Air Quality and Land Use Planning Land Use Consultants11th March 2008

Susanne Underwood

Overview

Study aims and objectivesMethod and FindingsConclusions Recommendations

Study aims and objectivesAimto undertake research to inform SEPA planning staff and local air quality specialists about how best to achieve SEPAs outcomes for air quality through the planning system Objectivesto research the interface between land use planning and the protection and improvement of air qualityto assess the impact and effectiveness of planning decisions and policy on air quality

Air Quality and PlanningScottish Planning Policy (SPP) 1 The Planning System (2002) sets out role of integrated and sustainable transport to help improve air quality, address climate change and protect environmental resources from the damage caused by pollution Scottish Planning Policy (SPP) 17 Planning for Transport (2005) promotes an integrated approach to land use planning, economic development, transport and the environment, in order to meet Government commitments and targets on greenhouse gases and local air quality

Air Quality and PlanningPlanning Advice Note (PAN) 51 Planning, Environmental Protection and Regulation (Revised 2006) provides detailed advice on the role of the planning system in relation to air quality issuessets out SEPAs role as a statutory consultee on Local Air Quality Management

Method and ApproachMain stages: 1.Review of all structure and local plans in Scotland adopted since 2001 for references to air quality2.Review a sample of English structure and local plans adopted since 2001 in local authorities with AQMA for references to air quality3.Review of Supplementary Planning Guidance on air quality

Method and Approach4.Review of planning appeals in Scotland, England and Wales where air quality was an issue5.Review of a sample of development control decisions6.Consultation with planning officers and environmental health officers, Scottish Executive, and the Environment Agency

Development Plan reviewFindingsApproaches to air quality policy vary Structure plans are not typically providing clear framework for local plans Even where the Structure Plan provided a framework generally poor coverage of air quality issues in Scottish local plans Some plans address air quality in relation to a wide range of developments, other plans are topic specificMore recent plans provide more comprehensive coverage of air quality in plan policiesAir quality policies often lack qualification

Supplementary Planning GuidanceRole and purposeProvides guidance for applicants and plannersProvides additional detail to plan policiesRaises the profile of air quality issuesIdentifies circumstances when an AQA likely to be requiredGuidance on conditions and how to use themCan provide guidance on mitigation and cumulative impacts

Review of planning appeals and development managementReviewed appeals where the environmental impact on air quality was a significant issueReviewed planning applications for references to air qualityDifficult to identify where air quality was an issue in planning applications due to inconsistent use of terms relating to air quality and limited search optionsLimited examples of air quality related conditions or air quality as a determining issue

ConsultationAims of consultation:To identify the mechanisms for triggering consideration of air quality issues;To identify the information or advice each local authority uses in relation to air quality issues;To identify examples of planning applications where air quality issues should have been a consideration, but werent;To identify what changes would help ensure that air quality was addressed more comprehensively.

Conclusions and Recommendations

ConclusionsRelatively low profile of air quality in planningInconsistent approach to air quality through development plansInconsistent use of terminology relating to air quality in development managementSPG beneficial in informing air quality in planning, but no examples of SPG in Scotland Joined up approach between local authority environmental health officers and planners brings significant benefits for addressing and understanding air quality issues

RecommendationsContextSEPA is a consultee on development plans and a statutory consultee for SEAFuture changes to the planning system strategic development plans and local development plansUnder the new planning act, pre-application discussions will become mandatory for some developments this presents future opportunities for SEPA involvement

RecommendationsConsultation responses to development plansEvaluate policy coverage of air quality issues and make recommendations on changesHow significant are air quality issues within this local authority?Is there a stand alone air quality policy?Is air quality covered in other environmental protection policies?Are air quality issues addressed in relation to specific development types?Does the policy seek to improve air quality?

RecommendationsAir quality policyStatement supporting improvement of local air quality Consideration of air quality standards in selecting locations for new development Consideration of air quality impacts when assessing development applications including departures from the development plan Reducing the need to travel Promoting public transport and an integrated transport systemKey links to be made with policies on sustainable development, quality of life and environmental justice

RecommendationsSupplementary Planning GuidanceIdentified as beneficial for local authorities in providing clarity on when to consider air quality issuesSEPA could produce guidance on scope and content of SPG on air quality to encourage more local authorities to develop this

RecommendationsImproved guidance on air quality and planningAir quality information not always submitted as part of a planning applicationDecision may be made with air quality information outstandingRequirement for guidance on air quality related conditions for planningUndertake a workshop event with SEPA staff, planners and environmental health officers to identify model conditions to address air quality considerations in planning applications

RecommendationsRequirement for guidance on addressing cross boundary impacts between local authoritiesFurther research into need and scope for air quality modelling at a local authority scale and to assess cumulative impacts of developments

RecommendationsPromote and support cross departmental workingWithin local authoritiesWorkshop eventsAt a national levelPromoting integration of air quality issues between government departments

RecommendationsSharing good practice experienceWithin ScotlandWithin UKRaise the profile of local authorities in addressing air quality issues when responding to development management consultations

Stress role of LUC as planners not air quality/pollution expertsSPP 4: Planning for Minerals (2006) includes a section on dust and air quality and the health concerns associated SPP2 Economic Development (2002) in paragraph 51 states that; In making provision for economic development and considering proposals, planning authorities should seek to minimise adverse effects on the natural and built heritage, consistent with national planning policies in SPPs/NPPGs. Scottish Executive (2004) Air Quality and Land Use Planning Guidance PAN57: Transport and Planning (2004) supports the integration of planning and transport and achieving sustainable travel choices. Stand alone air quality policy; Sustainable development/strategic development policies; transport/waste/minerals specific policy with reference to air quality;

Informed conclusions and recommendationsDrawing on the Falkirk Structure plan policy on air quality and other policies the following have been identified as key componentsFinal point links to SEPAs themes from the corporate planSPG was identified as beneficial for local authorities in being clear about when to consider air quality issues in a planning applicationSE Modernising the planning system (2005) states intention to enhance the status of sPGSome of the appeals found air quality policy or SPG was not detailed enough to allow the reporter to make a judgement on e.g. significance of the impact of a development on air qualityRaised as an issue in Edinburgh as developments outwith the city generate travel into the city for commuting, shopping etc.Local air quality monitoring and modelling seems to be quite focused in scale and not necessarily easily applicable to planning. There could be an opportunity for development of computer modelling to take a more strategic overview of the air quality impacts of a new development on local air quality. This would allow cumulative impacts of several new developments to be assessed. Several appeals noted that the impact of traffic generated by the particular development under consideration was not significant or would not cause any thresholds to be breached, but if you could map in a range of developments that are taking place this would allow more informed decision making.