annual Conference in November 2014, and a series of further invitations were provided to key contacts identified by members.

ContributersFour key meetings were held between February 2015 and April 2015, defining the purpose and remit of the group, collecting the evidence, developing recommendations for Modelling and Monitoring as set out within the Low Emission Strategy for Scotland, and the prepare the outline for this draft final report. Meeting five held during July finalise the report from the group, whilst providing the group with the opportunity to agree the proposed Framework and proposed Actions. A further meeting is planned to be held in late August / early September to allow members to discuss the proposed framework and actions in the report. Table 2 below lists the MAMWG members and attendance to date.

Name Organisation 1 2 3 4 5 6

Colin Gillespie (Chair) SEPA X X X X X

Dom Callaghan Glasgow City Council X X X X X

Jackie Hyland NHS X X X X

Stefan Reis CEH X X X X X

Aileen Brodie Aberdeen City Council X X X X X

Alan Hills SEPA X X X X X

Jonathan Flitney Falkirk Council X X X X X

Drew Hill Transport Scotland X X X X X

Lyn Farmer Aberdeenshire Council X X

Shona Clarke City of Edinburgh Council X X X X X

Marian Scott GlasgowUniversity X X X X

Margaret Bell Newcastle University X X X X

Eleanor Pratt SEPA / Transport Scotland X X

Vincent McInally City of Glasgow Council X X X

Iain Beverland* Strathclyde University X

Claire Reid* East Renfrewshire Council

Derek McCreadie* City of York

Sally Jones* Bradford City Council

* Corresponding members

Remit of the Group

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At the first meeting of the MAMWG members were informed of the SUAQWG process and the on-going work on the draft Low Emission Strategy for Scotland (LES) (issued for consultation during 16 January to 10 April 2015, and due to be updated during the life of group). During the initial meeting the following objectives for the group were defined and agreed.

Provide comment on the LES consultation document and to provide guidance on how to progress the LES further towards its publication, providing suggestions on appropriate Actions in the LES.

Support the delivery of the LES actions, and provide input on the same to the SUAQ steering group (who provide leadership and coordination), and any future LES Delivery Group.

Provide suggestions on how to build a collaborative community to support the delivery of the Modelling and Monitoring actions within the LES (following the publication of the final document in late 2015).

Following the first meeting, and a discussion of Modelling and Monitoring within the LES, the key elements noted in Table 3 below were agreed as a focus for suggestions and recommendations from the MAMWG. The remit of the MAMWG was communicated to each of the contributors.

Task Detail

National Modelling Framework procedure

A clear, consistent national approach will need to be developed to assist local authorities to assess AQ issues across LA boundaries and to determine the need for LEZ’s. This will be delivered by a two tier modelling approach, at a national and local scale, to assess AQ issues across regional boundaries, and within AQMAs respectively. This advice should consider the spatial and temporal relationship of these two levels of modelling, and how they connect to each other to ensure that the aim of the LES is delivered – what should the modelling framework and assessment procedure involve and what areas should it cover from the national to local scales?

Guidance Provide background to the guidance required for the implementation of the national Modelling Framework. This should include background on data requirements, including suggestions on how the data could be collected, and what the modelling outputs look like for interactive assessment tools.

Role & Responsibilities

Suggest which elements of the National Modelling Framework should be mandatory and which should be voluntary, with views on how the data and modelling process should be implemented?

Actions There will be a series of actions that will be required to develop and deliver the national modelling approach. Comment on the draft LES Modelling and Monitoring actions, appraise the detail of these, and provide recommendations on a programme to develop a national modelling and monitoring approach to drive an affective assessment process.

Existing work Appraise SEPA’s pilot modelling project in Aberdeen (to be peer reviewed via an independent reviewer), provide support to the LES Sniffer work, the SEPA’s SUAQD Development Project, and the NTDS.

