Tackling local air quality breaches

There is a high level of uncertainty in government’s model for assessing pollution levels, which may mean that further areas of poor air quality might be missed by the programme. Government uses a national model to identify areas that are likely to be breaching air quality limits, and uses this to direct local authorities to take action. The national model does not directly use the results of monitoring by local authorities; instead, it uses a national network of monitoring stations. The model is regularly updated to take account of differences to local modelling, however government estimates that overall uncertainty in the model remains at the ‘allowable limit’ of +/- 30%. There is no formal margin of tolerance to identify local authorities for inclusion in the programme, and some local authorities are concerned this may result in an unfair situation whereby areas with high levels of NO2 pollution are not required to take action due to the national model not predicting a breach. Recommendation: As part of the Treasury Minute response, the government should set out how it will satisfy itself that all areas in exceedance of pollution limits have been identified and included in the programme, taking into account the high levels of uncertainty associated with the national model.

Central government has not always got the balance right in how it works in partnership with local government, having been prescriptive in some respects, while seeming to avoid responsibilities that naturally sit at a national level in others. The best approach to addressing air quality issues varies between areas according to local circumstances. Although Local Authorities have had the freedom to set different exemption criteria and different charging levels for Clean Air Zones, some feel that JAQU has been inflexible and lacks understanding of local politics, with too much emphasis placed on 6 Tackling local air quality breaches CAZs as the default option, instead of other measures that may be more suited to the area. On the other hand, government has not taken the responsibility it should for national messaging on the need for air quality measures, saying that local places were best placed to judge how to communicate with their residents, and so not introducing a national campaign. The experience of the Covid-19 pandemic shows that local communications need to be supported by a strong national message about why specific local actions are necessary. Recommendation: The government should review its approach to working with local authorities on air quality, to make it a more effective partnership. In particular, it should: • introduce a national communications campaign on air quality to provide a strong national message about the purpose of air quality measures that supports locally-tailored communications. • Ensure that local authorities have sufficient flexibility to determine the approach to be taken in their local area. In addition, government should provide a further update to the committee by the end of this year outlining what further steps are being taken to improve its working relationship with local authorities.

Although calculating an exact figure may be difficult, with Departments claiming it would be a great deal of effort to produce something not necessarily precise, Government could do more to improve the transparency of cross-government public spending that has an impact on air pollution. While Defra tracks spend on its own air quality initiatives, it could not provide the National Audit Office with a breakdown of spend across all the cross-government initiatives it expects to contribute to air quality improvements, such as from programmes within BEIS and DLUHC. Government says that disaggregating the air quality impact of these programmes from other outcomes is a difficult technical challenge. It is important for government to be transparent with the public and Parliament about how much taxpayer’s money is going towards meeting air quality targets. Without this information the benefits and risks for air quality of wider programmes across government are not be as clear as they need to be. A lack of cross- government transparency also makes it harder for government to reprioritise when necessary and judge value-for-money. Recommendation: Although calculating an exact level of spend on air quality across government may be too difficult, there is value in improving transparency through higher level estimates. Government should, by the end of the year, develop options for improving the transparency of cross-government air quality spend and inform the Committee of its preferred approach.

Government is not yet taking a sufficiently integrated approach to tackling the problem of poor air quality. Measures to tackle air pollution on the strategic road network risk displacing heavy vehicle traffic onto local roads. Although government is aware of this risk, we are not clear what specific actions are being taken to work with local authorities to manage this risk, and National Highways has not published criteria that set out the point at which this possibility renders a particular measure non-viable. In addition to working with local authorities, central government is starting to develop opportunities Tackling local air quality breaches 7 to work with local health and education providers to support air quality communications campaigns, such as through a pilot project working with around 40 GPs and awards through the local air quality grants programme. The Departments for Business, Energy, Innovation and Skills (BEIS) and for Levelling Up, Housing and Communities (DLUHC) are also important partners for addressing issues of air quality. Recommendation: The update to the National Air Pollution Control Programme should set out how government will ensure full integration between the different areas of responsibility with an impact on air quality.

