Greater Manchester Clean Air Plan Consultation Document

Consultation runs from 8 October to 3 December 2020
Find out more and get involved at cleanairgm.com
About this document
This document sets out the proposals for the GM Clean Air Plan, which are being consulted on between 8 October and 3 December 2020.
It presents the policies that have been developed, as well as explaining which parts of the policies you can have your say on. At the end of each section, you’ll find the questions relevant to that section, that are asked in the consultation.
The policies for consultation have been agreed by the 10 Local Authorities of Greater Manchester, who are responsible for the GM Clean Air Plan. Throughout this document, when Greater Manchester or GM is used to describe the decision-making body for the proposals, it refers to the 10 Local Authorities of Greater Manchester.
The GM Clean Air Plan proposals are a collaboration between the 10 Greater Manchester Local Authorities. The proposals have been coordinated by Transport for Greater Manchester.

Contents
About this document
Foreword by Councillor Andrew Western, Green-City Region Lead and Leader of Trafford Council
Overview of the plan
What is a Clean Air Zone?
Where will the Clean Air Zone cover?
How will it operate?
The daily charges are:
Funding to upgrade to complaint vehicles
Vehicle finance
Try before you buy hackney scheme
Introduction and background
Why are we producing a Clean Air Plan?
What about COVID-19?
Why this plan?
The journey so far
What is the consultation about?
Additional information about taxis: hackney carriages and private hire vehicles
Greater Manchester Charging Clean Air Zone
Clean Air Zone at a glance
What is a Clean Air Zone?
Where will the Clean Air Zone cover?
How will it operate?
The daily charges are:
Scope
Enforcement
Discounts and exemptions
Funding to upgrade to compliant vehicles
Summary of funding
Vehicle finance
Proposed support at a glance
Funding to support bus operators – Clean Bus Fund
Retrofit
Replacement
Eligibility
Management of funds
Greater Manchester’s Zero Emission Bus Fleet Ambition
Funding to support HGVs, vans, minibuses and coaches – the Clean Commercial Vehicle Fund
HGVs
Vans
Minibuses (which are not a GM-licensed taxi or PHV or used on a GM-registered
bus service)
Coaches and buses (which are not used on a GM-registered bus service)
Eligibility
Management of funds
Funding to support hackney carriages and private hire vehicles – Clean Taxi Fund
Hackney carriages
Additional Government funding
Try before you buy hackney scheme
Private hire vehicles
Private hire wheelchair accessible vehicle or minibus
Non-wheelchair accessible private hire vehicle:
Additional Government funding
Eligibility
Management of funds
Electric vehicle charging infrastructure for hackney carriages and private hire vehicles
Minimum Licensing Standards
Hardship fund
Fraudulent activity and misappropriation
Impacts and overall opinion
Overall Clean Air Plan impacts
COVID-19 impact
Equalities
Equality impact assessment
How to get involved and have your say
Who can take part?
Where can I get more information?
How do I respond?
Access to all
What happens to my response?
Appendix 1 - Clean Air Zone vehicle categories and minimum  emission standards as set out in the UK Government’s  Clean Air Zone Framework
Appendix 2 – Consultation questionnaire

Foreword by Councillor Andrew Western, Green-City Region Lead and Leader of Trafford Council

Now more than ever, we are thinking about the air that we breathe.

Air pollution affects us all, but particularly our poorest communities, those with health problems, older people, and children. It’s also damaging our economy.

At the start of the pandemic, lockdown led to a huge improvement in air quality across our city-region, with reduced traffic on our roads and many choosing to cycle or walk.
 
We’ve been able to experience what a future with cleaner air might look like if we tackle the vehicle emissions that expose us all to harmful nitrogen dioxide (NO2).

But as restrictions have been reduced and more vehicles have returned to the roads, the levels of air pollution are quickly returning. Many sites are once again above legal limits across Greater Manchester.

As part of our efforts to build back better from the pandemic, we want everyone to continue enjoying the benefits of improved air quality.

Our Clean Air Plan is an important part of our post-lockdown recovery, cleaning up our commercial vehicles and providing bus operators and hackney carriage and private hire drivers with access to funding to move to a modern, cleaner fleet.

It will help us reach legal limits of NO2 as soon as possible, by 2024, making our city-region a cleaner, greener place to live, work and grow old. Where we can all breathe more easily.

We’re now asking businesses and residents across Greater Manchester and beyond to give their views and help shape the final plan. At the same time, we are further considering the ongoing impacts of the pandemic.

The plan remains a progressive and ambitious strand of our green road to recovery. It proposes:
•	A Greater Manchester-wide charging Clean Air Zone covering all ten local authority areas – the largest outside London.
•	A comprehensive package of funding support to help Greater Manchester businesses upgrade to cleaner vehicles before that zone is introduced.

It’s the result of a tremendous amount of hard work and continues Greater Manchester’s proud history of collaboration.

During the public "conversation" in 2019 we had thousands of responses – and nearly 70% of individuals who responded were supportive of the proposals.

Since then we’ve used that feedback to make some key changes to the plans:
•	Adjusted the proposed daily charges and made some changes to the proposed Clean Air Zone boundary.
•	Increased our ask of government funding to more than £150 million, with £41 million already committed.
•	Developed supporting financing schemes so Greater Manchester businesses can access funding support in a way that suits them.
•	Proposed a wide range of temporary and permanent exemptions and discounts to limit the impact on key industries.

The Greater Manchester Council Leaders and I believe that the resulting plan is the right one, to clean up the air we all breathe now, but also to protect future generations. It will support Greater Manchester’s plans to build back better and greener.

This plan will impact all of our lives. I hope you will set some time aside to get involved, fill out our questionnaire, and help shape the final plan we submit to government.

Help us get it right. Let’s clean up our air together.

Overview of the plan
The proposed GM Clean Air Plan includes launching and operating a GM-wide Clean Air Zone (CAZ), with a number of temporary and permanent discounts and exemptions for some vehicle types. Private cars and motorbikes are not included in the scheme. As well as that, the proposals include a package of support funding, to help upgrade vehicles across Greater Manchester.
What is a Clean Air Zone?
This is a designated area which certain higher pollution vehicles would pay a charge to drive.
Vehicles which do not comply with the required emissions standards would pay a daily charge for each day on which they drive into, out of, within or through the Clean Air Zone. Failure to pay the daily charge would result in the issue of a penalty charge notice, requiring an additional payment of £120.
A Clean Air Zone is not the same as a Congestion Charge Zone. The purpose of a Clean Air Zone is to improve air quality by encouraging drivers to upgrade to a cleaner vehicle. It is not designed to tackle congestion.
The GM Clean Air Zone will launch in Spring 2022. You can check if your vehicle is compliant by using the GM vehicle checker cleanairgm.com/vehicle-checker
Where will the Clean Air Zone cover?
All roads within Greater Manchester (GM) will be included in the Clean Air Zone, with the exception of those roads managed by Highways England, such as motorways and trunk roads, and you can see this in detail by visiting cleanairgm.com/clean-air-zone-map
How will it operate?
The CAZ will operate 7 days a week, 24 hours a day. Those vehicles liable to pay the charge will use the Government's online portal to do so.
Discounts and exemptions will be put in place for some vehicle types. Some exemptions are temporary, some are permanent, some are for vehicles licensed with the Greater Manchester Authorities.
The daily charges are:
•	Buses and coaches - £60
•	Hackney carriages/private hire vehicles - £7.50
•	HGVs - £60
•	Vans - £10
Funding to upgrade to complaint vehicles
Greater Manchester is requesting a package of funding from Government totalling over £150m to support owners or registered keepers of non-compliant vehicles with the cost of upgrading to vehicles that would not incur a charge. Of the total request, so far £41m has been confirmed by Government and further awards are anticipated.
This funding aims to mitigate negative social and economic effects on businesses and individuals most affected by the GM CAZ.
The funding proposals are:
•	A Clean Commercial Fund to provide financial support for the upgrade of non-compliant vans and HGVs, minibuses and coaches, which will be targeted to support smaller local businesses, sole traders, individuals and the charity/voluntary sector.
•	A Clean Taxi Fund to provide financial support for the upgrade of non-compliant GM-licensed hackney carriage and private hire vehicles.
•	A Clean Bus Fund to provide financial support for the upgrade of non-compliant buses registered to run services across GM.
•	A Hardship Fund to support individuals, companies and organisations who are considered to be the most vulnerable to the potential negative economic impacts of the GM CAZ.
This means that owners or registered keepers of non-compliant vehicles that would be subject to the GM CAZ charges may be eligible to apply for financial support towards upgrading to a compliant vehicle (subject to meeting eligibility criteria and state aid restrictions).
Vehicle finance
The proposals also include an offer to access affordable finance (through a panel of GM appointed finance providers) for eligible applicants who require assistance in funding the cost of upgrading to a compliant HGV, van, coach, minibus, GM-licensed hackney carriage or GM-licensed private hire vehicle. It has been designed to address some of the potential reasons that finance might typically be refused.

Try before you buy hackney scheme
To tackle the barriers to switching to electric vehicles, GM is proposing a ‘Try Before You Buy’ initiative for GM-licensed hackney carriage drivers.
Electric vehicle charging infrastructure for hackney carriages and private hire vehicles GM is proposing a £6.5m network of 40 taxi-only rapid electric vehicle charging points tailored to locations to support zero emissions capable taxis to operate across GM.
The funding to upgrade to compliant vehicles is explained in pages 22 - 33.

