Air Quality And Emissions Mitigation - Borough Of Gedling
in collaboration withEast Midlands Air Quality NetworkAir Quality andEmissionsMitigationGuidance for Developers2019
SummaryThe environment can impact negatively on the health and wellbeing of the population and ofall the environmental factors, air pollution has the greatest impact. Current evidence indicatesthat air pollution is associated with cardiovascular disease, lung cancer, respiratory disease,asthma and stroke. Air pollution disproportionately affects the young, older people, those withunderlying cardiopulmonary conditions and the most deprived within our communities.In the UK, the mortality burden of exposure to human-made air pollution is estimated as anannual effect equivalent to between 28,000 and 36,000 deaths a year, with an associated lossof life of between 328,000 and 416,000 years 1. For the East Midlands, it has been estimatedas an annual effect equivalent to 2,314 deaths, with an associated loss of life of 24,016 lifeyears attributable to particulate air pollution only 2This technical planning guidance for Gedling Borough Council has been prepared inconjunction with the East Midlands Air Quality Network (EMAQN) and has been developed tosupplement the National Planning Policy Framework (NPPF) 3. This guidance will be reviewedand updated in light of any specific future national and local policy changes.This document aims to improve air quality across the East Midlands and thus improve theenvironment and health of the population. This will be achieved where possible through eitherpreventing new emission sources or encouraging emission reductions, physical activity andhealth lifestyle choices. It aims to provide a consistent approach to air quality in the planningregime across the East Midlands. In producing this document the Council aims to providedevelopers with clear information as to what is required and how planning applications areevaluated in terms of air quality, which should help to speed up the planning process.The document deals primarily with the air quality impacts from traffic emissions (the maincontributor to ambient air pollution), however, point source emissions e.g. generators,incinerators, power plants and other potentially significant industrial/commercial sources of airpollution including the increasing use of biomass boilers are important local planning issues.The assessment and control of dust impacts during demolition and construction is alsoconsidered, as dusts contribute to airborne particulate matter. Greenhouse gas emissions arenot addressed explicitly, as they are covered by other initiatives, but synergies exist betweenmeasures to minimise climate change and local air quality impacts.It is recognised that new development will in the main inherently increase road transportemissions, both during the construction and operational phases. However, it is alsorecognised that sustainable development can be a positive force for change. The approach inthis document seeks to minimise or offset road transport emissions wherever practicable, bysecuring reasonable emission mitigation while also seeking to counter the cumulative impactsarising from all developments and maximise potential benefits to health and the environment.1Committee on the Medical Effects of Air Pollutants (COMEAP) - Associations of long-term average concentrations of nitrogendioxide with mortality. Available ent/uploads/system/uploads/attachment data/file/734799/COMEAP NO2 Report.pdf [Accessed 14/03/19].2Gowers, A. M., Miller, B. G. & Stedman, J. R. 2014. PHE-CRCE-010 Estimating Local Mortality Burdens associated withParticulate Air Pollution. stem/uploads/attachment data/file/332854/PHE CRCE 010.pdf [Accessed 26/07/16].3Department for Communities and Local Government - National Planning Policy Framework l-planning-policy-framework--2ii
A key theme of the National Planning Policy Framework (NPPF) is that developments shouldenable future occupiers to make green vehicle choices and it explicitly states that lowemission vehicle infrastructure, including electric vehicle re-charging, should be provided. Thisdocument seeks to develop consistent EV re-charging standards for new developmentsacross the East Midlands.An air quality assessment is undertaken to inform the decision making with regard to thedevelopment. It does not, of itself, provide a reason for granting or refusing planningpermission.The air quality assessment process follows a staged process:1. Using the ‘Screening checklist’ to determine whether the proposal qualifies as a‘small’, ‘medium’ or ‘large’ development;2. Determining whether the development requires an air quality assessment or emissionsassessment using the ‘Air quality and emission mitigation assessment checklist’;3. Determining whether additional assessment is required to assess the impact on publichealth and/or the local environment as well as the significance of a development onlocal air quality; and4. Determining whether an application should be refused on air quality grounds or whatmitigation measures are required to make the development acceptable on air qualitygrounds.AcknowledgmentThis document has been based on work carried out by West Midlands Low Emissions Towns& Cities Programme, West Yorkshire Councils, Kent & Medway Air Quality Partnership andthe Sussex Air Quality Partnership. Dust Management Guidance has been based on guidanceproduced by Wakefield Council.Our thanks are extended to them for their assistance in drafting this document.iii
