Questions for Discussion Session

From your experience of LAQM in the East Midlands do you think the main recommendations of the review are correct?

Do you think a ‘modest’ or ‘proactive’ approach would be the way forward in your area?

What more do you feel you need (enabling action, guidance, resources) to help local authorities make LAQM effective?

What are the impacts of local authorities working on climate change – is policy being ‘joined up’?

Planning and Air Quality

Ed DearnleyPolicy Officer

About Environmental Protection UK

Formerly the National Society for Clean Air, founded 1898

Large cross sector professional membership

10 staff in Brighton, 2 in Scotland Three work areas

– Air quality and climate change– Land quality– Noise

Planning for air quality

Why is planning important? Guidance on air quality in the planning system The pro-active approach – Low emission

strategies Burning issues, biomass in the planning

system

Development and air quality

Development can have a significant impact on air quality:– Construction dust and emissions– Building emissions (boilers, etc)– Transport emissions (e.g. new car and bus

journeys) New development may also expose more

people to polluted air (e.g. new homes or offices in polluted areas)

Planning guidance

PPS 23 contains guidance on air quality ‘Any air quality consideration that relates to

land use and its development is capable of being a material planning consideration.

Wherever a proposed development is likely to have significant air quality impacts, close co-operation between LPAs and those with responsibilities for air quality and pollution control will be essential’

Improving air quality via development

Development can also act as a ‘force for good’ for air quality– Introduce new technologies/ techniques – Go ‘air quality neutral’ or beyond

Low emission strategies can be a major part of this process – addressing the transport emissions of new development

Guidance from Environmental Protection UK

Guidance is aimed at environmental protection and planning officers

Provides background material and an approach to assessment for air quality in the development control system

Recently updated for 2010

Aims

To assist environmental protection officers to better understand the planning system, and planning officers to better understand air quality issues

To help spread a consistent approach to air quality assessment amongst local authorities (helps all parties)

Identifying Applications with AQ Impacts

The guidance suggests that the earlier air quality concerns are picked up in the planning process, the better:– Close communication with planning colleagues– Development briefs and SPDs for larger sites

Post submission:– Development listing– Air Quality Management Area ‘flag’

AQ Steps in the Application Process

Table 3 Steps in the planning application process

Local Authority Developer

Steps Actions Steps

Agree scope of air quality assessment

Pre-Application discussions

Scope air quality assessment

Evaluate air quality assessment and any mitigation measures

Submit air quality assessment

Advise Planners on significance of impacts

Carry out air quality assessment identifying

significant impacts and any necessary mitigation

measures

Set Conditions / S106 Agree Conditions / S106 Propose Conditions / S106

The air quality assessment

An air quality assessment generally uses computer modelling to predict changes in concentrations of air pollutants related to a new development

Guidance describes:– When an air quality assessment should be asked for– What the air quality assessment should contain– How a local authority should assess the adequacy

of the air quality assessment Job is then describing the significance

of air quality impacts

Describing significance

The guidance provides a process for describing the significance of potential air quality impacts

Distinction is made between significance in the air quality assessment, and significance in local authority decision making

New 2010 update makes changes to guidance on significance in the air quality assessment

It also introduces an enhanced emphasis on professional judgement in deciding significance

Assessing significance

For the air quality assessment the guidance provides descriptors for the magnitude of the air quality impact, and how this is described in relation to existing air quality in the area

Professional judgement is needed to apply these descriptors, keeping in mind issues such as the number of people exposed and the difficulty of achieving air quality objectives

Local authority decision making

Once the air quality assessment has been completed local authorities need to apply their own judgement of significance

Guidance is given on how to do this, including a useful flow chart (next slide)

Again, professional judgement needs to be used in coming to a final decision

Mitigation

Guidance is provided on measures to mitigate the air quality impacts of new development

These include examples of mitigation measures that local authorities have included in planning conditions

Quantifying the impact of mitigation measures is difficult, but can be explored with:– The air quality assessment – DEFRA guidance– Forthcoming LES toolkit!