Introduction and background
Why are we producing a Clean Air Plan?
Government is working with more than 60 local authorities across the UK to improve air quality. Greater Manchester has received a direction from Government to introduce a Clean Air Plan to bring nitrogen dioxide (NO2) levels within legal limits in "the shortest possible time".
GM needs to take action to improve air quality, now and for future generations. Pollution from road traffic is linked to a wide range of serious illnesses and conditions. It contributes to the equivalent of around 1,200 deaths a year in GM alone.
As air pollution does not respect geographic boundaries, the ten GM local authorities (Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Trafford, Tameside, Wigan) have come together to produce a joint plan. This co-ordinated approach is seen as the most effective way to deal with a problem that affects all parts of GM and will not be remedied on a site-by-site or district-by district basis. The Clean Air Plan is being co-ordinated by Transport for Greater Manchester (TfGM).
The core aim of the GM Clean Air Plan (GM CAP) is to remove all concentrations of NO2 that have been forecast to exceed the legal limits "in the shortest possible time and by 2024 at the latest", in line with Government's direction to Greater Manchester.
The GM Authorities are now consulting on the key elements of the zone, including the proposed daily charges, discounts and exemptions, and the proposals for funding packages to help local businesses upgrade to cleaner vehicles.
What about COVID-19?
The Government has asked Greater Manchester to continue to progress the Clean Air Plan, and to undertake the consultation, based on proposals developed before the COVID-19 pandemic that showed compliance would be achieved by 2024.
GM is assessing the possible effects of COVID-19 on the Clean Air Plan and the consultation is asking questions about the impact of COVID-19 on impacted groups. This information will inform future decisions on each aspect of the final plan.
Why this plan?
This plan has been in development since 2018 when a Strategic Outline Case was submitted to Government. It has been designed to meet Government’s "primary and secondary success criteria". You can find out more detail through the technical documentation available at cleanairgm.com/technical-documents
The GM local authorities undertook a process to identify and assess the interventions that could be implemented to reduce annual mean NO2 concentrations on the roads they manage, following Government guidance.
The Strategic Case of the Outline Business Case (OBC) sets out a robust case for change, based upon local modelling. It revealed a much wider problem with current NO2 levels at the roadside than initially identified by Government. It sets out the approach GM took to identifying a preferred option for achieving compliance. As part of this process, GM identified a number of possible solutions, which were assessed against primary and secondary success criteria based upon modelling and analysis; engagement with stakeholders and professional experts, and the use of a Multi-Criteria Analysis tool to assess the performance of each option against the success factors and relative to each other. A full economic appraisal was then undertaken of the best performing options. More detail is available in the Options Appraisal Report, Appendix 1 to the Strategic Case.
GM has identified a preferred option based on which of the best performing options delivers compliance in the "shortest possible time" and that improves air quality with the least detrimental impact on GM. This means GM has taken account of its wider responsibilities to its people and businesses, and has sought to develop proposals that bring the most benefit, with the least negative impact. In particular, evidence suggests that some of GM’s most vulnerable residents are most likely to suffer the effects of poor air quality. This plan improves air quality for those residents without damaging their quality of life in other ways.
The GM CAP is supported by an evidence base consisting of modelling, analysis and research. The approach to developing the evidence base, along with key research findings, is set out in the Data, Evidence and Modelling Consultation Summary Report. Further information can be found in a series of Technical Reports4 produced to support the consultation, and in Technical Notes setting out analysis, research and modelling carried out since the OBC to support the development of the
consultation option.

Once the GM Clean Air Plan is in place, it is estimated that GM will have NO2 within the legal limit of 40 micrograms per cubic metre (ug/m3) by 2024. If we do not all take action, the dirtiest vehicles will remain on GM’s roads longer, meaning that the estimated date of legal compliance is 2027, which is not the "shortest possible time".

The journey so far
The Clean Air Plan process has a number of development stages. These are outlined below:
•	March 2018 – Strategic Outline Business Case:
o	96 measures identified in a long list
o	Sifting exercise reduced this to 17 and then 14 measures
•	October 2018 – Target Determination
o	Agreed with Government the extent of the Air Quality problem
o	Modelling shows that illegal levels of NO2 will span all GM Local Authorities in 2021 if no action is taken
•	October 2018 to March 2019 – Measure development
o	Options combining the shortlisted measures were developed and assessed to determine which delivered compliance in the shortest possible time
•	March 2019 – Outline Business Case
o	GM determined the best performing option to reduce NO2 across GM
o	A charging Clean Air Zone (CAZ) category C
o	Funds to support business upgrade
o	Electric Vehicle Infrastructure and Promotion
o	Sustainable Journeys (behaviour change activity)
o	Consider Loan Finance
•	May/June 2019 – Public conversation on the proposals
o	Over 3,300 responses
o	Nearly 70% of individuals who responded supported the proposals
o	Businesses thought the proposals would have a negative effect on the economy (54%), and two-thirds felt they would have a negative impact on their business
•	July 2019 – Government response
o	Government directed all 10 Greater Manchester authorities to implement a charging Clean Air Zone Category C with additional measures and provided a further £36m funding
o	Further options appraisal information
•	July 2019 to March 2020 – Development of the proposals 
o	38 briefing notes and eight technical reports submitted to Government
o	Ongoing dialogue with Government about the funding packages to support impacted groups
o	Ongoing development of the proposals
•	March 2020 – Government response and COVID-19
o	Government provide initial tranche of £41m funding to support businesses to upgrade to cleaner vehicles
o	COVID-19 pandemic leads to nationwide "lockdown"
•	October 2020 – Statutory consultation
o	GM Clean Air Plan consultation running for eight weeks
•	February 2021 TBC – Consultation findings to be reported
o	Including assessment of COVID-19 impacts on GM Clean Air Plan
•	TBC – Final Business Case and GM Clean Air Funds open
•	Spring 2022 TBC – GM Clean Air Zone launches

What is the consultation about?
Based on local analysis by GM, the 10 GM authorities have been legally directed by Government to introduce a Category C Clean Air Zone (CAZ) across the region. This means that buses, coaches, hackney carriages, private hire vehicles, HGVs, vans and minibuses that do not meet the required emission standards would be required to pay a daily charge for driving into or within the CAZ.

Private cars and motorbikes are not included. Some permanent and temporary discounts and  exemptions are proposed for some vehicles that otherwise would be required to pay the daily charge.

In addition to the plans for implementation of the charging CAZ, GM is sharing details of the wider proposals as part of this consultation, including funding to support impacted vehicles. This will help to ensure that respondents have as much information as possible to inform them, before they answer the questions in this consultation.

Additional information about taxis: hackney carriages and private hire vehicles
Hackney carriages and private hire services are a significant part of GM’s transport offer. In 2018, the Greater Manchester authorities agreed to collectively develop a common set of Minimum Licensing Standards (MLS) for these services that cover the whole of GM.

To make sure there is as much certainty and clarity as possible for the trade on any proposed changes they might need to make to their vehicles, as a result of both the CAP proposals and the proposed GM MLS, the consultation on both these policies is running at the same time.

For more information on the MLS, visit gmtaxistandards.com

There are two types of vehicles that the general public call "taxis"
•	Hackney carriages are licensed to pick up people who wave for the vehicle to pull over and stop at the roadside or from an authorised taxi rank. Hackney carriages are often purpose built "black cabs" but don't have to be (depending on local policy) and they may also do pre-booked work.
•	Private hire vehicles (PHVs) are only permitted to pick people up via a pre-arranged booking. This might be over the phone, on the web or using an app based booking system.
In this document, if referring to a specific vehicle type, "hackney carriage" or "private hire vehicle" will be used. If referring to this form of public transport generally, "taxi" will be used.

Greater Manchester Charging Clean Air Zone
Clean Air Zone at a glance
What is a Clean Air Zone?
This is a designated area which certain higher pollution vehicles would pay a charge to drive.
Vehicles which do not comply with the required emissions standards would pay a daily charge for each day on which they drive into, out of, within or through the Clean Air Zone. Failure to pay the daily charge would result in the issue of a penalty charge notice, requiring an additional payment of £120.
A Clean Air Zone is not the same as a Congestion Charge Zone. The purpose of a Clean Air Zone is to improve air quality by encouraging drivers to upgrade to a cleaner vehicle. It is not designed to tackle congestion.
The GM Clean Air Zone will launch in Spring 2022. You can check if your vehicle is compliant by using the GM vehicle checker cleanairgm.com/vehicle-checker
Where will the Clean Air Zone cover?
All roads within Greater Manchester (GM) will be included in the Clean Air Zone, with the exception of those roads managed by Highways England, such as motorways and trunk roads, and you can see this in detail by visiting cleanairgm.com/clean-air-zone-map
How will it operate?
The CAZ will operate 7 days a week, 24 hours a day. Those vehicles liable to pay the charge will use the Government's online portal to do so.
Discounts and exemptions will be put in place for some vehicle types. Some exemptions are temporary, some are permanent, some are for vehicles licensed with the Greater Manchester Authorities.
The daily charges are:
•	Buses and coaches - £60
•	Hackney carriages/private hire vehicles - £7.50
•	HGVs - £60
•	Vans - £10
Failure to pay the daily charge would result in a penalty charge notice (PCN) of £120, in addition to the daily charge. See section 4.4 for more information

Scope
Greater Manchester has been directed by Government to introduce charging Clean Air Zone Category C across the region. This means that owners or registered keepers of the following vehicle types will be required to pay a daily charge for driving inside the zone, if the vehicle does not comply with the vehicle emission standards in Government’s CAZ Framework:
•	Licensed hackney carriages
•	Licensed private hire vehicles (PHVs)
•	Buses
•	Coaches
•	Minibuses
•	Light Goods Vehicles (LGVs) such as vans
•	Heavy Goods Vehicles (HGVs)

The CAZ vehicle categories and minimum emission standards as set out in the Government's CAZ Framework are provided in Appendix 1. Vehicles which meet the emissions standards will not be subject to charges. Private cars and motorbikes will not be charged under these plans.

A central Government database (vehicle checker) will determine if a vehicle is in scope for a charge. This vehicle checker is primarily linked to the Driving and Vehicle Licensing Agency (DVLA) database holding information on the classification of vehicles (often found on a V5C document). The vehicle checker can be accessed at cleanairgm.com/vehicle-checker. Any queries relating to the classification of vehicles are a matter for the registered keeper and the DVLA.

The GM CAZ will be implemented through a Road User Charging Scheme Order with an anticipated start date of Spring 2022.