Air Quality and Emissions MitigationPlanning Guidance NoteQuick Reference Guide: Air Quality Assessment/Mitigation ProcessStep 1 - Pre-Application Stage (see Page 8)Submit application to LocalPlanning Authority (LPA)with Scheme MitigationStatement (see page 19)Step 2 – Development Classification(see Page 8)Development is largescaleDevelopment issmall or medium scale Exposure Assessment FAILStep 3 - Air Quality Assessment(see Page 10 and Appendix 2)Assessment acceptedDevelopment issmall or medium scale Exposure Assessment PASSStep 4 - Mitigation and Compensation(see page 12)If assessment failsair quality criteriaRecommendrefusalRevised application/ mitigation andassessmentAssessmentnot acceptedStep 4 - Mitigation and Compensation(see page 12)(S)RETURN TO ‘WHAT IS REQUIRED’Submit Scheme MitigationStatement to Local PlanningAuthority (LPA)(see page 19)iv
Air Quality and Emissions MitigationPlanning Guidance NoteContentsSummary.iiQuick Reference Guide: Air Quality Assessment/Mitigation Process . ivIntroduction .1Purpose of this Guidance .1Air Pollution – What’s the Problem? .3Air Pollution and Planning Policy – National Context.6Air Pollution and Planning Policy – Local Context .7Assessment and Mitigation – What is required? .9Step 1 – Pre-Application Stage .9Step 2 – Classification of the Development .9Step 3 – Assessment. 11Small and Medium Scale Proposals . 11Large Scale Proposals. 12Step 4 – Mitigation and Compensation . 13Type 1 - Mitigation Measures. 14Type 2 - Mitigation Measures. 16Type 3 - Mitigation Measures. 19Construction Phase - Emissions Mitigation and Assessment . 19Scheme Mitigation Statement . 20Technical AppendicesAppendix 1 – Air pollution and HealthAppendix 2 – Air Quality AssessmentsAppendix 3 – Demolition and Construction Dust Management GuidanceAppendix 4 – Valuing Impacts on Air Quality for Type 3 Mitigation Measures
Air Quality and Emissions MitigationPlanning Guidance NoteIntroductionPurpose of this GuidanceIt is recognised that new development will in the main inherently increase road transportemissions, both during the construction and operational phases. However, it is alsorecognised that sustainable development can be a positive force for change. The approach inthis guidance seeks to maximise potential benefits to health and the environment, minimiseroad transport emissions wherever practicable to sustainable levels, and to counter thecumulative impacts arising from the emissions arising from new development schemes overtime.Although the focus of this guidance concerns air quality issues primarily arising from roadtransport emissions, it also considers the related benefits of tackling greenhouse gas andnoise emissions from road transport as additional benefits. Separate guidance is available toassist developers when considering emissions from other sources, including point sources(eg, biomass installations). 4The NPPF introduces the presumption that planning approval will be granted for sustainabledevelopment. This guidance document seeks to define what is meant by ‘sustainable’ in airquality terms in order to provide consistency and clarity to local authority practitioners anddevelopers alike.A key consideration in the NPPF is the cumulative impact of development on pollution levels;therefore, this guidance seeks to simplify assessment and mitigation procedures through astandardised development scheme classification, according to potential scheme impact, whilerecommending the types of appropriate and reasonable mitigation measures that should bedesigned into each scheme classification.The process outlined below provides an indicative step by step approach to dealing withplanning applications that have the potential to create relevant exposure to road transportemissions (nitrogen dioxide (NO2) and particulate matter (PM10/2.5)) for future occupants of adevelopment, or where the proposed development scheme has the potential to increaseconcentrations of pollutants in the surrounding area arising from road transport emissions.4EPUK guidance available at http://www.iaqm.co.uk/text/guidance/epuk/biomass developers leaflet.pdf1
