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