There is a lot resting on the updated plan that government expects to publish if 2030 air quality targets are to be met. The UK may have missed its target for national ammonia emissions in 2020, and existing policy measures will not be sufficient to achieve the 2030 emissions ceilings set for the UK for a further three pollutants. At the time we took evidence Government planned to publish in September 2022 an update to the National Air Pollution Control Programme, and this must be robust and realistic enough to ensure that targets are met. Past action to tackle local breaches of air quality limits has fallen significantly behind schedule, and similar delays at the national level would mean targets being missed. Meeting these targets will require action beyond the transport sector, such as by reducing domestic wood-burning (which accounts for a quarter of fine particulate matter emissions) and addressing ammonia use in farming (around 87% of ammonia emissions). Recommendation: The government must ensure that the plan it publishes includes robust, actionable measures that will result in compliance with the 2030 targets for all air pollutants, and ensure it has strong governance arrangements to monitor progress against its plan and take decisive action if progress falls behind expectations. 8 Tackling local air quality breaches Tackling Local Air Quality breaches

On the basis of a report by the Comptroller and Auditor General, we took evidence from the Department for Environment, Food & Rural Affairs, the Department for Transport, and National Highways on their work to tackle poor air quality in England.1 Our report covers both the Nitrogen Dioxide (NO2) Programme (the Programme) and work to address other air pollutants.

While emissions of most air pollutants have been falling in recent decades in the UK, poor air quality continues to cause damage to people’s health and the natural environment. The Committee on the Medical Effects of Air Pollutants estimated that human-made air pollution in the UK has an effect equivalent to between 28,000 and 36,000 deaths each year. There are two types of air quality target in the UK—national emissions ceilings, which are breached if too much of one pollutant is emitted across the UK within a year, and local concentration limits, which are breached if the average level of a pollutant in a specific area is too high. Current targets cover pollution from ammonia, particulate matter, nitrogen oxides, non-methane volatile organic compounds, sulphur dioxide, and more.2

The UK complied with most of these legal limits between 2010 and 2019 with the exception of the local concentration limits for NO2, for which there have been longstanding breaches in some areas of the country. The country may also have missed the national limit for ammonia in 2020, and existing policy measures will not be sufficient to achieve most of government’s 2030 emissions ceilings targets, which require lower levels of pollution than current targets. Government published a Clean Air Strategy in January 2019 outlining its approach to air quality more broadly. Government expects to publish an update of its National Air Pollution Control Programme in September 2022 to set out the measures that will be required for the UK to meet its 2030 national emissions limits.3

The Department for Environment, Food & Rural Affairs (Defra) and the Department for Transport (DfT) established the Joint Air Quality Unit (JAQU) in 2016 to oversee delivery of government’s plans to achieve compliance with NO2 limits. The NO2 Programme is government’s largest dedicated air quality initiative and involves two main elements: • Ministerial Directions to specified local authorities requiring them to assess potential breaches in their local area, and identify and implement measures to tackle the problem, with support and funding provided by JAQU; and • work by National Highways, a government-owned company, to assess and tackle breaches on England’s motorways and certain major A-roads known as the Strategic Road Network.4

Since 2017 Defra and DfT have jointly issued directions to 64 local authorities. It has also identified 31 sections of the Strategic Road Network that are above the limit value and therefore non-compliant. Measures to tackle NO2 pollution include bus retrofit and traffic management schemes, and in some areas, Clean Air Zones where vehicle owners 1 C&AG’s Report, Tackling local breaches of air quality, Session 2022–23, HC 66, 17 June 2022 2 C&AG’s Report, paras 1.3 - 1.6 3 C&AG’s Report, paras 1 - 6, 10, 1.12 4 C&AG’s Report, para 3 Tackling local air quality breaches 9 are required to pay a charge if their vehicle does not meet a certain emissions standard.5

Of the 64 local authorities initially directed to take action to tackle poor air quality, 16 were found to be already compliant following local modelling, and three exited the programme for other reasons.6 The Department for Transport told us that it expects the upcoming assessment of data for 2021, to be published in September, to show that 16 of the remaining 45 were in compliance in 2021, and that a further 16 will be compliant over the subsequent four years. The remaining 13, for which expected compliance dates are unknown, are the 10 local authorities working together in Greater Manchester, along with Liverpool, Coventry and Nottingham.7

The Department for Transport considers that the impact of the Covid-19 pandemic was a significant factor in delays seen by the Programme.8 The National Audit Office reported that although there was a clear impact from the pandemic, government did not have summary data on the extent to which other factors have also contributed, and highlighted that two local authorities have publicly attributed delays in their implementation of Clean Air Zones to the delivery of the central Clean Air Service.9 Gareth Davies CB, Second Permanent Secretary at the Department for Transport, told us that, in his personal judgement, one-third of the delays seen has been due to the complexity of the programme and issues around the IT platform, and two-thirds due to Covid.10 Public information on Air Quality