Air Quality and Emissions MitigationPlanning Guidance NoteA basic hierarchy of principles is used as the basis for mitigating the operational air qualityimpacts associated with development schemes.Preference should be given to Preventing or Avoidingexposure/impacts to the pollutant in the first place byeliminating or isolating potential sources or by replacingsources or activities with alternatives. This is usually bestachieved through taking air quality considerations intoaccount at the development scheme design stage.Reduction and Minimisation of exposure/impacts shouldnext be considered, once all options forprevention/avoidance have been implemented so far as isreasonably practicable (both technically and economically).To achieve this reduction/ minimisation, preference shouldbe given first to:a. mitigation measures that act on the source; beforeb. mitigation measures that act on the pathwaybetween the source and receptor; which in turnshould take preference overc. mitigation measures at or close to the point ofreceptor exposureMeasures are all subject to the efficacy, cost andpracticability of the available solutions. In each case,measures that are designed or engineered to operatepassively are preferred to active measures that requirecontinual intervention, management or a change inpeople's behaviours.Off-setting a new development's air quality impact byproportionately contributing to air quality improvementselsewhere (including those identified in air quality actionplans and low emission strategies) should only beconsidered once the solutions for preventing/avoiding, andthen for reducing/minimising, impacts have been exhausted.Figure 1: Hierarchy of air quality mitigation for development 5By incorporating mitigation measures into scheme designs as standard, this approach helps tocounteract incremental increases in air pollution associated with cumulative development overtime.5Position Statement – Mitigation of Development Air Quality Impacts, January 2015http://iaqm.co.uk/text/position statements/mitigation of development.pdf2
Air Quality and Emissions MitigationPlanning Guidance NoteAir Pollution – What’s the Problem?Air pollution is the largest contributor to the burden of disease from the environment whichimpacts on the whole population. Current evidence indicates that air pollution is associatedwith cardiovascular disease, lung cancer, respiratory disease, asthma and stroke. Air pollutiondisproportionately affects the young, older people, those with underlying cardiopulmonaryconditions and the most deprived within our communities.Figure 2: Sources of air pollution including oxides of nitrogen (NOx) and fine particularmatter (PM2.5) 6How does it affect my health?Health effects are mainly related to long-term exposure to particulate air pollution (PM2.5) andnitrogen dioxide (NO2) (Appendix 1). The primary sources of these pollutants are shown inFigure 2.In the UK, the mortality burden of exposure to human-made air pollution is estimated as anannual effect equivalent to between 28,000 and 36,000 deaths a year, with an associated lossof life of between 328,000 and 416,000 years1. (Appendix 1 - Air pollution and health).6Department for Environment, Food and Rural Affairs (DEFRA), Public Health England (PHE). Air QualityA Briefing for Directors of Public Health, March 2017 nts/6.3091 DEFRA AirQualityGuide 9web 0.pdf3
Air Quality and Emissions MitigationPlanning Guidance NoteThe financial implications arising from the health burden associated with air pollution areconsiderable. The Department for Environment, Food & Rural Affairs (DEFRA) haveestimated the annual health costs for UK citizens to be in the region of 15 billion (range: 817 billion). As a comparison the health costs arising from obesity have been estimated to bearound 10 billion per year.Interventions that improve air quality and health deliver one or more of these high-leveloutcomes: Source reduction – reducing the sources of air pollution; Exposure reduction – reducing people’s exposure to air pollution; and/or Improving physical and/or mental health.Source: Air Pollution and Public Health; 2017035, PHE 2017The health evidence is unequivocal: any reduction in air pollution –even below limit values – will directly benefit public health, aspollutants such as nitrogen dioxide and particulate matter show nothreshold below which health effects do not occur.4