Review of LES National Modelling Framework section

Table 4 below provides specific suggested rewording and commentary relating to the current LES actions 3a to 3c listed in Section 3 – Establishing a national Low Emission Zone Framework (Communications Section) of the Draft Low Emission Strategy for Scotland (LES).The bullet points

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summarise the main points raised by the contributors. Where applicable, action rewording is also proposed, with green highlighting the text which is OK and red highlighting where the words for an action need attention/altered. It was by the MAMWG members that the actions need to link to the other groups to ensure that we are delivering across the strategy to ensure that actions associated with other working groups do not potentially result in a negative outcome for any individual group.

Current action wording Proposed new action wording (delivery date)

3a A national air quality modelling methodology will be developed.

Design, develop and implement a 2 tier modelling system for different spatial scales (regional and local) to provide evidence for appraising air quality and potential LEZ areas.

General comments: Need to tighten up action 3a as proposed, and provide words in the supporting text

(or case study) to reflect existing projects such as the Aberdeen pilot project and the Dutch national AQ model. This will support potentially new projects associated with the regional approach.

Need to expand on the wording within the strategy to capture both the regional and local approach within the framework.

Need to evaluate the feasibility of a regional model and then support its development over a 2 year timescale.

Members agreed that there is a value on standardising the approach taken across Scotland, to reduce discrepancies that are included in other assessment processes that are not consistent in their approach.

Need to consider (for the delivery programme) who should lead on developing, operating, and improving the systems, although the group did agree that the centrally led approach would maintain consistency in collecting data and in developing the modelling approach.

In terms of delivery period to full establishment, the group suggested a two year period for modelling the main LEZ candidate cities such as Glasgow, Edinburgh and Dundee, with Aberdeen undertaken during a pilot phase project. There is the potential for a second phase of cities/towns identified through the regional model such as Perth, Paisley and Kilmarnock etc to be modelled and assessed.

Important to ensure the new process is linked to the Defra modelling approach and links to this where appropriate.

Note: the contributors agreed that there is a value on standardising the approach taken across Scotland, to reduce discrepancies that are included in other assessment processes that are not consistent in their approach. This approach should form a central resource for Scottish Government and Local Authorities.

Current action wording Proposed new action wording

3b A training programme enabling spatial and transport planners to use the new methodology will be developed.

Design and implement guidance and support network for all professions involved in conducting assessment on development contribution to Air Quality.

General comments:

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This action is much more than a training requirement. The action needs to promote knowledge exchange rather than training, bringing together urban planners, transport partners, roads engineers, and AQ specialists, to engage with, own, and develop any new appraisal processes.

Need to evaluate how we encourage ownership of the programme of work, so that targets are achieved and annual reporting requirement for the regional model are delivered.

Need to ensure any software tools developed (i.e. the regional model) and the reporting structure are fit for purpose (i.e. for use by private developer and planners alike).

Appropriate guidance covering new development thresholds and potential mitigation options should also be included.

An example of the “type” of guidance approach is the STAG Appraisal Guidance. This is supported by a user group and is Transport led, but evidence driven.

Note: the contributors agreed that there is a requirement to develop guidance for planning and development practitioners to ensure a standardising approach is taken when using the regional model and assessing potential mitigating measures to reduce discrepancies and maintain consistency in their approach. The information provided and the quality of the assessment can be substantially different depending on the applicant and the methods applied.

Current action wording Proposed new action wording

3c A screening procedure for assessing LEZ requirements will be produced.

Design and implement an air quality options appraisal process.

General comments: Jacobs work will feed in to this process and so the wording for the action may

change.

Need to provide an opportunity for LAs and wider organisations to provide comment and input to the appraisal process (such as at the STEP Conference and other focussed events).

The screening process should link to the existing LAQM requirements that the LAs already work towards and any proposed changes that come out of the current AQ review and legislation.

Current action wording Proposed new action wording

3d A national LEZ framework will be developed.

General comments: Although this is being led by the other working group, it is important that it fits in with

the work being developed by the MAMWG.