GM anticipates that once the CAZ has been implemented, compliance for NO2 levels will be reached by 2024 and the CAZ will remain in full operation until at least the second half of 2026.

GM intend to review the need for a CAZ following two consecutive years of compliance, so if in 2026 it’s found that GM has met the legal limit value for NO2, and there is confidence the limits will continue to be maintained, GM will write to the Government to notify them of GM's intention to revoke the daily charge and decommission the GM CAZ.

Table 1 provides a summary of the key characteristics of the proposed GM CAZ.

Table 1: Key characteristic of the GM CAZ

Clean Air Zone Boundary	The proposed boundary of the CAZ would follow the existing administrative boundary of Greater Manchester as closely as possible, excluding the Strategic Road Network (SRN)8 which is managed by Highways England. The CAZ boundary has been set with the principle that signage would be clear so that vehicle drivers who do not wish to enter the CAZ can take an alternative route. There is a proposal to exclude a small stretch of the A555 from the junction with the B5166 in the west to the junction with A523 in the east (from Styal Road to the Macclesfield Road junction). 
This is to enable movements between Poynton and Handforth (which are towns located in the district of Cheshire East), to continue uncharged, given the expectation that implementing a charge would result in local journeys returning to the roads that the A555 was designed to reduce.
See the full detailed boundary by visiting cleanairgm.com/cleanair-zone-map	
Clean Air Zone: Times of Operation	24 hours a day, 7 days a week, 365 days per year	
Clean Air Zone: Vehicles Affected	Hackney carriages
Private hire vehicles
Buses
Coaches
Minibuses
Vans
HGVs	
Clean Air Zone: Exemptions	Certain vehicle types may be eligible for exemptions as detailed in section 4.4.	
Clean Air Zone: Discounts	Certain vehicle types may be eligible for discounts as detailed  in section 4.4.	
Clean Air Zone: Daily Charges	Daily charges would apply for each day a non-compliant vehicle is used within the GM CAZ, with one charge imposed per vehicle, per "Charging Day" (midnight to midnight), however many journeys the vehicle makes within the GM CAZ in that  24-hour period.
•	Hackney carriages – £7.50
•	Private hire vehicles – £7.50
•	Buses – £60
•	Coaches – £60
•	Minibuses – £10
•	Vans – £10
•	HGVs – £60
Owners or registered keepers of non-compliant vehicles used within the GM CAZ will be required to pay the relevant charge via a central Government payment portal. Government intends that a user can pay 7 days in advance, including the journey date (Charging Day), up to 7 days in advance after the journey date including the journey date (Charging Day).	
Penalty for non/late payment of CAZ charge	£120 (in addition to the daily charge) will be applied to all relevant vehicles. This will be reduced to £60 (plus the daily charge) if paid within 14 days of the Penalty Charge Notice being issued.	

Some of the key characteristics of the GM CAZ are specified by Government, but you can have your say on the elements identified in the questions below.

Q1: The proposed Clean Air Zone Boundary would follow the existing administrative boundary of Greater Manchester as closely as possible.
Do you have any comments on the proposed boundary?

Q2: The Clean Air Zone would operate 24 hours a day, seven days a week, signage would be used to clearly identify the Clean Air Zone, and the daily charges would apply from midnight to midnight.
Do you have any comments on these proposals?

Q3: Please tell us what you think of the proposed daily charges for each of the vehicles?
a) Buses / Coaches and HGVs – £60
b) Hackney carriages and private hire vehicles – £7.50
c) Vans and Minibuses – £10

Q3a: Do you have any comments on the proposed charges?

Enforcement 
Enforcement of the Greater Manchester Clean Air Zone will be undertaken in line with the prescribed process set out within Road User Charging Schemes (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2013 (the Penalty Charges Regulations).

The GM CAZ will use a network of automatic number plate recognition (ANPR) cameras to identify non-compliant vehicles. Where the ANPR system identifies non-compliant vehicles travelling in the GM CAZ and charges have not been paid, owners or registered keepers will be notified of a penalty charge of £120 via a Penalty Charge Notice (PCN).

If the person or organisation named on the PCN pays the amount specified on the PCN within 14 days of service of the PCN (as indicated on the PCN), the amount payable is reduced to £60 (payable in addition to the daily charge).

If the person or organisation named on the PCN does not either pay the amount specified on the PCN or make a representation in relation to it (on certain grounds specified in the Penalty Charges Regulations), within 28 days of the date of service of the PCN then a Charge Certificate would be issued and the penalty charge would be increased by 50% (as set out in the Penalty Charges Regulations) to £180 (payable in addition to the daily charge).

A representation against a PCN cannot be made once the Charge Certificate has been served. However, the person or organisation named on the Charge Certificate can make a Statutory Declaration if they did not receive the PCN or they have not received a response to a
representation against the PCN.

A representation against a PCN is considered and if it is accepted the PCN will be cancelled and any sums paid in respect of the PCN will be reimbursed. If the representation is rejected the person or organisation named on the PCN may appeal to an independent adjudicator within 28 days of rejection of the representation.

Where a charge certificate has been served and is not paid within 14 days of service, enforcement action may be taken to recover the increased penalty charge along with the daily charge. If these steps are taken, the associated additional costs would increase the sum sought from the individual or organisation.

Data collected through the ANPR system will be used for the purposes of managing the GM CAZ and will be handled in accordance with the General Data Protection Regulations (GDPR) and Data Protection Act 2018.

Discounts and exemptions
In general, all non-compliant vehicles in the same category will be required to pay the Clean Air Zone charge. However, there will be certain circumstances where discounts or exemptions from a charge
will be appropriate.

Government’s CAZ Framework sets out a series of permanent exemptions, which are those vehicles that will be exempt from charges for all CAZs across the country, including the Greater Manchester
CAZ. These exemptions are in place because some types of vehicle are particularly difficult or uneconomic to adapt to comply with the Framework's requirements. The exemptions also cover vehicles that are engaged in unique or novel operations. The national, permanent exemptions that apply to all CAZs are set out in Table 2.

Table 2 - Permanent exemptions to CAZ charges, set by Government

Historic vehicles

Permanent exemptions	Description	Rationale	Further information	
Historic vehicles	Vehicles with a "historic" vehicle tax class (vehicles built or first registered more than 40 years ago).	Exempt due to age and unsuitability for compliant retrofitting.	A database of these nationally exempt vehicles will be managed via the central Government payment portal, so vehicles will be automatically exempt with no additional action required by the owner or registered keeper.	
Military vehicles
	Vehicles in use by UK Armed Forces.
	Exempt from charges by virtue of Section 349 of the Armed Forces Act 2006. 		
Disabled Passenger Vehicle 	Vehicles within the DVLA Disabled Passenger Vehicle tax class, used by organisations providing transport for disabled people.	This group of vehicles may include a range of specialist and/or novel or adapted vehicles, where it may generally not be practical to upgrade to a vehicle compliant with the emission standards of the GM CAZ.		
Specialist Emergency Service Vehicles	Specialist vehicles in use by emergency services, such as aerial ladders and major incident command vehicles.	This group of vehicles may include a range of specialist and/or novel or adapted vehicles where it may generally not be practical to upgrade to a vehicle compliant with the emission standards of the GM CAZ.	It is proposed that a locally managed database of vehicles exempted will be developed in liaison with emergency services.	

In addition to stipulating national exemptions, Government’s CAZ Framework allows local authorities to consider additional exemptions or discounts based on particular local circumstances, specifically
highlighting the need to work with local emergency services to understand the vehicles they use and what they use them for. Further local exemptions and discounts can be proposed on this basis so long as they do not undermine GM’s ability to achieve compliance "in the shortest possible time".
GM is proposing the following local exemptions and discounts for the GM CAZ. These exemptions and discounts fall into three categories:
•	Permanent local exemptions (set out in Table 3)
•	Temporary local exemptions (set out in Table 4)
•	Permanent local discounts (set out in Table 5)

Table 3: Permanent local exemptions proposed by Greater Manchester 

Permanent local exemptions	Description	Rationale	Further information	
Specialist heavy goods vehicles	Certain types of
heavily specialised
HGVs, such as
certain vehicles used
in construction or
vehicle recovery.	This group of vehicles
includes certain novel
or adapted road going
HGVs of a particularly
specialised nature,
meaning it may not be
practical to upgrade
to a vehicle compliant
with the emission
standards of the GM
CAZ.	It is proposed that
owners or registered
keepers of specialist
HGVs will need
to apply for this
exemption, as there is
no national database
of these vehicles.	
Non-road-going vehicles	Certain types of nonroad
going vehicles
which are allowed to
drive on the highway
such as agricultural
machines; digging
machines, and mobile
cranes.	This group of vehicles
includes a range of
specialist and/or novel
or adapted vehicles,
where it may generally
not be practical to
upgrade to a vehicle
compliant with the
emission standards of
the GM CAZ.	It is proposed that
owners or registered
keepers of non-road
going vehicles not
identified through
DVLA vehicle
classification will
need to apply for this
exemption.	
Vehicles used by emergency services 	Certain types of
vehicles used by
emergency services
front line emergency
and certain nonemergency
vehicles.	This group of vehicles
includes a range of
vehicles, associated
with front line
emergency response,
and where it may
generally not be
practical to upgrade
to a vehicle compliant
with the emission
standards of the
GM CAZ, which are
not captured by the
national exemption.	It is proposed that
a locally managed
database of vehicles
exempted will be
developed in liaison
with emergency
services.	
Community minibuses	Those operating
under a permit under
section 19 or section
22 of the Transport
Act 1985, issued by a
body designated by
the Secretary of State.	These vehicles provide
important access
to employment,
education and training
for people who may
otherwise be isolated,
including those with
mobility issues and
located in areas with
poor public transport
accessibility. They also
facilitate inclusion in
social and community
activities.	It is proposed that
owners or registered
keepers of community
minibuses will need
to apply for this
exemption, as there is
no national database
of these vehicles.	
Showmen’s Guild vehicles	Fairground/funfair
vehicles which are
registered with the
Showmen’s Guild.	This group of vehicles
includes a range of
specialist and/or novel
or adapted vehicles,
where it may generally
not be practical to
upgrade to a vehicle
compliant with the
standards of the GM
CAZ.	It is proposed that
the Showmen’s Guild
will notify GM of the
vehicles registered with the Showmen’s Guild and that these vehicles will be exempted.
	