‘a package of policies & measures…’

‘secured through a combination of planning conditions & legal obligations…’

‘to mitigate the transport impacts of development by accelerating the uptake of low emission transport fuels and technologies in and around a new development…’

Tackling air pollutant AND greenhouse gas emissions

Current Emissions

Baseline

Business as usual

Target

Proposed Developmen

t

Low Emission

Development

Increasing acceptabilityof development

Reduce Journeys

Mode Shift

ImproveTechnology

Trips

Residual Emissions

Options include: Hybrids, Electric, Biogas, Biofuel and Hydrogen

Options include:Travel planning,Smarter choicesPublic transport, Road charging

Using the planning system to reduce transport emissions

• Specification of minimum emissions standards to be achieved by service vehicles accessing the site

• Residential car parking with a graduated annual charge depending on Euro standard and/or vehicle VED rating

• Contributions to enhance provision of local public transport, supporting deployment of low emission technologies

• Provision of electrical vehicle charging points

• Provision of car club, deploying low emission vehicles

Some Key Planning Measures…

‘A practical approach for mitigating cumulative impacts’

Contributions to a ‘general low emission strategy fund,’ can be deployed flexibly to support a wide range of low emission projects, policies and strategic activities

Important ConsiderationsWhat criteria and formula to use?Encouraging good development rather than ‘paying to pollute’?Flexibility? Transparency and accountability?Interaction with / implications of CIL?

Standardised Charging

Biomass

Biomass is a ‘burning’ issue for local authority air quality officers – most local authorities are seeing a large increase in planning applications

Current biomass drivers are mainly local planning policies

Forthcoming Renewable Heat Incentive will drive the market from next year

What is Sustainable?i.e. what should we be assessing?

Carbon emissions?

Fuel source?

Air quality?Economic impacts?

DEFRA Impacts Assessment

In 2008 DEFRA commissioned a UK wide study of the potential air quality effects of a major expansion in biomass heat

Results and key messages communicated in a letter from DEFRA/ DECC/ Scottish Government to all local authorities in the UK

Results of the Study

Unit emission levels

Final uptake level in 2020

Fuel and location bias?

Additional Km of roads exceeding PM10 limit value in 2020

Annual social (health) cost in 2020 (£m)

Medium – equates to average performance of current plant

52 TWh No 577 2,80350 TWh Yes 20 73238 TWh Yes 9 557

High – equates to top end performance of current plant

52 TWh No 138 73150 TWh Yes 3 18938 TWh Yes 2.5 142

52 TWh = 6.2% of 2005 UK Heat Demand

‘Key Messages’ from the Study

‘To meet the 2020 targets for renewable energy, the UK needs to increase very substantially the amount of renewable heat generated, and biomass heat is one of the key technologies’

‘Key Messages’ from the Study

‘The potential conflicts between these goals and air quality can be avoided through the use of high quality, low emission plant.

The replacement of old coal and oil fired plant with high quality wood fired plant located off the gas grid and away from densely populated urban areas may actually benefit air quality’.

‘Key Messages’ from the Study

‘In urban areas we would expect biomass heat deployment to be less common and larger (and therefore cleaner) biomass units to be more prevalent

‘Encouraging the use of larger plant, for example in conjunction with the development of heat networks, will result in a system where air quality emissions are easier to control than from a larger number of small plant’

Implementing these key messages?

At present biomass is largely development driven, i.e. led by ‘Merton Rule’ style planning conditions

Implementing these messages requires– Targeting deployment geographically – local

planning policy – Emissions standards – Amend the Clean Air Act, or

use the ‘carrot’ of the Renewable Heat Incentive– Encouraging larger plant – Community Infrastructure

Levy?

Planning Policy

In 2009 Environmental Protection UK and Lacors produced guidance on biomass and air quality

Covers assessment, management and mitigation of emissions

Comes with a number of supporting tools (unit conversion spreadsheet, developers information leaflet, etc)

But what about biomass outside of the planning system?

Emissions Standards

Clean Air Act sets a standard for ‘exempt appliances’ for use in Smoke Control Areas, but no standards for NOx and fine particles

Outside of SCAs controls are even weaker Government’s preferred way forward is to

introduce new emissions standards in the new Renewable Heat Incentive

Proposed RHI Emissions Standards

Encouraging Larger Plant

Biomass development is still overwhelmingly development driven

RHI may well be a ‘game changer’ but unlikely to encourage larger plant on its own

New Community Infrastructure Levy could perhaps be one way of funding larger, geographically targeted plant

What is sustainable?

Realistically a ‘horses for courses’ approach is needed for small scale renewables:

Urban areas:– Passive technologies (e.g. solar)– Energy efficiency and large scale CHP

Rural areas:– Biomass, ground source heat pumps, wind, etc

(Previous) government policy on planning does not help this approach!

More information

Planning guidance - www.environmental-protection.org.uk/aqplanning

Low emission strategies - www.lowemissionstrategies.org/

Biomass and air quality - www.environmental-protection.org.uk/biomass/

Planning and Air Quality

Ed DearnleyPolicy Officer