Air Quality SPD
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Air Quality SPD
Local Air Quality
Representation ID: 71207
Received: 16/10/2018
Respondent: Hitchman Stone Architects
Agent: Hitchman Stone Architects
With regard to the new AQMA zones in Warwick and Kenilworth. Have sufficient traffic management schemes been considered?. These areas do suffer from serious peak hour traffic congestion, however at quiet times traffic congestion could probably be eased with better controls to traffic light sequences to ensure that at quiet times the traffic can flow more freely.
With regard to the new AQMA zones in Warwick and Kenilworth. Have sufficient traffic management schemes been considered?. These areas do suffer from serious peak hour traffic congestion, however at quiet times traffic congestion could probably be eased with better controls to traffic light sequences to ensure that at quiet times the traffic can flow more freely.
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Air Quality SPD
Stage 3 - Mitigation
Representation ID: 71208
Received: 16/10/2018
Respondent: Hitchman Stone Architects
Agent: Hitchman Stone Architects
We note that the mitigations have been updated and expanded in some cases. Some of these we feel will require additional conditions or Section 106 agreements. Some mitigations can be difficult to achieve in certain developments, especially mixed use / mixed occupier schemes. What penalties will be levied if NRMM being used on a project does not comply with the emissions standard. Again this will end up being conditioned.
We have completed a few developments now with a Low Emission Strategy and are used to the process. We note the additional triggers proposed for a Major Development.
Mitigations
On the projects that we have completed we have incorporated mitigations as outlined in the AQA Addendum, not all of them can be adopted on each project and we have to balance the needs/operation of the end user with the requirements of the AQA Addendum. Paragraph 5.3 states that "mitigations/compensation measures are to be equivalent to the value of their emissions calculation". Is this going to apply to ALL developments in of Minor/Medium/Major Classification?, or just Major as at present?.
We note that for Type 1 mitigations (Table 3) the proposals are expanded and include rapid charging units to be incorporated to commercial/retail and industrial developments.
We note that for Type 2 mitigations (Table 4) measures to support public transport infrastructure and promote its use, measure to support cycling/walking infrastructure and measures to support an electric vehicle plan are included. We envisage that these would require and a section 106 or equivalent agreement with the developer.
We note that for Type 3 mitigations (Table 5) it is proposed to add CAZ, LEZ and LES operations, again no doubt this would need to be conditioned or part of a section 106 or equivalent agreement. It also proposes a plugged in development and demonstration scheme which could encourage the use of green vehicles.
Infrastructure for low emission, alternative fuels for service vehicles, refuse collections and community transport services is more difficult to achieve depending on the development.
The proposal to add NRMM controls (Table 6) also seems to be unworkable as this is proposed to be included in Construction Environmental Management Plan, which will no doubt be a conditions/section 106 agreement or equivalent to be attached to any planning application. The onus then falls on the contractor to ensure that equipment they use meets the standard. Who is going to ensure this is being complied with?, and what penalties would they face if caught in breach of the condition/S106?.