Driving within the zone because of a road diversion	Vehicles driving within
the zone because of
a road diversion who
would otherwise not
have entered the GM
CAZ.
Applies only while
the diversion is
active and subject
to non-compliant
vehicles being on the
designated diversion
route.	This exemption is
aimed at protecting
road safety and
recognises that
vehicles may enter the
GM CAZ for reasons
outside of the driver’s
control.
The exemption will
apply to vehicles
which enter the GM
CAZ as a direct result
of a road diversion
only.	It is intended that no
additional action will
be required by the
owner or registered
keeper of a noncompliant
vehicle
driving on a diversion
route who would
otherwise not have
entered the GM CAZ.	
Disabled tax class vehicles	Vehicles used by, or
for the purposes of a
disabled person which
are exempt from
vehicle tax.	This exemption is
complementary to the
vehicle tax exemption
for Disabled Tax Class
vehicles.
An exemption
certificate will have
been secured for
vehicles within this
group, following a
successful application
to the Driver and
Vehicle Licensing
Authority (DVLA)
for exemption from
vehicle tax. The
vehicle must be
used solely for the
purposes of the
disabled person.	A database of these
nationally exempt
vehicles will be
managed via the
central Government
payment portal,
so vehicles will be
automatically exempt
with no additional
action required by the
registered keeper.	

Q4: To what extent do you agree or disagree with the permanent local exemptions proposed by Greater Manchester?

Q4a: Why do you say this?

Table 4: Temporary local exemptions proposed by Greater Manchester

The proposed local temporary exemptions are not expected to change the GM Clean Air Plan’s date of compliance for legal NO2 levels across Greater Manchester.

Temporary local exemptions	Description	Rationale	Further information	
Vans and
minibuses
(which are
not a licensed
hackney carriage
or PHV or used
to provide a
registered bus
service)	Light Goods Vehicles
(vans) and minibuses
which are not used as
a licensed taxi, PHV
or on a registered bus
service, will be eligible
for a temporary
exemption until 31
December 2022.
After 31 December
2022, non-compliant
vehicles will be
charged.	GM evidence indicates
that the cost and
availability of new,
second and third hand
compliant vans will
not provide a viable or
an affordable option
for many operators
(especially for the
smallest businesses
and sole traders)
to upgrade to a
compliant vehicle in
2022, given the scale
of the GM CAZ.
Introducing a charge
in 2022 risks many
operators having to
switch from using
a van to a pre-Euro
VI diesel car or stop
trading.
Given the number of
vans operating in GM,
there is also a high
risk of there being
insufficient time in
advance of 2022 to
administer the funding
required to support
affected parties to
upgrade to compliant
vans.	As proposed, this
temporary exemption
for vans and minibuses
does not affect the
projected year of legal
Limit Value compliance
with the GM CAZ in
place, or the number of
exceedances in 2023.
It is proposed that
this exemption will be
managed centrally, so
eligible vehicles will be
automatically exempt
with no additional
action required by the
registered keeper.	
GM-licensed
Wheelchair
Accessible
hackney
carriages & PHVs	Wheelchair Accessible
hackney carriages and
accessible private hire
vehicles (PHVs), which
are licensed to one of
the 10 GM Authorities,
as of the 3 December
2020 will be eligible
for a temporary
exemption until 31
December 2022.
After 31 December
2022, non-compliant
vehicles will be
charged.	Wheelchair accessible
hackney carriages and
private hire vehicles
offer a vital service
for disabled people
and are often the
only mode of travel
available to them.
26% of taxi users
report that they have
a health problem or
disability that limits
their day-to-day
activities, and 26%
of taxi users over 65
say that they cannot
use buses due to a
disability.
The cost of upgrade
to a wheelchair
accessible vehicle
(WAV) is high and
availability of secondhand
vehicles is
poor (especially for
London-style hackney
carriages).
The application of
GM CAZ charges in
2022 could therefore
affect disabled
people’s access to taxi
services, by reducing
the number of
wheelchair accessible
vehicles operating in
the region.	As proposed, a
temporary exemption
for wheelchair
accessible hackney
carriages and PHVs
does not affect the
year of compliance
or the number of
exceedances in 2023.
It is expected that
this exemption will
be facilitated through
Government’s Hackney
Carriage and PHV
Centralised Database,
which forms part
of the wider digital
infrastructure that
is being developed
to support the
introduction of the
CAZ.
Therefore, no
additional action will
be required by the
registered owner.	
Coaches and
buses registered
to a business
address within
GM and not used
on a registered
bus service
within GM.	Coaches and buses
registered to a
business address
within GM and not
used on a registered
bus service within GM
will be eligible for a
temporary exemption
until 31 December
2022.
After 31 December
2022, non-compliant
vehicles will be
charged.	Although compliant
Euro VI coaches have
been available since
2013, the majority
(67%) of the fleet
operating within GM
is not compliant with
the GM CAZ emission
standards.
This is because coaches
have a long running
life and upgrade to a
compliant vehicle is
very expensive.
69% of coach operators
are small businesses
and have very small
fleets of 1-5 vehicles.
There is a risk that,
even with funding
support, coach
operators cannot
reasonably comply with
the GM CAZ emission
standards by 2022
and that this creates a
risk of reduced coach
operations.
In comparison to
buses, retrofit solutions
are also relatively
immature, affecting
availability.
This in turn risks
affecting accessibility
and the provision of
services for vulnerable
groups, particularly
children, elderly people
and those on low
incomes.	Analysis shows
that coaches make
up under 0.5% of
total traffic and
as proposed, a
temporary exemption
for coaches is not
projected to affect the
year of compliance
or the number of
exceedances of the
legal Limit Value in
2023.
Owners or registered
keepers of coaches
and buses registered
to a business address
within GM and not
used on a registered
bus service within GM
will need to apply for
this exemption, as
there is no database of
these vehicles.	
Outstanding
finance or
lease on noncompliant
vehicles	Non-compliant
vehicles subject
to finance or
lease agreements
entered into before
3 December 2020
which will remain
outstanding at the
time at which the
GM CAZ becomes
operational, will
be eligible for a
temporary exemption
until the agreement
ends or until 31
December 2022,
whichever is sooner.
After 31 December
2022, non-compliant
vehicles will be
charged.	A move to a compliant
vehicle is not
considered feasible
due to outstanding
finance, which was
entered into before
information on the GM
CAZ had been made
publicly available.	Owners or registered
keepers of noncompliant
vehicles
which are subject to
outstanding finance
or lease agreements
at the time at which
the GM CAZ becomes
operational will need
to apply for this
exemption, as there is
no national database
of these vehicles.	
Limited supply
(awaiting
delivery of
a compliant
vehicle)	Owners or registered
keepers of noncompliant
vehicles
that can demonstrate
they have placed an
order for a compliant
replacement vehicle
or retrofit solution,
will be eligible for a
temporary exemption
until such a time as
they are in receipt
of the compliant
replacement vehicle
or retrofit solution,
or for 12 weeks,
whichever is sooner.	Upgrade to a
compliant vehicle may
not be immediately
possible due to an
issue with the supply
of a compliant vehicle
or retrofit solution
on order, which is
considered outside
of the control of the
applicant.	Registered keepers of
non-compliant vehicles
who can evidence that
they have placed an
order for a compliant
replacement vehicle or
retrofit solution, which
is yet to be received,
will need to apply for
this exemption, as
there is no national
database of these
vehicles.	

Q5: To what extent do you agree or disagree with the temporary local exemptions proposed by Greater Manchester?

Q5a: Why do you say this?

Table 5: Permanent local discounts proposed by Greater Manchester

Permanent local discounts	Description	Rationale	Further information	
PHVs (owned
or exclusively
contracted by
one person)
licensed to one
of the 10 GM
Local Authorities
and also used as
a private car	Owners or registered
keepers of noncompliant
PHVs
which are also used
as a private car will be
eligible to apply for
a discounted charge
of 5/7 of the weekly
total (proposed to
be £37.50 per week)
from 2022.	This responds
to previous
feedback from the
"conversation" in 2019
which highlighted
the large proportion
of PHVs that are also
used as a private car
when not in service,
and private cars will
not be subject to
charges under the GM
CAZ.
The discounted
charge is based upon
the proportion of the
week that vehicles
could reasonably be
expected to be in
service.	Owners or registered
keepers of noncompliant
PHVs,
licensed to one of
the 10 GM Local
Authorities, which are
also used as a private
car will need to apply
for this discount.	
Leisure vehicles
in private
ownership
(>3.5t)	Owners or registered
keepers of leisure
vehicles (>3.5t) in
private ownership
(e.g. motor caravan
(>3.5t), motorised
horse box (>3.5t)),
and registered to an
address in GM for
not less than 12 full
consecutive calendar
months prior to the
date of application,
will be eligible to
apply for a discounted
charge.
The vehicle would
be eligible for
consideration for a
charge equivalent to
the van daily charge
(proposed to be £10
a day), rather than
the HGV daily charge
(proposed to be £60
a day).
The discount will be
subject to providing
evidence that the
vehicle is not used for
commercial purposes.	A small proportion
of HGVs will be in
private ownership,
largely used for leisure
purposes, e.g. motor
caravans (>3.5t) and
motorised horseboxes
(>3.5t). This group
of vehicles includes
a range of specialist
and/or adapted
vehicles, which are
often bought second
or third hand where it
may generally not be
feasible to upgrade
to a vehicle compliant
with the emission
standards of the GM
CAZ.
This approach
recognises feedback
received during
the "Clean Air
Conversation".	Owners or registered
keepers of leisure
vehicles in private
ownership which have
a gross weight above
3,500kg will need to
apply for this discount.	