The UK Air website is government’s main source of communication on air quality, but it is fairly impenetrable to the general public.11 While the website provides a high- level air pollution forecast, and allows users to download air quality datasets, it does not clearly present information on the legal limits for each pollutant, actions taken to date by the UK government and the progress being made, to put the air quality data it gives in context. The annual Air Pollution in the UK report only gives a breakdown of air quality information by the zones that are used for reporting compliance with legal limits on a national basis, which is not informative to local residents.12

Issues of poor air quality are often highly localised: the 31 non-compliant sections of the Strategic Road Network represent about 51 miles of road, out of the 4,500 managed by National Highways.13 National Highways estimates about 240 to 250 houses or properties are directly affected by these exceedances, as many are not in urban areas, and levels of NO2 drop off quickly away from the road.14 Tackling these exceedances will require interventions that may be unpopular with local residents; National Highways told us that it is looking at developing two nine-metre-high barriers in the centre of Guildford, which is the location with the most severe air quality impact from the breaches identified on the strategic road network.15 These would require planning permission, which is unlikely to be 5 C&AG’s Report, paras 3–5 6 C&AG’s Report, Figure 7 7 Q 46 8 Qq 44 - 46 9 C&AG’s Report, para 17 10 Q 46 11 Q57 12 C&AG’s Report, paras 1.21, 1.22 13 Q 19 14 Q 43 15 Q 12 10 Tackling local air quality breaches straightforward if residents are not aware of the need to tackle air quality at the location.16 Other measures face similar barriers in public understanding; for example, speed limits are introduced for a variety of reasons, and in at least four locations are driven purely by air quality concerns, but this is not always clearly communicated.17

National Highways acknowledge that the accessibility of the government’s data on air quality is an issue, and Defra told us that it is reviewing its social media and online offering over the next 18 months. It particularly highlighted the need to test the quality of its messaging for specific groups, such as older people and people from different ethnic minority communities.18 Modelling air quality

Government uses national and local modelling, together with two national networks of monitoring stations, to direct its actions on air quality, with directions to local authorities issued primarily on the basis of a national model identifying areas of likely exceedance of air quality targets.19 The national network consists of around 430 unique monitoring stations across two separate networks; the UK Urban NO2 Network, established in 2020, and the older Automatic Urban and Rural Network.20 The Joint Air Quality Unit estimates that the overall uncertainty in the national model is around +/- 30%, as it was in 2017, although it has found that the model results are now more closely aligned to the results produced by the more detailed local models.21 The NAO reported that some local authorities that had been directed to act by government are concerned that this could create an unfair situation whereby other local areas might be experiencing high levels of NO2 pollution but not be required to take action because the national model had not projected a breach of local concentration limits.22

DfT explained to us that the national model ‘fills in the gaps’ in data collected by its monitoring stations to create a kilometre by a kilometre map of air quality across the country, and forecasts to 2030.23 DfT also told us that the results of the national model are updated to account for local experience; for example, in Southampton the local authority found that the national model underestimated NO2 compared to the results of local monitoring, due to a different fleet mix than predicted, so the model was updated.24

DfT told us that it takes account of the uncertainty in the model when identifying local authorities requiring action, and that it worked with local authorities to update and reopen the model as required based on local monitoring.25 However Defra and DfT subsequently wrote to us to explain that there is not a formal margin of tolerance; instead, the national modelling is continually updated to reflect the latest evidence, and additional local authorities can be brought into the programme where new exceedances are identified.26 16 Q 14 17 Q 23 18 Qq 20, 57 19 C&AG’s Report, paras 2.5, 2.9 20 C&AG’s Report, paras 2.9, 2.10; UK Air Website 21 C&AG’s Report, para 2.12 22 C&AG’s Report, para 2.13 23 Q 7 24 Q 8 25 Q 61 26 Follow-up response submitted by Defra and DfT dated 11 July 2022 Tackling local air quality breaches 11

