From out of thin air

Environmental managers in industry could be forgiven for placing air pollution low on their list of concerns: any objective assessment of air quality in the UK shows road traffic, not industry, to be the primary offender. But recent developments at EU and national level guarantee that the drive to improve air quality will continue to impact on the manufacturing sector, says Tim Brown, deputy secretary for Policy and Development for the National Society for Clean Air - and sometimes from unexpected directions.

Most polluting industrial processes are already regulated under the 1990 Environmental Protection Act. The National Air Quality Strategy, published last year, sets air quality objectives for the UK and gives district, metropolitan and unitary authorities the job of assessing local air quality. If monitoring and modelling suggest that any location is likely to fail to meet the objectives by 2005 – and many areas of the UK are going to have problems with particles, nitrogen dioxide and sulphur dioxide – then the authority has to put together an action plan to sort the problem out. That will mean introducing a mixture of measures to cut pollution, and the authority must consult at various stages of what has become known as the local air quality management process.

Whatever the monitoring data may show, opinion polls indicate that the public still sees industry as a major contributor to poor air quality

Your local council has until the end of this year to complete the first stage of its air quality assessment, so it’s worth checking on progress. Why? Because they will be making a judgement about how much local pollution is coming from industry, before deciding where to seek emissions reductions. Most urban authorities will be compiling local emissions inventories and may therefore be asking industry to supply information about emissions to air.

Tightening framework

Operators of processes already regulated for Integrated Pollution Control (IPC) or Local Air Pollution Control (LAPC) will have some information already, but pilot work by local authorities suggests that the data used for authorisations is often in the wrong format for compiling emissions inventories. Process authorisations usually set emission standards in terms of pollutant concentrations, whereas inventory compilers may need to know about mass emissions of pollutants over specific time periods.

Operators of Part A (IPC) and Part B (LAPC) processes are already familiar with the tightening regulatory framework. But if their process is contributing to a local air pollution hotspot there may be pressure to go beyond what is currently accepted as BATNEEC in the next round of authorisation reviews. Local authorities will seek a balance of measures to cut pollution from traffic and industry, and must consult with the Environment Agency or SEPA, as well as industry, on appropriate measures. Sulphur dioxide is likely to be a sticky issue for industry – plume grounding from large combustion plant has already been identified as an area for action. Operators of small combustion plant which currently escape regulation (below 20MW) may also find themselves drawn into agreements to change, or at least vary, fuel use during times of poor air quality – particularly if they burn high-sulphur fuels.

Common position

What does this mean for the environmental enforcement level playing field? Any industry which is pressurised to tighten up its emissions under the new local air quality management regime can challenge the local authority to show that similar improvements could not be achieved though alternative means – usually by tackling traffic pollution. Agreeing which anti-pollution measures are likely to work, be most cost-effective, and be socially and politically acceptable could prove to be a real headache. The good news is that industry across the EU will come under similar pressure. For once, the UK has led from the front on an environmental issue, and our approach to air quality management has now been adopted by the Union through the Framework Directive on Air Quality Manage-ment and Assessment. The British Presidency of the Union in the first half of this year agreed a common position on a Daughter Directive which sets EU air quality objectives for four pollutants – particles, oxides of nitrogen, sulphur dioxide and lead. Working groups are now discussing limit values for carbon monoxide, benzene and ozone, with work on PAHs and four heavy metals also in the pipeline. Industry across Europe will have to play a part in meeting these EU air quality objectives.

The Commission is very keen on air quality issues and several other initiatives – sometimes overlapping – still have the potential to affect particular industrial sectors. The oil industry and motor manufacturers face product and market changes, following Directives stemming from the Auto-Oil process, whilst combustion plant operators face a further squeeze thanks to the EU Acidification Strategy. This involves a number of strands, including a Directive on the sulphur content of liquid fuels, a Directive on national ceilings for acidifiers and ozone precursors, and (possibly) a new lease of life for the Large Combustion Plants Directive (LCPD).

Integrated approach

The power sector argues that the LCPD is obsolete, since it will be overtaken by the Integrated Pollution Prevention and Control Directive, and UK industry can anticipate a more general who-does-what debate, as IPPC replaces our current IPC/LAPC system. Some processes currently regulated for air pollution only will become liable to a more integrated regulatory approach – although whether this will mean the Environment Agency takes over control for such processes from local authorities in England and Wales remains to be seen. Processes which currently escape authorisation, such as food processing and intensive livestock units, will also be drawn into the regulatory net.

Low emission zones

If your industry remains outside the IPC/LAPC regime, air quality may still have an impact on operations. Back at local authority level, the environment officers will want to know about more than stack emissions. As part of the local emissions inventory they will be calculating the pollution caused by local traffic. Is your site the base for a large delivery fleet? Does it generate a lot of car-based commuter or sales trips? If so, the air quality management team may want to know about the efforts you are making to clean up your act – through using cleaner vehicles and trip reduction programmes.

Following the publication of the Integrated Transport White Paper, Ministers are talking about low emission zones – pollution hotspots where access may be restricted to certain types of vehicles. Heavy-duty diesels look particularly vulnerable to exclusion. Tax concessions for some cleaner fuels and technologies have already been agreed. Many local authorities are also taking up the idea of Green Commuter Plans – programmes to reduce the number of single-occupancy car trips made to sites. This is often perceived as an assault on personal mobility and the car-based perks package. Experience in the US shows that well-designed Transport Demand Management Plans can cut commuter trips whilst benefiting employees and saving companies money. Now the idea is catching on in the UK as one of the air quality management tools available to local authorities.

Wider environmental profile

Any environmental manager has a pretty good idea of the direct air quality impacts of the process or facility they manage. Assessing the wider environmental profile of your company through an environmental management system may reveal that significant impacts are caused elsewhere – through vehicle movements, or via the purchasing and supply chain. The new air quality management regime means that effective action to reduce air pollution may come, not from further improvement to a manufacturing process, but through fleet management, product design and purchasing policy decisions. As interest in formal environmental management systems grows, local authorities may be asking how much you know about these wider impacts, and more importantly, what you are doing about them. This moves environmental management out of the engineer’s office, into the personnel, transport management and finance functions, and beyond.

A final point. Whatever the monitoring data may show, opinion polls indicate that the public still sees industry as a major contributor to poor air quality. Such attitudes take a long time to change. It makes sense to participate fully in the developing framework for air quality management as a responsible local stakeholder. But you may also be able to gently remind those who are worried about air quality that the threat may equally come from their own car exhaust pipes, bonfires, barbecues and cigarettes.

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