Q6: To what extent do you agree or disagree with the permanent local discounts proposed by Greater Manchester?

Q6a: Why do you say this?

Funding to upgrade to compliant vehicles
Summary of funding
Greater Manchester is requesting a package of funding from Government totaling over £150m to support owners or registered keepers of non-compliant vehicles with the cost of upgrading their
vehicles. This is so they are compliant with the emission standards required by the implementation of a GM CAZ, so as not to be subject to a charge. Of the total request, so far £41m has been confirmed by Government and further awards are anticipated.

This funding aims to mitigate negative social and economic effects on businesses and individuals most affected by the GM CAZ. The funding proposals are:

•	A Clean Commercial Fund to provide financial support for the upgrade of non-compliant vans and HGVs, minibuses and coaches, which will be targeted to support smaller local businesses, sole traders, individuals and the charity/voluntary sector.
•	A Clean Taxi Fund to provide financial support for the upgrade of non-compliant hackney carriages and private hire vehicles licensed with the Greater Manchester Authorities.
•	A Clean Bus Fund to provide financial support for the upgrade of non-compliant buses registered to run services across GM.
•	A Hardship Fund to support individuals, companies and organisations who are considered to be the most vulnerable to the potential negative economic impacts of the GM CAZ.

This means that owners or registered keepers of non-compliant vehicles that would be subject to the GM CAZ charges may be eligible to apply for financial support towards upgrading to a compliant vehicle (subject to meeting eligibility criteria and state aid restrictions).

What is state aid?
State aid is any advantage granted by public authorities through state resources on a selective basis to any organisation that could potentially distort competition and trade in the European Union (EU).

A breakdown of the total funding ask of Government per measure, and the current funding position, can be seen in Table 6 below:

Table 6: Summary of funding by measure
Vehicle	Total ask (excl Delivery Costs)	Funding position (incl. Delivery Costs)	
Clean Bus Fund	c.£30m	£15.4m funded (retrofits)	
Clean Commercial Vehicle Fund	c.£98m	£14.7m funded 	
Clean Taxi Fund	c.£28m	£10.7m funded	
Total	c.£156m	£41m funded	

GM is proposing that financial support is:
•	Only offered for vehicles that do not comply with the relevant GM CAZ emission standards and are not eligible for a permanent national or local exemption;
•	Provided for the replacement of a non-compliant vehicle with a compliant vehicle on a "like-for-like" basis – i.e. financial support will not be available to facilitate upgrade of a non-compliant vehicle to a compliant vehicle of a different vehicle type (e.g. van to HGV) or Euro Category (e.g. N1 to N2) (see Appendix 1, Table A1 for details of vehicle types and Euro Categories);
•	Facilitated directly with accredited suppliers of retrofit and replacement upgrade options, to ensure maintenance of a comprehensive audit trail, accountability for public funding and to reduce the risk of fraudulent activity and misappropriation of funds;
•	With the exception of the Clean Bus Fund, limited to a maximum of 10 vehicles per applicant, with a maximum of eight vehicles for hackney carriages and five vehicles for HGV retrofit;
•	Managed and administered centrally on behalf of the 10 GM authorities; and
•	Only available insofar as it complies with UK government and European requirements, including but not limited to, State Aid Regulations

Vehicle finance
In Greater Manchester’s Outline Business Case, it was proposed that a scheme to offer loans at preferential rates for those taking advantage of the Clean Air funds would be investigated.

Feedback received as part of the "conversation" in 2019 indicated that vehicle finance is needed to help some owners upgrade their vehicle.

The Vehicle Finance measure has been developed to support individuals, companies and organisations to upgrade to a compliant vehicle.

It will provide access to affordable finance (from a GM appointed panel of finance providers) for eligible applicants who require assistance in funding the cost of upgrading to a compliant HGV, van, coach, minibus, GM-licensed hackney carriage or GM-licensed private hire vehicle. It has been designed to address some of the potential reasons that finance might typically be refused, including:
•	Affordability – the ability or otherwise of applicants to meet finance re-payments.
•	Thin credit file – applicants not having enough information in their credit reports to generate a high enough credit score to be approved for credit.

Vehicle Finance will work alongside the Clean Commercial Vehicle Fund and Clean Taxi Fund to offer eligible owners of a non-compliant vehicle the option of either a lump sum grant or a finance contribution towards vehicle finance for upgrade to a compliant vehicle. Applicants will
therefore be able to choose the option which best suits their individual circumstances. These options are as follows:
•	Lump sum grant contributing to the cost of replacement or retrofit the applicant funds the remaining costs with their own capital or financing arrangements; or
•	Vehicle Finance contributing to the cost of financing a replacement vehicle through the GM scheme, through either a lease or Hire Purchase – the applicant pays monthly for an agreed finance period.

All financial support set out in the following sections includes a proposed amount of grant funding and an alternative figure, available as a contribution towards vehicle finance. Eligibility criteria for both of these options is detailed in the Clean Commercial Vehicle Fund and Clean Taxi Fund sections.

In addition to meeting the eligibility criteria those seeking vehicle finance will need to:
Hold a UK bank account in the name of the applicant or business
• Consent to the Lending Body carrying out credit reference searches on their credit history
• Require a 10% deposit contribution (cash or vehicle trade-in value)
• Note that lending decisions will rest with a GM appointed panel of finance providers, and
• Recognise that whilst they may be eligible for a non-repayable grant through Clean Air Funds, they may not be able to secure a vehicle finance agreement due to their individual circumstances.

Proposed support at a glance
Greater Manchester is requesting a package of funding from Government totalling over £150m
to support owners or registered keepers of non-compliant vehicles with the cost of upgrading to
vehicles that don’t incur a charge. Of the total request, so far £41m has been confirmed by
Government and further awards are anticipated.

This funding aims to mitigate negative social and economic effects on businesses and individuals most affected by the GM CAZ.

Buses
Proposed support for those eligible and have a non-compliant bus which is used on a registered bus service in GM.
•	Grant of up to £16,000 per vehicle for replacement or retrofit.
•	Bus operators will not be offered access to the vehicle finance scheme.
•	No proposed cap on number of vehicles per applicant.

Hackney carriages
Proposed support for those eligible with a non-compliant hackney carriage licensed with the Greater Manchester Authorities.
•	£10,000 per vehicle for a running costs grant or a contribution for vehicle finance, for a replacement zero emissions capable wheelchair accessible vehicle; or
•	£5,000 grant towards an LPG retrofit.
•	There is also a UK government grant available of up to £7,500 for purchasing a new zero emissions capable vehicle.
•	Limit of 8 vehicles per applicant.

Private hire vehicles
Proposed support for those eligible with a non-compliant private hire vehicle licensed with the Greater Manchester Authorities.
•	£1,000 grant or vehicle finance contribution towards replacement to a compliant petrol or diesel vehicle; or
•	£2,000 grant or vehicle finance contribution towards replacement to a hybrid or plug-in hybrid; or
•	£2,500 running costs grant for replacement with a zero emissions capable vehicle; or
•	£5,000 grant or vehicle finance contribution towards replacement of a minibus or WAV.
•	Limit of 10 vehicles per applicant

Light Goods Vehicles (vans)
Proposed support for those eligible with a noncompliant van.
•	Available for vehicles registered in GM, small and micro businesses, sole traders, charities and social enterprises, private owners, initially targeted towards individuals and the smallest businesses with the oldest vehicles.
•	A grant of £3,500 per vehicle for replacement or vehicle finance contribution.
•	Limit of 10 vehicles per applicant.

Heavy Goods Vehicles
Proposed support for those eligible with a noncomplaint HGV
•	Available for vehicles registered in GM, small and micro businesses, sole traders, charities and social enterprises, private owners, initially targeted towards individuals and the smallest businesses with the oldest vehicles.
•	A grant of up to £5,500 per vehicle for replacement or vehicle finance contribution. Limit of 10 vehicles per applicant; or
•	A grant of up to £16,000 per vehicle for retrofit. Limit of five vehicles per applicant.

Coaches
Proposed support for those eligible with a noncompliant coach.
•	Available for vehicles registered in GM, small and micro businesses, sole traders, charities and social enterprises, private owners, initially targeted towards individuals and the smallest businesses with the oldest vehicles.
•	Grant of up to £16,000 per vehicle for replacement or retrofit or vehicle finance contribution.
•	Limit of 10 vehicles per applicant.

Minibuses
Proposed support for those eligible and have a noncompliant minibus.
•	Available for vehicles registered in GM, small and micro businesses, sole traders, charities and social enterprises, private owners, initially targeted towards individuals and the smallest businesses with the oldest vehicles.
•	A grant of up to £5,000 for replacement or vehicle finance contribution for replacement of minibuses (which are not licensed taxis or PHVs or used on a registered bus service
in GM).
•	Limit of 10 vehicles per applicant.