Defra and DfT also wrote to us to explain that local monitoring is not directly fed into Defra’s national model in real time, particularly as many local measurements do not meet the data requirements for inclusion in the national NO2 compliance assessment. Instead, they review the model results against local NO2 assessments and use any discrepancies to prioritise improvements to the national NO2 compliance assessment. They also told us that an uncertainty of around +/-30% is not unusual for a model of this scale and complexity, and that their model meets the uncertainty requirements for assessing compliance with the annual mean NO2 limit value under the Air Quality Standards Regulations.27 However, the NAO highlighted that this is the limit of what is permitted.28 Working with local government

Government sees the relationship with local authorities as a partnership, and told us that it believes the programme will fail if it is seen to be a top-down programme done by national Government.29 However, local authorities are expected to follow a fairly centralised, prescriptive approach to achieving compliance with air quality targets, albeit with some discretion about the mix of exemptions to be applied in any charging Clean Air Zone.30 Some local authorities told the National Audit Office that there was still too much emphasis placed on CAZs as the default option, instead of other measures that may be more suited to the area.31 Similarly, we have heard that Greater Manchester considers a broader approach, including measures such as promoting active travel and providing revenue support for low fares, would have been better than charging.32

We asked if departments had considered revisiting the assumption of a clean air zone as the baseline for judging local authority plans, given that there have been delays to implementation. DfT told us that the evidence from the latest annual assessment is that the clean air zone is the fastest way to achieve compliance, but that they are open to other approaches if local authorities can put together a package of measures that would achieve compliance faster.33

On the other hand, government has not taken the responsibility it should for national messaging on the need for air quality measures. We asked Defra and DfT why Government had decided against a national communication campaign about the new charging Clean Air Zones (CAZs) that are coming into effect through the NO2 programme in favour of a locally-led approach. They told us that this was because they consider local places are best placed to judge how to communicate with their residents, and because they consider that local awareness of which vehicles are subject to a charge is the priority.34 However, surveys in the first two cities with CAZs, Bath and Birmingham, showed that the local campaigns had mixed results. They did not result in a statistically significant increase in the percentage of residents who ‘know a great deal’ or ‘fair amount’ about the CAZ, and the reasons for the CAZ were misunderstood by a substantial minority of those surveyed in both cities, with many believing the purpose was to raise revenue for the local authority.35 27 Follow-up response submitted by Defra and DfT dated 11 July 2022 28 C&AG’s Report, para 2.12 29 Q 34, 40 30 Q 35 31 C&AG’s Report, para 2.21 32 Q 35 33 Q 41 34 Qq 50, 51 35 C&AG’s Report, para 3.28 12 Tackling local air quality breaches Moreover, the experience of Covid-19 showed that the success of local communications partly depends on a strong national message about what is to be achieved; if the national message does not come through, local authorities will struggle.36 Public spending on air quality

As at May 2022, a lifetime budget of £883 million has been committed to the NO2 Programme to support local authorities. Separately government has spent £39 million to improve air quality on the Strategic Road Network from 2015–16 to 2019–20. Further funding is available to 2024–25.37 Although the NO2 programme is the largest dedicated air quality initiative, other work across government is expected to contribute to improving air quality, such as support to ultra-low emission vehicles and the Transforming Cities Fund, which improves public and sustainable transport. Government could not provide the National Audit Office with a breakdown of committed and actual spend across its portfolio of air quality initiatives.38 DfT told us that it has carried out deep dives in specific areas, such as on air quality benefits from meeting Net Zero commitments over the period from 2020 to 2050, but that carrying out similar work across the full span of Government programmes on an annual basis would be technically difficult.39

The NAO reports that, by not tracking spend across its work on air quality, government risks being unable to evaluate the relative cost-effectiveness of its spending on the issue. The NAO highlighted the example of government’s preparations for EU Exit, where it found that a lack of spending information at a cross-government level created risks to financial management, programme management, and public accountability.40 We have seen similar weaknesses in government’s approach to Net Zero, with neither the Department for Business, Energy & Industrial Strategy nor HM Treasury collating information on the total costs and benefits of government policies that contribute to achieving Net Zero.41 UK100 told us that it believes government may miss out on opportunities for significant cost savings as a result of more cross-cutting policy implementation if investments are not clearly delineated, and claimed that it had identified that better integrating clean air and Net Zero policies could save £1.6 billion a year on the cost of delivering Net Zero.42