It may be advantageous to consider merging groups to develop a wider collaborative group that supports the work to deliver the LES actions.

Although Jacobs will deliver this through the Scottish Transport project, we need to ensure wider comment.

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Actions

A number of actions were recorded during the 5 meetings; the key actions that relate to the final draft of the LES are listed below along with the status.

Action Owner Status

1 Provide group members with access to the Aberdeen pilot project tools

SEPA All members were provided with the tools and asked for appropriate comments.

2 Develop a programme for peer reviewing the modelling framework developed through the Aberdeen pilot project.

SEPA Reports from the pilot project are being drafted and a tender for an independent review of the outcomes will be commissioned.

3 Develop a national screening / appraisal approach for identifying candidate LEZ areas.

TS Transport Scotland has commissioned a project with Jacobs that will identify such an approach.

Key CommentsA number of key comments were raised by the contributors. The group discussed these comments at meeting 5 to address how they are taken forward within the final preparation of the Low Emission Strategy and its implementation. Details of these observations and comments are noted in table 6 below.

Comment Actions to be taken

General Comments

Identify when modelling is required. For NO2 the focus is on the major urban areas and the emission maps will give sufficient ideas on where that is. For PM2.5 the long-range contribution will make this a lot less accessible, Here you could take an approach to say that the focus is on reducing LOCAL emissions of PM2.5 (primary and precursors to secondary formation) and thus widely ignore the long-range transport contribution to PM2.5.

This should be expressed within the LES text, whilst ANPR will help to quantify the local contribution at the street level. This could be subsequently enhanced by monitoring black carbon emissions at the same time.

Should there be a link to the Local Air Quality Management Review and Assessment process?

If there is common ground between the review and the LES then they should be linked.

Both the models and the reporting process should include input/consideration of emission from other sources (other than traffic).

The models will include other inputs from sources other than traffic, whilst the reporting process will focus on developments that exceed a specified size reporting threshold.

National Traffic data collection plans need Local Authority Roads Authorities buy-in to try and relieve concerns about: good quality traffic data,

The use of DFT data should be backed by other traffic data sources and used within the regional model. At a local level, Jacob task 1 will review existing

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funding and future governance, the use of DFT data is a concern as it is

estimated data.

traffic data collection and propose a standard methodology for national traffic data collection for air quality modelling purposes, The Sniffer will use the outputs from this task, planning the next traffic data gathering exercise within a city in Scotland, and supporting the development of a national traffic data collection programme to support the air quality modelling process within the LES. Additional funding will be required to set this national approach to traffic data collections for the LEZs. The estimated cost for traffic data collection should come out of the Jacobs project.

Agree models will need to be regularly updated. There will be elements that will need updating periodically e.g. when emission factors change or the national emission inventory changes – how will this be managed?

It would be useful to define an annual update programme, similar to the Netherlands national model; this will include developments and other changes to sources, such as emission inventories.

Would be good to tie in with any work that is ongoing with DEFRA to ensure continuity and ease for businesses.

We are aware that there is no similar approach proposed for the UK, however any future Defra approaches (and awareness of such) should be considered.

In terms of drawing on existing models to avoid duplication of effort, more should be done to co-ordinate with regional Transport & Planning Groups and national groups Transport Scotland etc. There could be an assessment of current models (including status and capability),e.g. Transport Scotland model last updated with 2001 census data. 2011 census data now available.

Transport Scotland should commission a full appraisal of existing traffic models during the development of the national model frame work, this would include an assessment of data requirements.

The framework and models developed will need peer reviewed.

There will be an opportunity for further reviews of the framework. The proposed methodology of the options appraisal LEZ model, the scenario testing tools and the development of the regional model will be peer reviewed.

Consideration needs to be given to the KPIs,- the question of health and mortality

It is difficult to develop KPIs on health and mortality since the direct causation/association studies of air pollution and health are difficult to interpret because of the issues around confounding and population level studies.

Further reporting procedures for AQ data will be developed to provide reportable KPIs.