Funding to support bus operators – Clean Bus Fund
Retrofit
In the Outline Business Case (OBC), Greater Manchester set out that the Clean Bus Fund would provide financial support to, where possible, retrofit buses which have an older engine than Euro VI. This funding would apply to buses registered to run services across across GM.
In March 2020, Government awarded £14.7m initial funding to retrofit buses running services in GM that have older engines which are not compliant with the GM CAZ emission standards. Government has confirmed that this funding for bus retrofit should be awarded as soon as possible and so consultation feedback is not being sought on this aspect of the fund.
This means that a grant of up to £16,000 towards retrofit to a compliant standard via a Clean Vehicle Retrofit Accreditation Scheme (CVRAS) certified system will be available. Financial support will be available to vehicles less than 13-years old that have operated for a minimum of six months on a GM-registered bus service.
Replacement
In the OBC, GM estimated 350 buses could not be retrofitted, and it would be for the owners of those vehicles to find a solution. This estimate has now been revised, based on further evidence, and it has been established that there are more than 500 non-compliant buses that cannot be retrofitted operating in GM. GM is requesting c.£9m of funding from Government to support the replacement of non-compliant vehicles operating on registered bus services in GM.
Using this funding, GM proposes that a grant of up to £16,000 will be available towards the cost of replacing a non-compliant bus registered to run services across GM with a compliant vehicle which meets GM CAZ emission standards.
Eligibility
Applicants would need to be able to demonstrate that:
•	They are the registered operator for a registered bus service operating in Greater Manchester;
•	They have not been in receipt of, or be subject to a current application for, public sector clean air funding in GM or elsewhere
•	in the United Kingdom for upgrade (retrofit or replacement) of the same vehicle(s) that is to be upgraded through the GM Clean Bus Fund;
•	They have been operating on a registered bus service, within GM, for not less than 12 full consecutive calendar months prior to the date of application;
•	The vehicle has been registered to the applicant for not less than 12 consecutive calendar months prior to the date of application, evidenced through the V5C Registration Document;
•	The vehicle has a valid MOT, road tax and suitable insurance to operate a bus passenger service at the date of application;
•	The upgraded vehicle will be compliant with the GM CAZ emission standards as a minimum; and
•	The upgraded vehicle will continue to operate on a registered bus service within GM for a minimum of five years following receipt of funding. If it is replaced or taken out of service in GM it must be replaced by a vehicle which meets the same emissions standard and passenger capacity, or better, e.g. a compliant double decker bus must be replaced with another compliant
Management of funds
If the fund is oversubscribed by the deadline, it is proposed that, in addition to applicants meeting the eligibility criteria, an additional process could be applied that seeks to prioritise air quality benefits, i.e. funding could initially be targeted towards the upgrade of the oldest vehicles first.

Greater Manchester’s Zero Emission Bus Fleet Ambition
Greater Manchester is developing proposals to deliver its strategic objective of a zero-emission bus fleet. In its March 2020 budget, Government announced £5bn worth of funding for buses and
cycling. Greater Manchester is looking to secure additional funding from this pot to help deliver this ambition.

Q7: Do you have any comments on the proposed Clean Bus Fund? (e.g. eligibility criteria, funding amounts)

Q7a: Do you believe you are eligible to access this fund?

Q7b: Would the proposed fund meet your needs e.g. support you to upgrade your vehicle(s)? if not, why not?

Q7c: Do you have any comments about the proposed management of the funds? (e.g. if over-subscribed the oldest vehicles could be targeted first)

Funding to support HGVs, vans, minibuses and coaches – the Clean Commercial Vehicle Fund
Greater Manchester has asked Government for £98m for the Clean Commercial Vehicle Fund (CCVF), to provide financial support for the upgrade of vans and HGVs, minibuses and coaches, which will be targeted to support smaller local businesses, sole traders and the voluntary sector.
HGVs
In March 2020, the Government awarded GM £7.6m as an initial tranche of funding towards the upgrade of HGVs, for retrofitting vehicles currently in use so that they subsequently meet the GM CAZ emission standards, or replacing non-compliant vehicles with compliant vehicles. Funding will be available to both commercial and private owners or registered keepers of non-compliant HGVs.
Retrofit
GM is proposing that a grant of up to £16,000 towards retrofit to a compliant standard via a Clean Vehicle Retrofit Accreditation Scheme (CVRAS) certified system will be available.
Replacement
Alternatively, a replacement grant will be available. Dependent on vehicle size, the following funding amounts are proposed:
•	44t articulated up to £4,500 per vehicle
•	32t rigid up to £5,500 per vehicle
•	26t up to £4,500 per vehicle
•	18t up to £3,500 per vehicle
•	<7.5t up to £2,500 per vehicle
Vehicle finance
Access to the Vehicle Finance offer will be available for replacement of non-compliant vehicles, offering an average finance contribution of £5,500 with the finance contribution per vehicle capped at £8,000. For more information about the Vehicle Finance measure, please see section 5.2.

Vans
GM is proposing that Government provides £80m of funding to support GM businesses and organisations to replace non-compliant vans with vehicles that meet the GM CAZ emission standards.
Retrofit
Subject to the award of Government funding to GM, it is proposed that a replacement grant of up to £3,500 per vehicle will be available.
Vehicle finance
Alternatively, access to the Vehicle Finance offer will be available for replacement of non-compliant vehicles, offering an average finance contribution of £3,500, with the finance contribution per vehicle capped at £5,000. For more information about the Vehicle Finance measure, please see section 5.2.

Minibuses (which are not a GM-licensed taxi or PHV or used on a GM-registered
bus service)
In March 2020, Government awarded £2m as an initial tranche of funding towards replacing non-compliant vehicles with those that meet the GM CAZ emission standards.
Replacement 
GM is proposing that a replacement grant of up to £5,000 per vehicle will be available.
Vehicle finance
Access to the Vehicle Finance offer will be available for replacement of non-compliant vehicles, offering an average finance contribution of £5,000, with the finance contribution per vehicle capped at £7,000. For more information about the Vehicle Finance measure, please see section 5.2.

Coaches and buses (which are not used on a GM-registered bus service)
In March 2020, Government awarded £4.4m as an initial tranche of funding towards the upgrade of coaches, by either retrofitting vehicles currently in use so that they subsequently meet the GM CAZ emission standards, or replacing non-compliant vehicles with compliant vehicles.
Retrofit
GM is proposing that a grant of up to £16,000 towards retrofit to a compliant standard via a Clean Vehicle Retrofit Accreditation Scheme (CVRAS) certified system will be available.
Replacement
Alternatively, a replacement grant of up to £16,000 per vehicle will be available.
Vehicle finance
Access to the Vehicle Finance will be available for replacement of noncompliant vehicles, offering an average finance contribution of £16,000, with the finance contribution per vehicle capped at £23,000. For more information about the Vehicle Finance measure, please see section 5.2.

Eligibility
Applicants for the CCVF would need to be able to demonstrate that they are:
•	A small business
•	A micro business/entity
•	Self-employed/sole trader
•	An entity regulated by the Charity Commission (including registered, active charities and active charities exempted from registration)
•	A social enterprise (including non-profit organisations), or
•	A private owner (owner or registered keeper) of non-compliant vehicles which are not used for commercial purposes.

They must also demonstrate that:
•	They have had a registered address within GM for not less than 12 full consecutive calendar months prior to the date of application 
•	They have not already been in receipt of Government clean air funding for the purpose of upgrade of the same non-compliant vehicle that is the subject of the application, in GM or elsewhere in the United Kingdom
•	They are not in receipt of, or have made a successful application for, an Office of Low Emission Vehicle (OLEV) grant for the acquisition of the same compliant vehicle that is the subject of the GM CCVF application
•	They have not received and do not expect to receive more than 200,000 Euros (or equivalent) of state aid from any source over a period of three fiscal years, if seeking funding support for the upgrade of a non-Road Freight Transport vehicle. This figure is inclusive of any discounts, exemptions, grants or Vehicle Finance secured through the GM CAP or any other funding source, including the grant applied for.
•	The non-compliant vehicle must be registered to the Applicant, or an authorised employee, director or trustee of the Applicant/ organisation, for not less than 12 consecutive calendar months prior to the date of application, evidenced through the V5C Registration Document provided with the application
•	The non-compliant vehicle must have been registered to an address in GM for not less than 12 consecutive calendar months prior to the date of application, evidenced through the V5C Registration Document provided with the application
•	The non-compliant vehicle has a valid MOT (or annual test)19, road tax and insurance, as appropriate for the vehicle use/organisation, at the date of application
•	The non-compliant vehicle will be replaced by a compliant vehicle, or upgraded via a Clean Vehicle Retrofit Accreditation Scheme (CVRAS) certified emission reduction system, to meet GM CAZ emission standards
•	Where in private ownership, the vehicle must not be used for commercial purposes
•	The business/organisation/trader/private owner will continue to have a base location in GM for not less than 12 full consecutive calendar months following receipt of funding.

Management of funds
It is proposed that financial support subject to available funds will be available through sequential funding rounds. These would target funding towards individuals and the smallest businesses within GM, and would be initially directed towards those who are likely to be most economically vulnerable to the impacts of the GM CAZ. The proposed funding rounds are set out below:
•	An initial round of funding will be open to eligible owners or registered keepers of a non-compliant vehicle of Euro VI standard or older, with the exception of small businesses
•	A second round of funding would be open to eligible owners or registered keepers of a non-compliant vehicle, with the exception of small businesses
•	Subject to available funds, a third round of funding would be open to eligible owners or registered keepers of a non-compliant vehicle, including small businesses.

Q8: Do you have any comments on the proposed Clean Commercial Vehicle Fund?

Q8a: Do you believe you are eligible to access this fund?

Q8b: Would the proposed fund meet your needs e.g. support you to upgrade your vehicle(s)? If not - why not?

