Sustainability Appraisal of the Sandwell Local Plan 2024-2041
7 Air
7.1 Introduction
7.1.1 Poor air quality is among the largest environmental risks to public health in the UK. Several objectives have been established in relation to air quality at the European, UK and regional levels seeking to reduce emissions of specific pollutants to minimise adverse effects on health and the environment. Key legislation / PPPs include the Environment Act (2021)[49] which sets out air quality as a priority area, the Air Quality Plan for NO2[50] and the Clean Air Strategy[51].
7.2 Baseline and key issues
7.2.1 The entirety of Sandwell Borough is designated as an Air Quality Management Area (AQMA), known as 'Sandwell AQMA'. The AQMA was declared in 2005, due to exceedances in the national annual mean objectives for nitrogen dioxide (NO2)[52] owing to the borough's large areas of established industry and complex road network of major arterial roads, including the M5 and M6 motorways.
7.2.2 The principal source of air pollution in Sandwell is vehicle exhaust emissions. Elevated NO2 levels are observed at busy junctions, narrow congested streets and in town centres. The adjacent authorities of Dudley, Walsall and Wolverhampton are also wholly designated as AQMAs.
7.2.3 The Air Quality Action Plan for Sandwell[53] and the Air Quality Annual Status Report[54] states that NO2 concentrations in seven areas continue to exceed the annual mean objective. Whilst this represents a decrease compared to the extent of exceedances which led to the AQMA's declaration, the Action Plan sets out key priorities for the Council to continue to improve air quality and reduce associated adverse health impacts, including:
- Developing specific measures in consultation with communities to reduce NO2 concentrations at 'hot spot' locations;
- Promoting public transport, walking, cycling and switching to low or zero emission vehicles;
- Reviewing what impact the council has on air quality in its role as a provider of public services and develop a plan to reduce emissions from its activities;
- Supporting and encourage taxi and private hire vehicle operators and drivers in reducing emissions from vehicles;
- Applying existing and developing new planning development policies that support air quality improvements;
- Developing information, social media and campaigns to encourage behaviour change around improving physical health and increasing use of low emission vehicles; and
- Working in partnership with Birmingham City Council to minimise negative impacts on Sandwell residents resulted from the implementation of the Clean Air Zone.
7.2.4 As all proposed development in Sandwell will be located within an AQMA, this is likely to lead to adverse impacts on health and may prevent the Council from achieving air quality targets. It is assumed that new development proposals would result in an increase in traffic and thus could potentially increase traffic-related air pollution. Both existing and future residents would be exposed to this change in air quality.
7.2.5 It is widely accepted that the effects of air pollution from road transport decreases with distance from the source of pollution. The Department for Transport (DfT) in their Transport Analysis Guidance consider that, "beyond 200m from the link centre, the contribution of vehicle emissions to local pollution levels is not significant"[55]. This statement is supported by National Highways and Natural England based on evidence presented in a number of research papers[56] [57]. Exposure to road transport associated emissions may have long term health impacts.
7.2.6 Air pollution, particularly excessive nitrogen deposition, is known to be harmful to the health and functioning of natural habitats.
Key issues for air quality include:
- The industrial character of the borough accompanied by the strategic network of local and major arterial roads, including the M5 and M6, has led to high traffic volumes and congestion, with adverse implications for air quality.
- Sandwell AQMA covers the whole local authority area and the principal pollutant affecting air quality is nitrogen dioxide (NO2), mostly sourced from road traffic. There is a need to ensure development avoids exacerbating air pollution issues in existing AQMAs and contributes to air quality improvement measures.
- There is a need to ensure development proposals are designed in order to avoid any significant adverse impacts from pollution, including cumulative impacts, on human health and wellbeing, biodiversity, the effective operation of neighbouring land uses and the water environment.
7.3 Impacts on air
7.3.1 Box 7.1 presents a plan-wide summary of the adverse impacts on air that have been identified through the SA process. These adverse impacts are those identified prior to mitigation considerations.