Rotational ANPR and tailpipe collection within LEZ areas would provide a potential KPI that is linked to long-term improvements.

National Framework

The flow chart can be quite hard to follow over the logic, particularly when considering the nesting of the LEZ within the regional model. The regional model in some sense provides boundary conditions for the LEZ modelling.

The overall process will be presented using an adapted version taken from Stefan’s paper (see diagram 1), whilst the flow chart (see diagram 2) will form part of the guidance to illustrate key steps. These will be accompanied by

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There are likely more connections between components that could be there, and there is clearly a series of iterations and feedbacks. While you have traffic data analysis and visualisation, there would also be the modelling analysis and visualisation that would then be an important component of the reporting measures, assessment and effectiveness box. 

explanatory text to ensure that the process is well documented and any new terminology is explained. Suggested flow charts showing the module relationship and data flows are included in the report (see diagrams 3 and 4).

How detailed is the framework going to be? It might be more appropriate for the LES and associated Tools (to be developed/some being developed [UK]) to take account of public exposure and health costs of air pollution.

The framework within the strategy will set out the process and structure. At this stage it is difficult to say how public exposure will be taken in to account, however further development (post launch) will be required to provide a robust cost benefit process that considers the full benefits to health – further consideration will need to be given to HIA’s to inform local scenario testing.

Resourcing and governance of the modelling will need to be detailed in a Framework.

The overall governance will be set out within the framework to provide clarity on structure, whilst funding will need to be identified and agreed by Scottish Government.

There is a need to have immediacy in model runs and scenario testing.  

There is a potential that the traffic data used for the modelling could become out of date, however the proposal is that traffic data will be collected at the time of the modelling and further traffic data (i.e. ANPR) will be collected in response to the model outputs. In addition, subsequent traffic data will be required to maintain the accuracy of the regional model, whilst a potential rotation programme will help to inform local KPIs.

Regional Model

Will the Regional Modelling not require traffic analysis / local emissions analysis? Should there be regional planning/transport input?

The regional model will be developed after the adoption of the LES. The proposal will be to develop the regional model based on the LATIS approach, using enhanced methods such as those developed within the national Dutch model. The aim of the regional model is to take in to account significant development including transport.

Non-traffic sources also need to be considered – domestic/commercial heating, gas CHP (especially in AQMAs), biomass boilers, and wood burning stoves.

Non-traffic sources will be taken in to account within the regional model where appropriate.

It is difficult to establish a defined start point. My assumption is that the beginning is to define regional and local study zones. The local study zones are probably an easier prospect to define from a LA perspective since we generally have a good idea of the problem areas. However, there will be some practical problems in judging the extent of these in terms of the practicalities of potential LEZs which may result. Regional

The framework will aim to set this out, it is agreed that although the regional model should help to inform the LEZ areas there are limitations to such models and local knowledge will help to determine LEZ modelling areas, with local model then identifying individual streets that require actions.

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model areas may be more difficult and will depend to a large extent on the suitability of the model method chosen. It’ll also depend largely on the traffic data and potentially the information coming from LA planning departments.

The traffic database is crucial, but, as mentioned, the database will almost certainly have to have a degree of modelled data. Has there been much thought put into adopting a standard model or unifying existing ones? This feeds into the traffic data collection which we all know will be crucial. I don’t think a regional model can work well without a robust traffic model to fill in the gaps (as with the Dutch method). Again, this will cause problems without a unified approach across LAs.

The outcome of the Jacobs project will help to determine the extent of traffic data available. The regional model will include modelled and observed traffic data.

The Dutch model has the local authorities able to utilise and manipulate a version of the “master” model for planning purposes, assessing potential developments etc. Is this how we imagine the Scottish model working? Although the flowchart is about setting up the respective models – should there be a place for developers AQ modelling to feed in (again like the Dutch model)? The flowchart only shows Planned Development feeding into traffic data collection. Many developments have point or area source aspects as well. Existing point source data also doesn’t feature in the flowchart.