Q8c: Do you have any comments about the proposed management of the funds? (e.g. financial support could be available for the smallest businesses)

Funding to support hackney carriages and private hire vehicles – Clean Taxi Fund
The Clean Taxi Fund will provide a financial mechanism to support the upgrade of non-compliant hackney carriages and private hire vehicles (PHVs) licensed with the Greater Manchester Authorities.
Hackney carriages
GM is requesting £10.4m funding from Government towards the replacement or retrofit of non-compliant hackney carriages.
Using this funding, it is proposed that the following grants would  be available:
•	A grant of up to £10,000 will be available towards the running costs of a purpose-built wheelchair accessible zero emissions capable vehicle (ZEC), or
•	Access to vehicle finance towards the cost of upgrade to a purpose-built wheelchair accessible ZEC vehicle, offering an average finance contribution of £10,000, with the total finance contribution capped at £14,000, or 
•	A grant of £5,000 towards the LPG retrofit of a Euro 5 vehicle less than ten years old will also be available.
Additional Government funding
In addition to the proposed funding under GM CAP, Government also have funding of up to £7,500 available for those looking to purchase a new ZEC hackney carriage. This is available in addition to the GM CAP funding.  For more information, visit  gov.uk/plug-in-car-van-grants
Try before you buy hackney scheme
The Greater Manchester Clean Air Plan and the proposed GM MLS will require hackney carriages to meet stricter emissions standards. This means a significant proportion of the trade will need to upgrade their vehicles to meet these emissions standards to avoid a charge. The GM Five-Year Environment Plan sets out the ambition for GM to be carbon neutral by 2038, an objective that will be supported by the uptake of ZEC vehicles. Research has been done with the trade to explore their thoughts and expectations with these ambitions.
To tackle the barriers to switching to electric vehicles, GM is proposing a "Try Before You Buy" initiative for GM-licensed hackney carriage drivers. The opportunity to hire and assess the vehicle before making an investment should help to address identified uncertainties about operating costs, range anxiety and availability of charging infrastructure. The GM scheme would aim to encourage a 40% conversion rate of those taking up the trial.
Private hire vehicles
In March 2020, Government awarded £10.2m as an initial tranche of funding towards replacing non-compliant vehicles with compliant alternatives to meet the GM CAZ emission standards.
The following grants will be available to apply for:
Private hire wheelchair accessible vehicle or minibus
•	A grant of £5,000 towards the cost of a compliant 6+ seater vehicle,
•	OR access to vehicle finance, offering an average finance contribution of £5,000, with the finance contribution per vehicle capped at £7,000.
Non-wheelchair accessible private hire vehicle: 
•	A grant of £1,000 towards the cost of a compliant internal combustion engine vehicle
•	OR access to vehicle finance, offering an average finance contribution of £1,000, with the finance contribution per vehicle capped at £2,000.
•	OR a grant of £2,000 towards the cost of a compliant hybrid or plug-in hybrid
•	OR access to vehicle finance, offering an average finance contribution of £2,000, with the finance contribution per vehicle capped at £3,000.
•	OR a grant of £2,500 towards the running costs of a ZEC vehicle
Additional Government funding
In addition to the proposed funding under GM CAP, Government also have funding of up to £3,000 available for those looking to purchase a new ZEC private hire vehicle. This is available in addition to the GM CAP funding. For more information, visit  gov.uk/plug-in-car-van-grants
Eligibility
Applicants for the Clean Taxi Fund would need to be able to demonstrate that:
•	They have been trading and operating as a licensed hackney carriage or private hire driver or operator with one of the 10 Local Authorities in GM for not less than 12 uninterrupted consecutive calendar months prior to the date of application; 
•	They are the owner or registered keeper of a non-compliant vehicle which is and has been licensed for the purposes of hackney carriage or private hire services with one of the 10 Local Authorities in GM for not less than 12 uninterrupted consecutive calendar months prior to the date of application; 
•	The non-compliant vehicle to be upgraded has been registered to the applicant for not less than 12 uninterrupted consecutive calendar months prior to the date of application, evidenced through the V5C Registration Document provided with the application;
•	The non-compliant vehicle will be replaced by a compliant vehicle, or upgraded via a Clean Vehicle Retrofit Accreditation Scheme (CVRAS) approved emission reduction system, to meet GM CAZ emission standards;
•	The non-compliant vehicle has current road tax and business insurance at the date of application, with evidence of such provided with the application;
•	They will declare that they will remain licensed with one of the 10 GM Local Authorities for the purpose of performing hackney carriage or private hire duties within GM for two years following the receipt of funding; and 
•	They have not received and do not expect to receive more than 200,000 Euros (or equivalent) of state aid from any source over a period of three fiscal years, if seeking funding support for the upgrade of a non-Road Freight Transport vehicle. This figure is inclusive of any discounts, exemptions, grants or Vehicle Finance secured through the GM CAP or any other funding source, including the grant applied for.
Management of funds
It is proposed that funding will be offered on a first-come-first-served basis, once an applicant has evidenced that the eligibility criteria are met.
Electric vehicle charging infrastructure for hackney carriages and private hire vehicles
Research has shown taxi drivers are concerned about the ability to charge electric vehicles during shifts. Dedicated electric vehicle infrastructure will be key in supporting the transition to ZEC taxis. 
GM is proposing a £6.5m network of 40 taxi-only rapid electric vehicle charging points tailored to locations to support ZEC taxis to operate across GM. This measure is complementary to the financial support offered through the Clean Taxi Fund, for a running-costs grant for those who upgrade from a noncompliant vehicle to a ZEC vehicle.
This is in addition to £2.4m already in place to deliver 30 rapid chargers, targeted in areas suitable for the taxi trade across Greater Manchester.
Q9a: Do you have any comments on the proposed funds for hackney carriages?
Q9b: Do you have any comments on the proposed funds for private hire vehicles?
Q9c: Do you have any comments on the "Try Before You Buy" initiative?
Q9d: Do you believe you are eligible to access either of these funds?
Q9e: Would the proposed funds / "try before you buy" meet your needs e.g. support you to upgrade your vehicle(s)? If not - why not?
Q9f: Do you have any comments about the proposed management of funds? (e.g. offered on a first-come-first basis once an applicant has evidenced that the eligibility criteria are met)

Minimum Licensing Standards
In the longer term, there is an ambition to move towards a ZEC fleet for hackney carriages and private hire vehicles. This is driven by the GM Five-Year Environment Plan, through which GM aims to be carbon neutral by 2038. To achieve this target, there needs to be a shift to ZEC vehicles over the next decade.

To invest in ZEC vehicles, taxi and private hire vehicle owners require long-term confidence in the local policy landscape, including future interventions and supporting infrastructure. The following dates for ZEC adoption are therefore proposed as part of the Greater Manchester Minimum Licensing Standards consultation.
•	From 2025 all new to license vehicles would need to be ZEC; and
•	From 2028 all vehicles would need to be ZEC, meaning an entirely zero emission hackney/private hire fleet across Greater Manchester by 2029

There is significant overlap between the Greater Manchester Clean Air Plan proposals and the proposed Greater Manchester Minimum Licensing Standards for hackney carriages and private hire vehicles, namely with regard to emissions standards. Therefore, these two consultations are running at the same time to ensure that charging, funding and licensing policy positions are joined-up. You can find more information about the proposals for Minimum Licensing Standards at gmtaxistandards.com

Vehicle finance
Now that you have had chance to consider the vehicle finance offer available for eligible applicants, please consider the following questions:

Q10a: Do you have any comments on the proposed Vehicle Finance Offer (see section 5.2 for more information)
Q10b: To what extent do you agree or disagree that the proposed vehicle finance offer would meet your needs e.g. support you to upgrade your vehicle(s)?
Q10c: Why do you say this?

Hardship fund
Since submission of the OBC and following the feedback received as part of the "conversation" in 2019, GM considers that it is individuals and the smallest businesses who will be most economically affected by the GM CAZ charge, and that the proposed amount of grant funding to help upgrade to a compliant vehicle may not be enough to adequately mitigate the potential adverse economic impacts.

GM is proposing a Hardship Fund of at least £10m to support individuals, companies and organisations who are assessed to be most economically vulnerable to the CAZ charge.

GM is currently considering the scope and scale of support required. This assessment is also being considered in light of the impact of the COVID-19 pandemic. It is possible that the groups affected by the GM CAP may require different levels of financial assistance than had been assessed at the time of the submission of the OBC to Government.

GM knows that the transport sector has already been affected by the pandemic, and Government policies to stem its spread. The sector’s ability to recover from revenue loss, while also being expected to respond to pre-pandemic clean air policy priorities by upgrading to a cleaner fleet, will clearly require further assessment and consideration. Therefore, the consultation is asking questions about the impact of COVID-19 to provide information for a technical briefing note to be submitted to Government to assist in determining the amount of hardship funding to be made available.

Q11a: Do you support a hardship fund? Why do you say this?
Q11b: If you are impacted by the proposed clean air zone daily charges, is there any additional support that you would need?

Fraudulent activity and misappropriation
GM is proposing that if an applicant is found to have abused the application process for the funds, vehicle finance, discounts or exemptions (e.g. falsified information), such that there is a risk of misappropriation, the right is reserved to terminate applications for funding or take enforcement action to recover awarded grants where information provided is not truthful or accurate. 

Furthermore, any applicants found to have abused the application process or made a fraudulent application will not be eligible for any existing GM CAZ exemptions, discounts or financial support and GM will refer the matter to the relevant authorities where applicable.

Impacts and overall opinion
Overall Clean Air Plan impacts
Modelling shows that the current proposals would achieve the required reduction in NO2 levels in the shortest possible time, in the most cost effective way, while minimising the wider impacts on the people and economy of Greater Manchester.

Q12: To what extent do you agree or disagree that air quality needs to be improved in Greater Manchester?
Q13: Having read through the proposals, how confident are you that the Greater Manchester Clean Air Plan will bring roadside nitrogen dioxide (NO2) levels within legal limits "in the shortest possible time and by 2024 at the latest"?
Q13a: Do you have any other comments on the proposals for the Clean Air Plan as set out in the consultation document?
Q14: Taking into account both the Clean Air Zone and the support offered, what would be the likely impact on you/your business/ your organisation?

COVID-19 impact
It was originally thought that the statutory consultation on the Clean Air Zone and the wider proposals would take place earlier in 2020. However, due to the COVID-19 pandemic and the resulting national lockdown, plans to consult were paused. Government has now asked Greater Manchester to continue to progress the Clean Air Plan, and to continue with the consultation, based on proposals developed before the COVID-19 pandemic. Government has also asked that an assessment of the possible impacts of the pandemic on the proposals is undertaken to inform decision-makers in the GM local authorities.

GM is aware that businesses have been impacted by the pandemic, and Government policies to stem the spread of the virus and continue to be impacted. Their ability, particularly of the transport sector, to recover from revenue loss, while also being expected to respond to pre-pandemic clean air policy priorities by upgrading to a cleaner fleet, may require further assessment and consideration. Therefore, the consultation is asking questions about the impact of COVID-19 to inform decisions on the nature and requirements for additional support for those most vulnerable to the Clean Air Zone charge.

