Air Quality Planning Hierarchy
By Sean Graham, WKC Group
Pollutants in areas of low air quality can be hazardous and dangerous to people, especially to those with respiratory illnesses. The impact of air can therefore be significant to human health and the environment.
National frameworks and policies, along with regional and local plans are set out and explained below which should be followed for planning consideration for a new development with respect to air quality.
National Planning Policy Framework (NPPF)
The national planning policy framework (NPPF) published 27th March 2012 and revised 19th February 2019 sets out planning requirements and how these are expected to be applied. The NPPF provides a framework for the development of housing and other occupied facilities.
Paragraph 170 (e) of the NPPF advises planning policies to contribute and enhance the natural and local environment by:
preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans.
Paragraph 181 goes on to state:
Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement. So far as possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.
National Planning Practice Guidance (NPPG)
The national planning practice guidance (NPPG) published 6th March 2014 and revised 1st November 2019 provides guidance on how the impact of a new development on air quality can be managed by planning. The NPPG adds context to the NPPF and should be read together.
Regional Plan – The London Plan
The London Plan published March 2016 is an overall strategic plan which sets out development plans for planning decisions in London.
With reference to air quality, Policy 7.14 in the London Plan states:
The Mayor recognises the importance of tackling air pollution and improving air quality to London’s development and the health and wellbeing of its people. He will work with strategic partners to ensure that the spatial, climate change, transport and design policies of this plan support implementation of his Air Quality and Transport strategies to achieve reductions in pollutant emissions and minimize public exposure to pollution.
It goes on to list how development proposals should manage noise by:
- minimise increased exposure to existing poor air quality and make provision to address local problems of air quality (particularly within Air Quality Management Areas (AQMAs) and where development is likely to be used by large numbers of those particularly vulnerable to poor air quality, such as children or older people) such as by design solutions, buffer zones or steps to promote greater use of sustainable transport modes through travel plans;
- promote sustainable design and construction to reduce emissions from the demolition and construction of buildings following the best practice guidance in the GLA and London Councils’ ‘The control of dust and emissions from construction and demolition’;
- be at least ‘air quality neutral’ and not lead to further deterioration of existing poor air quality (such as areas designated as Air Quality Management Areas (AQMAs)).
- ensure that where provision needs to be made to reduce emissions from a development, this is usually made on-site. Where it can be demonstrated that on-site provision is impractical or inappropriate, and that it is possible to put in place measures having clearly demonstrated equivalent air quality benefits, planning obligations or planning conditions should be used as appropriate to ensure this, whether on a scheme by scheme basis or through joint area based approaches;
- where the development requires a detailed air quality assessment and biomass boilers are included, the assessment should forecast pollutant concentrations. Permission should only be granted if no adverse air quality impacts from the biomass boiler are identified.
It then states that Boroughs should have policies that:
- seek reductions in levels of pollutants referred to in the Government’s National Air Quality Strategy having regard to the Mayor’s Air Quality Strategy;
- take account of the findings of their Air Quality Review and Assessments and Action Plans, in particular where Air Quality Management Areas have been designated.
Each Borough will have their own local planning policies to adhere to in conjunction with the national and regional planning policies as described below.
Air Quality Planning Hierarchy