Air Quality and Emissions MitigationPlanning Guidance NoteAir Pollution in Gedling BoroughThe Environment Act 1995 established the Local Air Quality Management (LAQM) regime.LAQM requires Local Authorities to review and assess ambient air quality in their areasagainst health-based standards for a number of specific pollutants prescribed in the AirQuality Regulations 2000 and Air Quality (Amendment) Regulations 2002. If there is a risk thatlevels of air pollution in any part of the authority’s area will be higher than the prescribedobjectives, the authority is required to designate an Air Quality Management Area (AQMA). Itis then required to produce an Air Quality Action Plan, which sets out the measures it intendsto take in pursuit of the objectives.The main pollutants of concern in the Borough relate to the tail pipe emissions from motorvehicles. As such the main commuter routes into Nottingham, through the Borough, are themain areas of concern. Nitrogen Dioxide is the primary pollutant of concern in the Borough;Gedling Borough has an AQMA along the A60 Mansfield Road.For more information see: LINK TO GBC AIR QUALITY WEBPAGEPublic Health England has included an indicator in the Public Health Outcome Frameworkrelating to air quality 7. The indicator is a summary measure of the impact on death rates oflong term exposure to man-made particulate air pollution. The indicator underlines the scale ofthe health impact and the fact that it is modifiable. Table 1 shows the estimated mortalityburden in Nottinghamshire associated with particulate air pollution1.Table 1: Mortality burdens associated with particulate air pollution in NottinghamshireAreaEnglandEast MidlandsAttributable deaths25,0022,314Associated life years lost264,74924,016Attributable Fraction5.6%5.7%Nottingham UANottingham eldNewark and rtment of Health. Public Health Outcomes Framework 2013 to 2016, last updated 2015. Available ati/102/are/E06000015/iid/30101/age/230/sex/45
Air Quality and Emissions MitigationPlanning Guidance NoteAir Pollution and Planning Policy – National ContextNational Planning Policy Framework (NPPF)3 states that the purpose of the planning systemis to contribute to the achievement of sustainable development through three interdependentobjectives; economic, social and environmental and states that:‘an environmental objective – to contribute to protecting and enhancing our natural, builtand historic environment; including making effective use of land, helping to improvebiodiversity, using natural resources prudently, minimising waste and pollution, and mitigatingand adapting to climate change, including moving to a low carbon economy.’(Paragraph 8)Paragraph 181 highlights that planning decisions should ensure that new development inAQMAs and Clean Air Zones are consistent with the Council’s local air quality action plan, andlocal policies should contribute to meeting relevant limit values and national objectives for airquality.The NPPF Chapter 9 Promoting Sustainable Transport outlines how transport issues shouldbe considered including:‘ c)d)opportunities to promote walking, cycling and public transport use are identified andpursued;the environmental impacts of traffic and transport infrastructure can be identified,assessed and taken into account – including appropriate opportunities for avoiding andmitigating any adverse effects, and for net environmental gains; ’ [Para. 102]Paragraph 103 highlights that ‘Significant development should be focused on locationswhich are or can be made sustainable, through limiting the need to travel and offering agenuine choice of transport modes. This can help to reduce congestion and emissions,and improve air quality and public health. However, opportunities to maximise sustainabletransport solutions will vary between urban and rural areas, and this should be taken intoaccount in both plan-making and decision-making.’More generally planning policies should:‘ d)provide for high quality walking and cycling networks and supporting facilities suchas cycle parking ’ [Para. 104]The NPPF also states that:‘If setting local parking standards for residential and non-residential development, localplanning authorities should take into account:‘ . the availability of and opportunities for public transport; the need to ensure an adequate provision of spaces for charging plug-in and otherultra-low emission vehicles.’ ’ [Para. 105]6
Air Quality and Emissions MitigationPlanning Guidance NoteThe NPPF is less clear whether impacts on air quality at levels below the National Air QualityObjectives can be a material planning consideration. However, the health evidence isunequivocal: any reduction in air pollution – even below limit values – will directly benefitpublic health, as pollutants such as nitrogen dioxide and particulate matter show no thresholdbelow which health effects do not occur.Currently, there is no statutory guidance on how to deal with air quality considerations throughthe planning system. Most guidance concerns itself with technical modelling of impacts, withlittle information provided on how best to mitigate impacts. Gedling Borough has taken theapproach developed and adopted by councils in West Midlands, West Yorkshire, Kent &Medway and Sussex areas that simplifies the assessment of air quality impacts fordevelopment schemes and places