Draft Regulation 18 Sandwell Local Plan

Ended on the 18 December 2023

Air Quality

6.29 Promoting healthy living is a key element of the Sandwell Local Plan. Reducing exposure to poor air quality will help improve the health and quality of life of the population and support the Plan's aims and objectives[113]. The need to address climate change and its associated impacts will include the need to tackle pollution and poor air quality, especially where it has impacts on both human and environmental health.

6.30 The WHO published data on the impacts of ambient and household air pollution on human health for the European High-Level Conference on Non-Communicable Diseases held in April 2019. The paper stated that more than 550,000 deaths in the WHO European region were attributable to the joint effects of household and ambient air pollution in 2016, with over 500,000 being due to ambient air pollution and more than 50,000 to household air pollution[114].

6.31 According to the 2019 Clean Air Strategy published by DEFRA[115],

Air pollution is the top environmental risk to human health in the UK, and the fourth greatest threat to public health after cancer, heart disease and obesity. It makes us more susceptible to respiratory infections and other illnesses, and we estimate that the actions outlined in this document could cut the costs of air pollution to society by £1.7 billion every year by 2020, rising to £5.3 billion every year from 2030.

6.32 Paragraph 4.1 of the same publication outlines the impacts of air quality on economic growth. Cleaner air helps to reduce the likelihood of workplace absences through ill-health; the strategy identifies that particulate matter; nitrogen dioxide and ozone were estimated to be responsible for total productivity losses of up to £2.7 billion in 2012. Clean air also helps to create and sustain a pleasant and attractive living and working environment, which is more likely to encourage growth and investment in an area.

6.33 Following adoption of the Black Country Core Strategy in 2011 further guidance and advice was provided through the adoption of the Black Country Air Quality Supplementary Planning Document in 2016. This built on work undertaken on the West Midlands Low Emissions Towns and Cities Programme, including the West Midlands Good Practice Air Quality Planning Guidance (2014). The planning guidance offered further advice on issues around ambient and indoor air quality and model conditions for use by the local planning authorities.

6.34 This document will need to be revised and republished following adoption of the Sandwell Local Plan, considering new national legislation, regulations and targets and regional and sub-regional developments regarding air quality.

(4) Policy SHW3 – Air Quality

Strategic Approach

  1. The SLP will support a diverse approach to addressing the issue of poor air quality across the borough, including:
    1. requiring development and other land use proposals to promote the integration of cycling, walking, public transport and electric charging points as part of their transport provision;
    2. promoting and supporting (including through continued joint working with adjacent Black Country authorities and others) a modal shift from private motorised vehicles to the use of clean, fast and accessible public transport alternatives such as rail, the Metro and bus transport networks, cycling and walking;
    3. including a range of measures relating to energy generation at developments as set out in the hierarchy identified in Policy SCC2 - Energy Infrastructure, such as the installation of renewables-based systems, or the use of ultra-low emission NOx boilers;
    4. requiring the provision and protection of green open spaces and significant additional tree cover (Policies SDS7 and SNE3);
    5. ensuring the sustainable location of new residential and employment development to minimise commute times; and
    6. as part of an integrated zero-emission public transport system, promoting and requiring the use of sustainable technologies, zero-emission vehicles, design and materials and providing new or extended bus services to meet demand when development of a strategic nature is planned and constructed.
       
  2. New development must be at least air quality neutral following any required mitigation. Planning permission for new development or changes of use will be refused where data assessment indicates that development will:
    1. lead to deterioration of existing poor air quality;
    2. create any new areas that exceed air quality objectives; or
    3. delay compliance being achieved in areas that are currently in exceedance of legal limits unless sufficient mitigation can be achieved.

Improving air quality

  1. Residential or other sensitive development such as schools, hospitals / health care and care facilities should be sited in areas where air quality already meets national objectives, or where compliance with those objectives can be achieved with suitable mitigation proposed as part of the development proposal and verified as being achieved before occupation of the development.
     