Box 7.1: Summary of identified impacts on air
Impact on air
Summary of identified impact
Increased pollutant emissions
Impacts on air quality may arise during the construction and occupation of different types of development proposed within the SLP. Some types of new development, such as employment locations, local facility provisions or the cumulative impact of high-density residential development, are likely to increase the volume of traffic and associated emissions within the SLP area.
As a result, associated transport-related emissions including NO2 and PM10 will be released into the atmosphere, with potential adverse effects on local air quality.
Exposure of human and biodiversity receptors to poor air quality
An increase in air pollution from new development including vehicular emissions could potentially have adverse impacts on biodiversity assets, in particular European sites and SSSIs which are vulnerable to the impact of atmospheric nitrogen deposition, such as nearby SSSIs 'Wren's Nest' or 'The Leasowes'. Ecological networks in Sandwell are also vulnerable to eutrophication, acidification and increased toxicity as a result of increased emissions.
Exposure to sources of air pollution could potentially have adverse effects on the health of local residents, with children, the elderly and those of poor health identified as the most vulnerable. Development within or in close proximity to AQMAs would be likely to make it more difficult to achieve National Air Quality Objectives[58] within these areas.
The entirety of Sandwell is currently classed as an AQMA. Consequently, all allocated sites are located within Sandwell AQMA. In addition, the majority of site SH43 is located within 200m of Birmingham AQMA, and site SEC1-5 lies adjacent to Dudley AQMA.
Some 48 allocated sites are located within 200m of a main road, raising the potential for exposure of site end users to atmospheric pollution from traffic.
7.4 Local Plan mitigation
7.4.1 Box 7.2 lists the policies within the SLP which would be likely to mitigate, either fully or partially, some of the identified adverse impacts on air. Where there are no mitigating policies, or the contents of the SLP only partially mitigates the adverse impacts, a residual adverse effect is identified.
Box 7.2: Mitigating effects of the Local Plan policies on air
Policy mitigation for air
Summary of mitigating effect
Policy mitigation for impact of increased pollutant emissions
Various policies support improved low-emission forms of transport provision, including Policy STR1: Priorities for the development of the transport network and Policy STR9: Planning for low emission vehicles, as well as policies STR2, STR3, STR4, STR5, STR6, STR8 and SHW3. These policies support a reduction in private car use through improved public transport connectivity and supporting methods of sustainable and active travel, whilst seeking to improve traffic flow to reduce pollutant emissions.
Policy SCC2: Reducing operational carbon for new build non-residential development, supported by Policy SCC1 – Energy Infrastructure, Policy SDS2: Increasing efficiency and resilience and Policy SDMI: Design Quality, promote energy-efficient development proposals which support low carbon technologies, which will likely result in a decrease of pollutant emissions from the construction and occupation of new development.
Policy SDS8: Green and Blue Infrastructure in Sandwell and Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows encourage enhancements to the provision and connectivity of GI/BI, which will help to support ecosystem service functions such as the filtration of air pollutants and could potentially result in reducing impacts from increased emissions.
Policy mitigation for exposure of human and biodiversity receptors to poor air quality
Policy SHW3: Air quality will only permit development where it can be demonstrated that it will not further deteriorate existing poor air quality, supported by Policy SHWI: Health Impact Assessments. Any development that has potential to lead to significant adverse impacts on air quality will need to provide an air quality assessment.
Policy SDS2: Increasing efficiency and resilience ensures that development proposals will be designed to mitigate climate change impacts, in order to avoid a reduction in air quality and subsequently adverse impacts on human health. The policy is underpinned by other policies that aim to avoid changes in air quality through promoting energy efficiency for new development, including Policy SDMI: Design Quality, Policy SCC1: Energy Infrastructure and Policy SCC2: Reducing operational carbon for new build non-residential development. Policy SDS8: Green and Blue Infrastructure in Sandwell and Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows encourage enhancements to the provision and connectivity of GI/BI, which will help to support ecosystem service functions such as the filtration of air pollutants and could potentially result in improvements to air quality.
Various policies seek to improve traffic flow and promote sustainable and active modes of transport in order to avoid reductions in air quality, including Policy STR1: Priorities for the development of the transport network and Policy STR5: Creating coherent networks for cycling and walking, as well as policies STR2, STR3, STR4, STR6, STR8 and Policy STR9.