more emphasis on incorporating standard road transportemission mitigation measures.Each development dealt with through the planning system will have an impact on local airquality through road traffic it generates, for example, private traffic associated with residentialschemes or deliveries to commercial schemes. By securing standard emission mitigationmeasures on each scheme, cumulative impacts arising from development over time can beminimised and health benefits can be maximised. This approach provides clarity andconsistency for developers up front regarding what is required of new developments, whichshould help to speed up the planning process.Air Pollution and Planning Policy – Local ContextThe Adopted Local Planning Document (2018) addresses both non-strategic site allocationsand generic development management issues; policies within the document are used todetermine planning applications. Policy LPD11 makes reference to this guidance in theassessment and mitigation of air quality impacts of development.Policy LPD 11 - Air QualityPlanning permission will not be granted for development proposals that have thepotential to adversely impact on air quality, unless measures to mitigate or offset theiremissions and impacts have been incorporated, in accordance with the BoroughCouncil’s Air Quality and Emissions Mitigation guidance and other associatedguidance documents.In areas where air quality is a matter of concern, development proposals will berequired to deliver a positive impact on air quality.Development proposals must not exacerbate air quality beyond acceptable levels,either through poor design or as a consequence of site selection.7
Air Quality and Emissions MitigationPlanning Guidance NoteDevelopment around areas where air quality is of concernThe overriding consideration will be to ensure that the air quality in existing AQMA(s) does notworsen by the introduction of a development and/or that there is no additional air pollutionburden from a development(s) which could create new AQMAs.Policy LPD11 indicates that: ‘In areas where air quality is a matter of concern, developmentproposals will be required to deliver a positive impact on air quality’.It may be therefore appropriate, in some circumstances, for the developer to fund additionalmitigating measures (such as those found in the Air Quality Action Plan) to offset any increasein emissions as a consequence of the proposed development; thereby positively impacting theAQMA(s). Measures above and beyond the mitigation required for the development itself willbe encouraged.The scale and cost of any additional mitigation measures would be quantified using theemission impact(s) of the development on air quality with this then calculated in terms of amonetary damage cost. The process for the calculation of damage costs is discussed laterand set out in Appendix 4.The Mitigation Statement should outline all mitigation measures proposed.These additional mitigation measures can be secured by either planning condition or PlanningObligation by a Section 106 Agreement(s) to make the site acceptable, using reasonableendeavours.Refusal of a planning application may still result if air quality impacts from a developmentremain; even after all reasonable means to mitigate the impacts on air quality have beenexhausted.8
Air Quality and Emissions MitigationPlanning Guidance NoteAssessment and Mitigation – What is required?SEE - Quick Reference Guide: Air Quality Assessment ProcessStep 1 – Pre-Application StageIt is important that planning authority requirements regarding scheme sustainability and theplanning application validation process are identified at the earliest stage possible.For this reason pre-application discussion involving planning management, air quality andpublic health professionals should take place at the outset to ensure optimum scheme designand avoid unnecessary delays in the planning process. This is particularly pertinent in relationto major schemes.Step 2 – Classification of the DevelopmentThree levels of development scale have been categorised using the DfT Threshold Criteria forTransport Assessments 8 in addition to DEFRA Technical Guidance [TG (16)] 9; into small,medium and large classifications (See below).This is not limited to developments leading to a significant change in road traffic flows or othertransport sources, but also includes any development that may affect air quality, with relevantexposure nearby, should be such as: Industrial installations;Biomass boilers;SMALL Combined Heat and Power (CHP) plant;Landfill sites, quarries, etc. Development proposalsthat fall below thecriteria. (Table2)MEDIUM Development proposals that meetthe requirements. (Table2)LARGE Development proposals that meetthe requirements (Table 2) and theadditional criteria set out in Table 3.8The Department for Transport (DfT) Threshold criteria for Transport Assessments and Travel Plans 7/202657/guidanceontaappendixb9Department for Environment, Food and Rural Affairs (DEFRA) - Local Air Quality Management Technical Guidance (TG16)(April 2016). Available at l-16-v1.pdf9