Although the regional model has not be developed yet the proposal would be that there would be a functionality that would allow for assessing developments and traffic scenarios similar to the Dutch approach. There will be extensive LA liaison in developing the model further.

LEZ Model Comments

There is a need to have immediacy in model runs and scenario testing.  

There is a potential that the traffic data used for the modelling could be out of date, therefore subsequent traffic data is required to maintain the accuracy of the model.

For AQ modelling (and ultimately Scenario testing), Local emissions /ANPR /Tailpipe emissions analysis is a requirement. I wonder if the latter should come before Traffic Data Analysis and visualisation as it might be necessary for this too.  

There is a two way approach that we are suggesting, first you implement a traffic data collection programme – which we have funding to trial and are currently collecting the information on this before we trial a collection programme. This will stipulate what is needed for the first run of the model. In Aberdeen we had a detailed collection of traffic data collected and so are looking at what else would be required to spec out a survey. This can be detailed enough for starting to screen scenarios. Once you have modelled this and considered the streets involved (or area) you can then undertake a more focused ANPR/Tailpipe approach on key roads of interest – this is too expensive approach for a city wide survey and more a concentrated area investigation. This would then be fed back in to the model for finalising the LEZ requirements and actions.

Local monitoring data should be used for The detailed model of Aberdeen went through

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validation purposes. Concerns about data quality might need to be addressed through LAQM R&A process.

the verification process that not only looked at the model outputs against the monitored data, but also a detailed investigation in to why there were some discrepancies in the data. This approach allows identification of where the monitors position is affecting the verification of the data.

The draft tool (for Aberdeen) does not take account of gradient. Consultees have mentioned on a number of occasions the importance of local characteristics when modelling air quality at local level. A framework will need to take this into account, as well as notorious street canyons. Models can struggle with complexities of this topography and hence monitoring is necessary. Will the framework link to monitoring (TG09?)?

Gradients were considered in the Aberdeen model, but few streets exceeded the gradient necessary for inclusion. The national approach will take in to account gradients when appropriate, More importantly is the start/stop, for traffic, this will also need to be considered within the national modelling approach.

Traffic Data Analysis and Visualisation – For LEZs this may actually be easier than the Regional model approach since, dependant on area, it can be based on direct measurement with modelling being introduced for intervention measures (as in the linked box). Some areas may still need some degree of modelled data input at the assessment stage.

The comments above illustrate the two phased approach in collecting traffic data, the first phase will include modelled data where traffic data is difficult to obtain.

Compare with national fleet – I think this is very important. The EFT has a Scotland breakdown but I’m not sure of its accuracy or applicability across different areas of Scotland or how it breaks down when factoring in things like bus fleets.

A comparison across national fleet will allow a better understanding of the fleet composition within a single LEZ and provide information on fleet movement form one area to another.

Local emission ANPR / Tailpipe emissions – As above. I’m hesitant about supporting tailpipe emissions monitoring since it may well be duplication of work being carried out elsewhere (EFT work, European legislation). However, given the previous assumptions made about Euro engine’s effectiveness with regards NOx and the subsequent disappointment it may prove necessary.

The second phase of traffic data collection will include both ANPR and tailpipe emissions – taken across the road under real driving conditions. Similar work has found that specific Euro engines and manufacturers do not meet the reductions or emissions standards as stated and used within the emissions factors. The second phase of traffic data will also allow for more detailed actions to be considered in relation to local fleet, rather than based on national fleets.

In terms of planning it is worth noting that EPS has indicated specific planning guidance will be developed, this is required as the existing draft Scottish Planning document and planning changes provide only minor AQ changes.

EPS guidance should permit incorporation of more substantial changes according to framework and regional model etc.

It should be emphasising that modelling is only useful where there is monitoring to ensure its accuracy / verification.

Both modelling and monitoring go hand in hand, although this group has focused on the Modelling Framework, post implementation of the LES will result in the continuation of a Modelling / Monitoring working group.