7.5 Residual effects on air
7.5.1 Drawing on the information presented in Box 7.1 and 7.2, Box 7.3 explores the nature of the residual effects on air.
Box 7.3: Residual effects for air
Residual effects
Further details of the residual effect
Increased pollutant emissions
The policies outlined in Box 7.2, coupled with technological advances and alternative solutions to energy generation and transport modes, will help to reduce the extent of emissions over time. However, an increase in air pollutants including NO2 and PM10 is expected following the development proposed within Sandwell.
Increased traffic volumes and increased energy demand will be likely as a result of the introduction of 10,434 dwellings and 1,221ha of employment floorspace. Increased pollutant emissions will be likely as a result of the new development and therefore associated impacts on air quality.
An increase in pollutant emissions will be likely to be a long-term but potentially temporary significant effect.
Exposure of human and biodiversity receptors to poor air quality
The introduction of 10,434 dwellings and 1,221ha of employment floorspace will be expected to increase the number of vehicles, and consequently vehicle emissions, in the Plan area. The policies outlined in Box 7.2 are expected to reduce the likelihood of adverse impacts occurring and could potentially help reduce these adverse impacts. Strategies implemented through the West Midlands Transport Plan[59] and the Sandwell Air Quality Action Plan[60] will complement the SLP policies. However, due to the volume of development proposed within an existing AQMA, an increase in traffic flows and subsequent reduction of air quality will be expected to have residual adverse effects which cannot be fully mitigated through the SLP policies alone.
A reduction in air quality across Sandwell would be expected to be a long-term but potentially temporary significant effect.
[49] Environment Act 2021. Available at: https://www.legislation.gov.uk/ukpga/2021/30/contents/enacted [Date accessed: 07/08/24]
[50] DEFRA and DfT (2018) Air quality plan for nitrogen dioxide (NO2) in UK. Available at: https://www.gov.uk/government/publications/air-quality-plan-for-nitrogen-dioxide-no2-in-uk-2017 [Date accessed: 07/08/24]
[51] DEFRA (2019) Clean Air Strategy. Available at: https://www.gov.uk/government/publications/clean-air-strategy-2019/clean-air-strategy-2019-executive-summary [Date accessed: 07/08/24]
[52] DEFRA (2024) AQMAs Declared by Sandwell Metropolitan Borough Council. Available at: https://uk-air.defra.gov.uk/aqma/local-authorities?la_id=222 [Date accessed: 07/08/24]
[53] Sandwell Metropolitan Borough Council (2020) Air Quality Action Plan 2020 – 2025. Available at: https://www.sandwell.gov.uk/downloads/download/396/air-quality-action-plan-2020-2025 [Date accessed: 07/08/24]
[54] Sandwell Metropolitan Borough Council (2023) Air Quality Annual Status Report. Available at: https://www.sandwell.gov.uk/downloads/file/719/2023-air-quality-annual-status-report [Date accessed: 29/08/24]
[55]Department for Transport (2019) TAG unit A3 Environmental Impact Appraisal. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/825064/tag-unit-a3-environmental-impact-appraisal.pdf [Date accessed: 04/07/24]
[56] Bignal, K., Ashmore, M & Power, S. (2004) The ecological effects of diffuse air pollution from road transport. English Nature Research Report No. 580, Peterborough.
[57] Ricardo-AEA (2016) The ecological effects of air pollution from road transport: an updated review. Natural England Commissioned Report No. 199.
[58] Defra (no date) UK and EU Air Quality Limits. Available at: https://uk-air.defra.gov.uk/air-pollution/uk-eu-limits [Date accessed: 09/07/24]
[59] Movement for Growth: The West Midlands Strategic Transport Plan. Available at: https://www.tfwm.org.uk/media/3ukj3yw0/movement-for-growth.pdf [Date accessed: 23/08/24]
[60] SMBC (2020) Air Quality Action Plan 2020-2025. Available at: https://www.sandwell.gov.uk/downloads/download/396/air-quality-action-plan-2020-2025 [Date accessed: 23/08/24]