Air Quality and Emissions MitigationPlanning Guidance NoteTable 2: Development ClassificationLand UseDescriptionFood Retail (A1)Retail sale of food goods to the public – supermarkets,superstore, convenience food store 800 m (GFA)Non-Food Retail (A1)Retail sale of non-food goods to the public; but includes sandwichbars or other cold food purchased and consumed off site 1500 m (GFA)Financial and professionalservices (A2)Banks, building societies and bureaux de change, professionalservices, estate agents, employment agencies, betting shops. 2500 m (GFA)Restaurants and Cafes(A3)Use for the sale of food for consumption on the premises. 2500 m (GFA)Drinking Establishments(A4)Use as a public house, wine-bar for consumption on or off thepremises. 600 m (GFA)Hot Food Takeaway (A5)Use for the sale of hot food for consumption on or off thepremises. 500 m (GFA)Business (B1) 2500 m2(GFA)General industrial (B2)Offices other than in use within Class A2 (financial &professional).Research & development – laboratories, studios.Light industryGeneral industry (other than B1).Storage or Distribution(B8)Storage or distribution centres – wholesale warehouses,distribution centres & repositories. 5000 m (GFA)Hotels (C1)Hotels, boarding houses & guest houses 100 bedroomsResidential Institutions(C2)Hospitals, nursing homes used for residential accommodation andcare. 50 bedsResidential Institutions(C2)Residential institutions(C2)Dwelling Houses (C3)Boarding schools and training centres 150 studentsInstitutional hostels, homeless centres. 400 residentsDwellings for individuals, families or not more than six people in asingle household. 50 unitsNon-ResidentialInstitutions (D1)Medical & health services, museums, public libraries, art galleries,non-residential education, places of worship and church halls. 1000 m (GFA)Assembly and Leisure(D2)Cinemas, dance & concert halls, sports halls, swimming, skating,gym, bingo, and other facilities not involving motorised vehicles orfirearms.Criteria2222222 4000 m (GFA)222 1500 m (GFA)Additional Considerations1.2.3.4.Any development generating 30 or more two-way vehicle movements in any hourAny developments generating 100 or more two-way vehicle movements per dayAny development proposing 100 or more parking spacesAny relevant development proposed in a location adjacent to an Air Quality Management Area (AQMA)10
Air Quality and Emissions MitigationPlanning Guidance NoteTable 3: Additional Trigger Criteria for Large DevelopmentsThe development will:Indicative Criteria1. Cause a significant change in Light Duty Vehicle(LDV) traffic flows on local roads with relevantreceptors. (LDV cars and small vans 3.5t gross vehicleA change of LDV flows of: more than 100 AADT within or adjacent toan AQMA more than 500 AADT elsewhere.weight).2. Cause a significant change in Heavy Duty Vehicle(HDV) flows on local roads with relevant receptors.(HDV goods vehicles buses 3.5t gross vehicle weight).A change of HDV flows of: more than 25 AADT within or adjacent to anAQMA more than 100 AADT elsewhere.3. Realign roads, i.e. changing the proximity ofreceptors to traffic lanes.Where the change is 5m or more and the road iswithin an AQMA.4. Introduce a new junction or remove an existingjunction near to relevant receptors.Applies to junctions that cause traffic to significantlychange vehicle accelerate/decelerate, e.g. trafficlights, or roundabouts.5. Introduce or change a bus st
a. mitigation measures that act on the source; before b. mitigation measures that act on the pathway between the source and receptor; which in turn should take preference over c. mitigation measures at or close to the point of receptor exposure Measures are all subject to the efficacy, cost and practicability of the available solutions.
H2SSIM Results Basin Emissions Units Total Emissions (H2S) 0.071 gms/s kgen 0.25 Total Emissions (H2S) 4922.0 lbs/yr ThetaGen 1.06 Total Emissions (H2S) 2.5 tons/yr KDO 0.05 Total Emissions (H2S) 2.2 tonnes/yr KSO4 10 Emission Flux (H2S) 11.9 gms/m 2 yr kanox 0.006 ThetaOx 1.05 Zone Emissions Zone 1 Zone 2 Zone 3 Zone 4 Units m1 Zone Emissions (H2S) 0.02 0.03 0.02 gms/s n 0.2
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bulk, scale, materials, or style that would result in adverse visual impacts. Mitigation: Implement Mitigation Measure LU-1. Air Quality Impact: Implementation of the CAP could result in air emissions that would substantially deteriorate ambient air quality, including the exposure of sensitive receptors to substantial pollutant concentrations.
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