Air Quality SPD
3 National Policy & Practice
3.1 National Planning Policy Framework
The National Planning Policy Framework (NPPF) 2018 sets out the overarching national policy objectives relating to air quality and development. Most notably, it emphasises that development should, wherever possible help to improve local environmental conditions such as air quality. The most relevant paragraphs in respect of air quality are set out below:
- Planning policies and decisions should contribute to and enhance the natural and local environment by:
e) 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 quality;
- Planning policies and decisions should sustain and contribute towards compliancewith relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management AreasandClean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impactsshould be identified, such asthrough 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 Areasand Clean Air Zonesis consistent with the local air quality action plan.
The following paragraph outlines the relationship between the planning process and the environmental permitting system
- The focus of planning policies and decisions should be on whether proposed development is an acceptable use of land, rather than the control of processes or emissions (where these are subject to separate pollution control regimes). Planning decisions should assume that these regimes will operate effectively. Equally, where a planning decision has been made on a particular development, the planning issues should not be revisited through the permitting regimes operated by pollution control authorities.
The following paragraphs recognise the impact of traffic on air quality and health and the benefits of sustainable transport modes
- Transport issues should be considered from the earliest stages of plan-making and development proposals, so that:
d) the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for mitigation and for net gains in environmental quality;
103. The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions and improve air quality and public health. However, opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making.
3.2 National Planning Practice Guidance
National Planning Practice Guidance (NPPG)[2] provides advice to planning authorities on implementing the NPPF, including guidance on how air quality can be considered as part of the planning process, stating that, "Local Plans may need to consider:
- the potential cumulative impact of a number of smaller developments on air quality as well as the effect of more substantial developments;
- the impact of point sources of air pollution (pollution that originates from one place); and,
- ways in which new development would be appropriate in locations where air quality is or likely to be a concern and not give rise to unacceptable risks from pollution. This could be through, for example, identifying measures for offsetting the impact on air quality arising from new development including supporting measures in an air quality action plan or low emissions strategy where applicable.
When deciding whether air quality is relevant to a planning application, considerations may include whether the development would:
- Significantly affect traffic in the immediate vicinity of the proposed development site or further afield. This could be by generating or increasing traffic congestion; significantly changing traffic volumes, vehicle speed or both; or significantly altering the traffic composition on local roads. Other matters to consider include whether the proposal involves the development of a bus station, coach or lorry park; adds to turnover in a large car park; or result in construction sites that would generate large Heavy Goods Vehicle flows over a period of a year or more.
- Introduce new point sources of air pollution. This could include furnaces which require prior notification to local authorities; or extraction systems (including chimneys) which require approval under pollution control legislation or biomass boilers or biomass-fuelled CHP plant; centralised boilers or CHP plant burning other fuels within or close to an air quality management area or introduce relevant combustion within a Smoke Control Area;
- Expose people to existing sources of air pollutants. This could be by building new homes, workplaces or other development in places with poor air quality.
- Give rise to potentially unacceptable impact (such as dust) during construction for nearby sensitive locations."
The NPPG states that where a planning proposal, including mitigation, prevents sustained compliance with EU Limit Values or National Objectives for air quality and cannot be made acceptable then refusal of planning permission should be considered.