Local AQ Modelling / Scenario Testing / modelling database / Reporting measures

The aim would be that SEPA would provide that coordinating role in developing the LEZ models,

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Assessment Effectiveness – These are all obviously the most important outcomes from an LEZ model. One aspect not mentioned in the flow chart is responsibility. Obviously SEPA are coordinating the overall model approach but such things as scenario testing will depend on local input and, to a large degree, on the output from the Low Emission Zone working group. The Spotfire apps seem to be designed to allow a degree of scenario testing (albeit on a scaling rather than model output) but I have been wondering how local Authority input will work in practice.

with Transport Scotland providing the vital role in coordinating the traffic data collections. This would then generate two new data bases, one for the traffic data and one for the model outputs. It would then be the responsibility of the LAs to develop their own scenarios, identifying the streets for further ANPR data is collected. This would be fed in to the model to refine the information and then scenarios and actions could be developed. I would suggest that in undertaking all of above, close collaboration is required between all parties, so that the data etc can be properly gathered and validated. That central role provided by Transport Scotland and SEPA offers consistency in the modelling approach taken across Scotland, whilst LAs are key in driving this approach forward, identifying zones and undertaking scenario testing. LAs with internal modelling capacity would have the added advantage of being able to model the scenarios, working closely with SEPA in developing the model for their area.

LES Consultation comments – summary for WG responses

Consultation response Comment ActionExtremely ambitious – difficult to envisage how it could operate at local level given complex urban centre environments – may be more effective at regional scale.

The framework will provide two tiered modelling: regional model that will focus on land use and traffic movement between neighbouring LA areas: detailed model will be used for proposed LEZ areas. This detailed approach would rely on traffic data collected within a specifically defined area and to a defined method.

Ensure that the framework stipulates the difference between the approaches taken.

Model must be validated with monitoring data.

The detailed model is fully validated against automatic monitoring stations, with detailed investigation using CFD models and weather data where significant variation between modelled/monitored data exists.

Spotfire is used to undertake detailed data analysis between modelled output data and monitored data. Met office weather data will be used to investigate specific trends, whilst CFD models will be used for individual monitor station investigations to identify potential reasons for differences.

Robust traffic data essential – obtaining local data could be challenging.

There is a project to investigate existing data and collect traffic data at the city centre level for LEZ modelling purposes; this will result in guidance for traffic collection and recommendations for a traffic

Traffic data project to complement LEZ modelling guidance.

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data collection programme.

Model must be updated regularly to take account of new developments, and include future year predictions.

Proposed regional model could follow the LDP timescale or updated annually, with development size triggering assessment and potential mitigation requirements.

We need to set out a project that can look at the regional model in detail, including suggested timescale for development.

Question whether more modelling is needed.

The proposed Framework and models set out are aimed at: - identify early any potential cumulative effects associated with proposed large-scale developments at the regional and city level – Note that the SESTRAN regional model currently used in Edinburgh to predict impacts of development of traffic flow and speed, regional model should take such changes in to account when estimating emissions across certain link road networks. - providing a tool for identifying potential actions and suggested deliver mechanisms for LEZs

No action required.

Should include estimates of public exposure and health costs of air pollution.

The model looks at dispersion and pollutant levels, further modelling would need to be done for estimating public exposure, this would need to consider peoples movements etc. A cost benefit analysis should be undertaken against potential scenarios to understand cost implications and ascertain long-term benefits.

Consider developing a project on assessing exposure, involving individuals carrying personal monitors. Consider a specific project that can be used in developing a ‘cost benefit analysis’ tool within the scenario testing model.

Agree with principles but more detail needed on what will be included e.g. just AURN sites or local authority sites also.

The model outputs will be assessed against AQ data from all LA sites and AURN sites.

Include in guidance.

Concern that there will be no consultation on detailed framework.

The model used is a standard model that has been peer reviewed and has gone through various validation processes. What has been developed is a standard approach to detailed modelling, along with a high level of data validation.