Defra and DfT wrote to us to provide a breakdown of funding through the Joint Air Quality Unit and the Air Quality & Industrial Emissions programme. They also provided a summary of cross-government initiatives that affect air quality; these include work by Defra and DfT, as well as the Department for Business, Energy and Industrial Strategy, the Department for Levelling Up, Housing and Communities, and the Department of Health and Social Care. They explained that while Defra attempts to anticipate and model what the long-term reductions in air pollutants as a result of other department’s policies and initiatives may be, their estimates tend to be subject to uncertainty because it is difficult to predict the level levels of uptake, and other factors that will influence how pollution is reduced in practice. They told us that, given how difficult it can be to determine the precise air pollution reductions associated with net zero policies and other important programmes 36 Q 54 37 C&AG’s Report, para 4 38 C&AG’s Report, para 1.16 39 Q 33 40 C&AG’s Report, para 1.18 41 Committee of Public Accounts, Achieving Net Zero: Follow up, Forty-First Report of Session 2021–22, HC 642, 2 March 2022 42 LAQ0004 Tackling local air quality breaches 13 such as active travel, it would be consequently challenging to assign any meaningful estimates of public expenditure on each component of action that results in air pollution emission reductions. They agree that it is important to have robust procedures in place to ensure they are accountable for how money is spent on programmes in each Department, but believe it would not be proportionate to maintain ongoing detailed tracking of the air quality components of policies affecting air pollution across government, especially if the resulting estimates were subject to uncertainties. They told us that their priority is to ensure that their respective policies dovetail to secure multiple benefits, and to estimate the real-world outcomes and bene

National Highways retains responsibility for addressing air quality issues on the parts of the Strategic Road Network that pass through urban areas. It told us that, in setting its measures, it needs to ensure it does not do anything that displaces traffic onto other roads, which would shift where exceedances occur and risk displacing heavy traffic onto roads managed by local authorities.44 It told us that it manages these risks both at the national level, through working with the seven sub-national transport bodies, and at a local level, through considering signage options and working with local authorities where sections of the strategic road network are in a clean air zone.45 However, UK100, a network of local government leaders, told us that many of their members have found that “effective engagement with National Highways is difficult, and they struggle to find out information from them or gain tangible support from National Highways for air quality action.”46 The potential impact on local roads is considered as part of the assessment of the viability of air quality measures on the strategic road network, but as National Highways does not currently publish the criteria by which it judges viability, it is not possible to confirm the extent to which these considerations have affected decision making.47

Government expects that all parts of the UK will eventually become compliant with the NO2 limits as a result of wider changes in the transport sector such as greater uptake of electric vehicles.48 There are some local authorities where no viable measures can be identified that will bring NO2 concentrations below legal limits before it is expected to become ‘naturally’ compliant.49 Government told us it is keen to do more develop a clearer set of viability criteria for local authorities in these situations.50

The Joint Air Quality Unit estimates that a targeted vehicle upgrade scheme would need to upgrade 34% to 89% of frequent vehicles to bring forward compliance by two to four years.51 Government has recently withdrawn grants that were available to support people purchasing electric cars; it told us that this was due to the scheme exceeding its goals, and that funding for electric vehicles will now focus instead on infrastructure.52 43 Follow-up response submitted by Defra and DfT dated 11 July 2022 44 Qq 10, 21 45 Q 42 46 LAQ0004 47 C&AG’s Report, 3.15 48 C&AG’s Report, 1.14 49 C&AG’s Report, 3.8 50 Q 36 51 C&AG’s Report, paras 2.5, 3.19 52 Q 24 14 Tackling local air quality breaches

In addition to working with local authorities, the Department for Transport and the Department for Environment, Food & Rural Affairs needs to ensure it is working with other sectors with either an interest in, or an influence on, air quality, such as the Department for Business, Energy and Industrial Strategy and the Department for Levelling Up, Housing and Communities.53 Clean Air in London also highlighted to us the need to view the Government’s plans, spending and action, or lack thereof, to tackle air pollution in the wider context of: ‘One air’, covering both local air pollution and greenhouse gases.54 Similarly, UK100 highlighted the potential benefits of taking an integrated approach to clean air and net zero, while also warning that there are some areas where local authorities will need to carefully consider their approaches to ensure that policies do not have unintended consequences – as experienced with the promotion of diesel vehicles as more fuel efficient, which led to increased levels of NO2, worsening local air quality.55

