Air Quality SPD

Introduction
The FSB is the UK's leading business organisation and across Warwickshire, Coventry and Solihull 96.6% of the 50,000 private sector businesses are small - employing less than 50 employees. The FSB in Warwickshire and Coventry is grateful for the opportunity to comment on Warwick District Council Air Quality and Planning Supplementary Planning Document
The FSB understands air quality has become a much high priority area for UK Government and the consultation document aims to assist in reducing air quality impacts of development.
Our response focuses on a number of key principles that should be considered by Local Authorities in relation to small businesses when developing measures to tackle air pollution.
Supporting small businesses in tackling air pollution
* The FSB understands that improving our air quality in urban areas, is a complex issue and requires the joint action of Government and local authorities. One of the most significant challenges is the build-up of nitrogen dioxide concentrations around some local roads.
In response to this policy development the FSB released its report 'Clearing the Air: Supporting small businesses in tackling air quality in England (November 2017). The report is designed to help Government and local authorities to understand the diverse small business audience in relation to development of policies designed to tackle air pollution. The report is available here and we have highlighted some of the main recommendations in our response.
* Engagement with the small business community is key when developing guidance and we are therefore grateful for the opportunity to respond to this consultation on planning guidance and the designation of five air quality management areas.

* Despite widespread concern about the issue, it is important to note that air quality is improving nationally. By 2022 only 10 local authorities in England are forecast to still be in breach of air quality limits, even without the addition of new remedies. In the consultation guidance it states that air quality management areas established do not breach Air Quality Objectives.

However it is acknowledged that fine particulate matter levels have a significant impact on health across the district and reductions will still bring health benefits to the local population. As a result we would welcome regular assessment of measures to determine whether proposed mitigation measures are proportion or whether additional measures need to be included.

* The document proposes a number of mitigation measures for minor, medium and high new developments against the threshold criteria. These must be fair and transparent allowing those in the areas affected to adapt to and take advantage of any new requirements. The impact on small businesses operating in the designated areas and those travelling into the areas and impacted by any new developments should be considered when determining mitigation measures. The FSB believes that WDC in planning requirements should ensure that important and small business trades and services are not being deterred from the designated areas and town centres.

* The mitigation measures for major new developments include the establishment of Clean Air Zones. Where these are proposed as part of the planning requirements the FSB believe there should be further engagement and to ensure that small businesses are fully account for as part of the development process. Businesses must be given further fair opportunity to input and comment on proposals.

* Any supplementary planning documents and guidance resulting from this consultation should be implemented and followed fairly and transparently by planning officers so that a consistent and proportionate approach is taken to any new development.