We will ensure that both the model and the data analysis processes are validated through an independent peer review of the reports, modelled outputs and relevant tools generated.

Supported, but ideally should be consistent approach across the UK.

The LES sets out a national framework for Scotland, this approach has not been adopted in the rest of the UK.

No action required – in the meantime we will continue to review anything that comes out of Defra.

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Welcomed in principle, must be employed accurately and consistently to be effective.

The proposal is to develop a national approach, including a national approach to data collections, modelling and validation.

Guidance should set out the exact method to be deployed across Scotland. The guidance will follow the launch of the LES, with specific dates set out for its development.

Unsure of benefits if local and regional groupings can develop their own approaches.

The model should be consistent in its development, individual approaches come from the actions taken within the LEZ – this is because each LEZ will require different actions depending on local issues. The national LEZ framework should maintain some consistency in measures adopted.

No action required.

Welcomed, but data analysis must be undertaken consistently.

The analysis and scenario building is vital to ensure consistency in its approach and use.

The analysis and scenario tools will be available on the AQ in Scotland website, specific guidance will ensure that the data obtained from individual modelled LEZ areas will go through a rigorous analysis process.

More detail needed on the type and extent of high quality traffic data.

There is a detailed national traffic collection project that will develop the method employed to collect the necessary traffic data, including traffic counts and targeted ANPR, with the added potential of remote tailpipe emissions to improve on the current national emissions factors used.

Ensure the delivery of the project will aim to collect the relevant data – Jacobs and Sniffer are developing projects that will cover this area of work. A national programme and database should be set up by Transport Scotland and SEPA.

Clarification needed on how recent fleet composition estimates will need to be.

The collection of detailed traffic data will provide detailed local traffic profiles for each LEZ area rather than just national fleet composition estimates.

As above

Modelling methodology will need to take into account specific road characteristics such as street canyons and gradients.

The model used within the Aberdeen project and proposed within the national framework will take in to account street canyons (new model will include one-sided canyons), gradients as well as traffic start/stop and traffic flow.

Detailed guidance should provide guidance on the use of the model and detailed street characteristics.

Methodology will need to be locally verified.

The modelled data is verified against local monitoring stations and local weather data, additional CFD modelling will identify individual monitoring

Set out verification process within the guidance document.

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station issues where the model and data outputs don’t correspond.

Could be an opportunity to strengthen role of air quality in SEA.

The regional model could be used within the LDP process and therefore fit in to the SEA process, whilst the transport strategies would pick up on both local and regional issues with the LEZ delivering both practical and strategic options to improve an area.

SEPA guidance on SEA for Air should be updated – date for this should to be actioned, whilst the modelled generated within the LES could be used as part of SEA assessments.

General agreement, but clarification required on how data will be obtained and paid for.

It is proposed that SEPA will provide a central role in developing local models and provide a central repository for modelled data, whilst the analysis and scenario tools will be held on AQ in Scotland website. It is also proposed that Transport Scotland will develop a national traffic data collection programme that is guided by the modelling requirements. ANPR / Tailpipe analysis will be conducted by Transport Scotland / SEPA.

Develop the guidance for undertaking detailed local traffic surveys and ensure that there are funding for undertaking data collection programme for traffic data.

Supported, but should draw on existing models and best practice rather than starting from scratch.

The Aberdeen model utilises an existing model package, the added development is the data analysis process.

It is proposed for the regional model that a traffic and land- use model approach could be used.

Should be peer reviewed and subject to public consultation.

The Aberdeen pilot project used ADMS-Urban, EMIT for calculating emissions and Matlab and Spotfire for data analysis. Further detailed CFD modelling was undertaken at specific automatic monitoring stations when data did not fit. All models and data analysis software are common, however methodologies employed will require further peer reviewing.

The Aberdeen model will be written up for independent peer review and the framework will be subject to wider consultation.