The Department for Transport highlighted that local authorities are seeing addressing air quality not as a compliance issue, but as something to be considered more broadly as part of transport and local regeneration policies.56 We also heard about a pilot project working with GPs to provide advice on air quality in local communities, and about how the local air quality grants programme provides support for education initiatives in schools.57 Meeting the 2030 targets

Existing policy measures will not be sufficient to achieve most of the 2030 emissions ceilings (Figure 1). Defra told us that Government will soon publish a draft national air pollution control plan to set out policies and measures designed to bring the UK into compliance for 2030. It told us that these plans will build on existing programmes of continuous improvement, such as environmental permitting and work with industry around industrial emissions. Defra told us that building on these existing bodies of work gives some assurance over the feasibility of its proposed measures, but that it also intends to use a consultation period to further test the plans ahead of publication in September.58 53 Q 32 54 LAQ0003 55 LAQ0004 56 Q 40 57 Qq 55, 60 58 Q 2 Tackling local breaches of air quality Part One 23 1.13 Existing policy measures will not be sufficient to achieve most of the 2030 emissions ceilings and government is developing plans for the new policies needed (Figure 4). Projections submitted to the EU in 2019 indicated that targets would be missed, but did not include (as required by the EU) a full modelled scenario showing how compliance with all of the emission reduction commitments could be achieved. Government plans to publish an update to the UK’s National Air Pollution Control Programme in September 2022, in which it expects to outline in detail the measures required to achieve its emissions ceilings. Defra told u sT tahactk tlhienreg alroe cteaclh aniicra ql aunad lity breaches 15 behavioural challenges to reducing emissions of particulate matter, including because of the potential impact of increased energy prices on domestic wood-burning. Figure 4 Figure 1: UK UpKr porjoejecctteedd e memissiiosnssi oconms pcaoremd tpo aermeisdsi otnos ceemilinigsss iino 2n0s3 0ceilings in 2030 The latest government projections show that existing policy measures are insufficient for the UK to achieve most of its 2030 emissions ceilings Emissions (kt) 700 600 500 400 300 20

The ex3p Seormei seounrcecs oef t hoesef p otlluhtanets aNre exOclud2ed frpomr thoe tgotarl eamimssionms for ethe psuurpogsesg ofe asssetsssin gt chompaliatn cep waith sEmti sstioinsm Ceielingtsa. Fobr elxeamspl e,f or addressing most agricultural emissions are excluded from the targets for nitrogen oxides and for non-methane volatile organic compounds, and aircraft emissions issues of poobrey oand ithre laqndiung aandl tiatkey-of f hcycale varee ex cbludeede fonr all . Soeev thee Nra-tioonapl Emtisismion Ciesilintgsi cRe.g ulIatinons 220108 f1or 7a c omgporehvenesivre lnist.ment estimated that Source: National Audit Offi ce analysis of Department for Business, Energy & Industrial Strategy data available from: https://naei.beis.gov.uk/data/data-selector the clean air zones to be introduced by local authorities would take up to three years to implement, and indicated that non-charging measures should only be considered if they delivered compliance as fast or faster than this benchmark, with all measures implemented by 2021. However the National Audit Office found that, as of 1 April 2022, the 17 local authorities still in the process of implementing measures had been involved in the Programme for 4.5 years on average, and that two had been in the Programme for more than six years.59

Ammonia emissions have remained broadly stable since 2007, with the latest data implying that the UK missed its 2020 ceiling for this pollutant.60 We heard from Defra that it only became clear that this target would be missed when the annual projections were published in 2021, and that it has applied for a legal adjustment to take account of new emissions sources that have emerged since the target was set.61 Addressing ammonia emissions will require significant behavioural change in the agricultural sector, which accounts for around 87% of ammonia emissions.62 Government has not set further targets to 2040 for Ammonia through the Environment Act, but has instead focussed on targets for particulate matter, which is believed to be the air pollutant of greatest harm to human health.63 We heard that significant steps have been taken to address particulate matter pollution in recent months, such as the introduction of restrictions on the sale of wet wood and the phasing out of traditional house coal for domestic use, and that progress will be monitored and adjusted through annual projections.64 59 C&AG’s Report, para 3.23 60 C&AG’s Report, para 10 61 Q 16 62 Q 3 63 C&AG’s Report, para 1.7 64 Qq 71–73 16 Tackling local air quality breaches