Q15a: Which of the following best reflects your trading status as a result of the COVID-19 pandemic?:
•	Have continued trading throughout
•	Currently trading, having temporarily paused – but have resumed trading during the pandemic
•	Paused trading
•	Permanently ceased trading
•	Other, please state
Q15b: Have you or your business received any of the following as a result of the COVID-19 pandemic?: Please select all that apply
•	Coronavirus job retention scheme (aka Furlough)
•	Government-backed accredited loans or finance agreements (aka CBIL / BBLS)
•	Business grants funded by the UK and devolved governments
•	Self-employment income support scheme
•	Other government support
•	Other loans / grants (please specify) 
•	Not applied for any of these schemes 
Q15c: To what extent has the COVID-19 pandemic affected the following aspects of your business?
•	Level of debt 
•	Reserves / Savings
•	Turnover
•	Profitability
Q15d: Please tell us about how the COVID-19 pandemic has affected your ability to meet the proposals outlined within the consultation document.

Equalities
Equality impact assessment
Under equality legislation, there is a requirement to have due regard for the need to:
•	Eliminate unlawful discrimination, harassment and victimisation
•	Advance equality of opportunity between persons who share a relevant protected characteristic, and persons who do not share it
•	Foster good relations between those who have a relevant protected characteristic and those who don’t.
"Relevant protected characteristics" are age; disability; gender reassignment; pregnancy and maternity; race; religion or belief; sex and sexual orientation.
The draft analysis of potential impacts of the Clean Air Plan proposals is set out in the document "Equality Impact Analysis" which is part of the suite of documents available to consultees.
It concludes that the Clean Air Plan proposals would have a high positive impact on children and young people, older people, people from a variety of ethnic backgrounds and pregnant women. It also concludes that there would be a medium adverse impact on men due to the predominance of males working as taxi drivers and bus drivers.
Q16: The Equality Impact Assessment identifies the potential impact on the Clean Air Plan proposals on persons with protected characteristics. Do you have any comments on it?

How to get involved and have your say
Who can take part?
Anyone can get involved to share their views on the proposals to remove all concentrations of NO2 that have been forecast to be above legal limits and to make Greater Manchester’s air cleaner and healthier  for everyone.
Where can I get more information?
The questionnaire is available on cleanairgm.com, where you can also find supporting documents to give you more detailed, technical information on the proposals and sign up for any future updates. 
You can also request hard copies of the consultation document, questionnaire and supporting materials by calling 0161 244 1100.
How do I respond?
You can have your say on the proposals by going to cleanairgm.com to answer the questions in the online questionnaire. 
Alternatively you can:
•	Email your feedback to cleanairgm@aecom.com
•	Give your feedback via telephone on 0161 244 1100  (you will be forwarded through to our independent research organisation AECOM to submit your response)
•	Write/send a completed questionnaire to Freepost RUBS-XRAT-GLBK,  AECOM, 1 New York Street,  MANCHESTER, M1 4HD
All responses will go to AECOM – the independent agency who are managing and analysing the responses.
For further information or to request paper copies of the consultation document and questionnaire, please ring 0161 244 1100 or email info@cleanairgm.com. A pre-paid envelope will be provided along with the paper version of the questionnaire so that you are able to return your completed form to AECOM free of charge.
The consultation is open from Thursday 8 October to 23:59 on Thursday 3 December 2020.
Access to all
If you need to respond to the consultation in a different way, or require the consultation materials in a different format, please contact  info@cleanairgm.com or call 0161 244 1100 to discuss how we can help you. Support for non-English speakers is available on 0161 244 1100.
What happens to my response?
Your response will be independently assessed as part of the consultation.
The outputs of the consultation will be analysed and will be taken into account when finalising the proposals. The consultation findings will be reported in spring 2021.
Once the report is considered by the Greater Manchester local authorities the GM CAP Final Business Case (FBC) will be developed and subject to approval by the 10 Greater Manchester Local Authorities, submitted to Government. Then, subject to Government approval and funding, measures will be introduced from 2021, with the Clean Air Zone being introduced from spring 2022.

Appendix 1 - Clean Air Zone vehicle categories and minimum  emission standards as set out in the UK Government’s  Clean Air Zone Framework
Vehicle type	Euro Category	Minimum CAZ Compliant Euro Emission Standard 	Example vehicles	
Bus	M3 (Gross Vehicle Weight over 500kg and more than 8 sets in addition to the driver)	Euro VI	Public buses (single decker, double decker and midi, coaches (single and double decker)	
Coach		Euro VI		
HGV	N2 (Gross Vehicle Weight over 3500kg and ref. mass over 2610kg)
N3 (Gross Vehicle Weight over 5000kg)	Euro VI	Articulated vehicles, rigid HGVs, flatbed lorries, concrete mixers, 2-axle lorry, some motorised caravans (>3.5t) and motorised horseboxes (>3.5t)	
Minibus	M2 (Gross Vehicle Weight not exceeding 5000kg, reference mass not exceeding 2840kg and more than 8 seats in addition to the driver)	Euro VI (diesel)
Euro IV (petrol)	Minibuses (excluding those which are licensed as a taxi or private hire vehicle – see taxi and private hire vehicles below)	
Van	N1 (Gross Vehicle Weight not exceeding 3500kg and reference mass not exceeding kg)	Euro VI (diesel)
Euro IV (petrol)	Vans (short and long wheelbase), some car derived vans, some light 4x4 utility vehicles and pickups.	
Hackney carriage and private hire vehicle 	Minibus – M2 (Gross Vehicle Weight not exceeding 5000kg, reference mass not exceeding 2840kg and more than 8 seats in addition to the driver)
M1 Passenger vehicle with up to 8 seats in addition to the driver	Euro VI (diesel)
Euro IV (petrol)	Vehicles licensed as hackney carriages and/or private hire vehicles.	

Appendix 2 – Consultation questionnaire
These are the questions included in the consultation questionnaire. They are set out throughout this document at the appropriate points within each section.
Q1: The proposed Clean Air Zone Boundary would follow the existing administrative boundary of Greater Manchester as closely as possible.  Do you have any comments on the proposed boundary? 
Q2: The Clean Air Zone would operate 24 hours a day, seven days a week, signage would be used to clearly identify the Clean Air Zone, and the daily charges would apply from midnight to midnight.  Do you have any comments on these proposals?
Q3: Please tell us what you think of the proposed daily charges for each of the vehicles? a) Buses / Coaches and HGVs – £60 b) Hackney carriages and private hire vehicles – £7.50 c) Vans and Minibuses – £10
Q3a: Do you have any comments on the proposed charges?
Q4: To what extent do you agree or disagree with the permanent local exemptions proposed by Greater Manchester?
Q4a: Why do you say this?
Q5: To what extent do you agree or disagree with the temporary local exemptions proposed by Greater Manchester?
Q5a: Why do you say this?
Q6: To what extent do you agree or disagree with the permanent local discounts proposed by Greater Manchester?
Q6a: Why do you say this?
Q7: Do you have any comments on the proposed Clean Bus Fund? (e.g. eligibility criteria, funding amounts)
Q7a: Do you believe you are eligible to access this fund?
Q7b: Would the proposed fund meet your needs e.g. support you to upgrade your vehicle(s)? if not, why not?
Q7c: Do you have any comments about the proposed management of the funds? (e.g. if over-subscribed the oldest vehicles could be targeted first) 
Q8: Do you have any comments on the proposed Clean Commercial Vehicle Fund?
Q8a: Do you believe you are eligible to access this fund?
Q8b: Would the proposed fund meet your needs e.g. support you to upgrade your vehicle(s)? If not - why not? 
Q8c: Do you have any comments about the proposed management of the funds? (e.g. financial support could be available for the smallest businesses)
Q9a: Do you have any comments on the proposed funds for hackney carriages?
Q9b: Do you have any comments on the proposed funds for private hire vehicles?
Q9c: Do you have any comments on the "Try Before You Buy" initiative?
Q9d: Do you believe you are eligible to access either of these funds?
Q9e: Would the proposed funds / "try before you buy" meet your needs e.g. support you to upgrade your vehicle(s)? If not - why not?
Q9f: Do you have any comments about the proposed management of funds? (e.g. offered on a first-come-first basis once an applicant has evidenced that the eligibility criteria are met)
Q10a: Do you have any comments on the proposed Vehicle Finance Offer (see section 5.2 for more information)
Q10b: To what extent do you agree or disagree that the proposed vehicle finance offer would meet your needs e.g. support you to upgrade your vehicle(s)?
Q10c: Why do you say this?
Q11a: Do you support a hardship fund? Why do you say this?
Q11b: If you are impacted by the proposed clean air zone daily charges, is there any additional support that you would need?
Q12: To what extent do you agree or disagree that air quality needs to be improved in Greater Manchester?
Q13: Having read through the proposals, how confident are you that the Greater Manchester Clean Air Plan will bring roadside nitrogen dioxide (NO2) levels within legal limits "in the shortest possible time and by 2024 at the latest"?
Q13a: Do you have any other comments on the proposals for the Clean Air Plan as set out in the consultation document?
Q14: Taking into account both the Clean Air Zone and the support offered, what would be the likely impact on you/your business/ your organisation?
Q15a: Which of the following best reflects your trading status as a result of the COVID-19 pandemic?: • Have continued trading throughout • Currently trading, having temporarily paused – but have   resumed trading during the pandemic  • Paused trading  • Permanently ceased trading • Other, please state
Q15b: Have you or your business received any of the following as a result of the COVID-19 pandemic?: Please select all that apply • Coronavirus job retention scheme (aka Furlough)  • Government-backed accredited loans or finance agreements   (aka CBIL / BBLS) • Business grants funded by the UK and devolved governments • Self-employment income support scheme  • Other government support • Other loans / grants (please specify)  • Not applied for any of these schemes 
Q15c: To what extent has the COVID-19 pandemic affected the following aspects of your business? • Level of debt  • Reserves / Savings  • Turnover • Profitability Q15d: Please to tell us about how the COVID-19 pandemic has affected your ability to meet the proposals outlined within the consultation document.
Q16: The Equality Impact Assessment identifies the potential impact on the Clean Air Plan proposals on persons with protected characteristics. Do you have any comments on it?