Will need to tie in with existing and future Environmental Protection Scotland planning guidance.

The regional approach will have a development threshold trigger that will initiate mitigation measures.

Will ensure guidance and EPS guidance and aligned.

Emissions based approach should be considered for traffic sources – easier to measure and subject to smaller uncertainties than concentration based.

The Emissions Factor Toolkit takes account of many factors relating to calculating traffic emissions at the street level. This approach is used in the LAQM source apportionment process.

An emissions based approach will show emission reductions at the street level this does not fully translate in to concentrations and therefore exposure reductions. A mix of both approaches would be of benefit to illustrate level of

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reduction required.

Regional approach will need to offer guidance on how local authorities should interact and take any necessary action.

The regional model will be open for use by LAs and by developers.

Guidance will be developed with the regional approach and how it relates to LEZs.

Will the model replace or supplement existing modelling requirements under LAQM?

The model is aimed at LEZ areas rather than all LAQM areas, which will still be required under the current legislation.

No action required.

Must be adequately resourced and sufficiently robust to be useful as a first step in assessing potential impact of developments.

SEPA and Transport Scotland are pulling together costing for the proposed framework. It should be noted that this approach will provide a central role for government agencies and departments to ensure closer partner working with LAs in order to reduce overall costs.

Scottish Government will need to consider funding requirements for regional model.

Should aim to estimate public exposure and associated health costs.

See previous comments. See previous actions.

Should be applicable at both local and regional scales.

The proposed models are split between local and regional as the detail in assessment and data requirements are different. A regional approach will not be refined enough for the LEZ area.

Ensure framework provides detailed information on different approaches.

Essential that final framework is peer reviewed.

See previous comments. Final proposed framework should be reviewed, or the models used should be reviewed.

Still some unanswered questions around resources, ownership, access and the source and quality of input data.

Scenario testing will be the responsibility of the LAs, whilst data collection and modelling will be jointly delivered by LAs / SEPA / Transport Scotland.

Needs to be clear about what will be achieved that is not already being achieved.

The Strategy is there to deliver improvements over wider areas and to bring together other policies that are currently not addressed through LAQMAs.

The strategy needs to set this out rather than the modelling framework.

Important that the framework does not waste resources replicating what is already being done elsewhere.

Although LEZ assessments have been undertaken at the LA level for some LAs, these have been conducted ad hoc. The LES and the framework sets out a systematic process that can be replicated across other major cities.

Utilise existing LEZ Feasibility studies that have already been done where appropriate.

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Initial focus on SDP areas could miss an opportunity involve all relevant local authorities and RTPs.

The regional model will be transport based and so should follow the same structure as both the SDP and RTPs.

Further consideration needs to be given to the regional model approach.

Part of framework should be to test potential interventions and scenarios, and consider interplay between air quality modelling and transport modelling.

The LEZ model will develop the basis for scenario testing.

Consider how to introduce traffic model outputs with AQ modelled outputs for further scenario testing.

Role of new developments should not be over emphasised – existing developments contribute vast majority of impacts.

See previous comments on regional approach.

See action before regarding cumulative approach.

Should recognise that Regional Transport Strategy reviews are increasingly being aligned with SDPs.

See previous comments on regional approach.

See actions above on regional model.

Further consultation when more detail is available would be welcomed.

See previous comments. Additional consultation will be provided through scrutiny of the Aberdeen pilot project report.

Should also include rail. Rail is a contributing factor and should be considered when appropriate for the models, over and above the current input within background models.

Where appropriate.

Data requirements must be realistically achievable.

See previous comments. See previous actions on traffic data requirements.

Some concerns about ‘It is essential that there are detailed and high quality traffic data available across Scotland, especially in densely populated city centres and surrounding areas’ – could have significant resource implications.

See previous comments As above.

Useful but not a substitute for direct action.

The model framework is the basis of delivering direct actions, especially within the LEZ areas.

The framework should drive towards specific actions for individual LEZ areas rather than a blanket approach.

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