  2. Developments that will have a moderate air quality impact, and which can be dealt with through standard mitigation measures, will not require an air quality assessment.
     
  3. Whenever development is proposed in locations where air quality does not or will not meet national objectives, or where significant air quality impacts are likely to be generated onsite or elsewhere by the development itself or its subsequent use / activities, an appropriate Air Quality Assessment will be required to demonstrate that the proposed development will improve air quality to meet relevant objectives once the development is completed and occupied / operational:
    1. the assessment must take into consideration the potential cumulative impact on air quality of all extant planning permissions in the locality, for both large / strategic and small schemes;
    2. the impact of point source emissions[116] of pollutants to air on the scheme must also be addressed;
    3. the assessment must take into consideration the types of pollutant emissions likely to be generated by the development and its future use / associated activities that will have an impact on human health;
    4. where assessments show that a development is likely to result in exposure to pollutant concentrations that exceed national objectives, a mitigation plan will be required to determine that the development will improve air quality, in order that it will meet air quality objectives once it is complete and occupied / operational; and
    5. adequate and satisfactory mitigation measures that are capable of implementation, including the planting of additional and replacement trees in appropriate locations, must be identified, submitted as part of an application, and made subject to appropriate conditions before planning permission is granted.
       
  4. Developments should not include materials or be positioned or ventilated in a way that would result in poor indoor air quality. Guidance will be provided to detail how such issues should be addressed.

Emissions from Construction Sites

  1. For all types of development, the control of emissions from construction sites will be agreed with the local authority.

Justification

6.35 National planning guidance identifies the need for local planning authorities to address the problems created by pollution, in terms of poor air quality and its impacts on human and environmental health. Major air pollutants that impact on human health include particulate matter (PM10 and PM2.5 and fine / very fine particulates) and nitrogen oxides (NOx). These gases may also combine to create ozone, a greenhouse gas that impacts on the atmosphere.

6.36 The main cause of poor air quality across the Black Country is related to vehicular transport. Locations have been identified that do not comply with current national objectives and that will result in relevant exposure; there are several air quality hotspots where on-going monitoring is required. Sandwell Council is working to reduce pollutant concentrations and to minimise exposure to air quality that does not meet with national objectives. Like the other Black Country Councils, it has declared air quality management areas to try to address the issue of poor air quality and provide protection for human health.

6.37 It is important that development likely to have a negative impact on air quality is fully assessed and measures taken to make it acceptable, particularly in parts of the Black Country where air quality is currently, or is likely to become, a concern. Most developments will have a moderate air quality impact, which can be dealt with through standard mitigation measures, without the need for an Air Quality Assessment (AQA), as detailed in the Black Country Air Quality SPD. These standard mitigation measures are designed to deal with the cumulative impact of many moderate impact developments over time and over a wide area.

6.38 AQAs should be proportionate to the type and scale of development proposed, in accordance with the guidance provided by the Black Country Air Quality Supplementary Planning Document and relevant national standards for air quality. National planning policy guidance on air quality offers several examples of what might usefully be incorporated in such assessments, including baseline conditions, specific concerns, the assessment methods to be adopted, the basis for assessing impact and determining the significance of an impact and mitigation[117].

6.39 For some developments a basic screening assessment of air quality is all that will be required, whereas for other developments a full AQA will need to be carried out, using advanced dispersion modelling software. An appropriate methodology informed by the Black Country Air Quality SPD should be agreed with the relevant development management team / officer on a case-by-case basis.

6.40 Where a potentially adverse impact on air quality is identified, mitigation measures may include:

  1. increasing the distance between the development and the pollution source;
  2. using green infrastructure, particularly trees, to help absorb dust and other pollutants (see Policy SNE3 – care must be taken to ensure the type and location of such trees do not exacerbate air pollution by trapping it close to the street[118]);
  3. using ventilation systems to draw cleaner air into buildings;
  4. improving public transport access to all development;
  5. implementing travel plans to reduce the number of trips generated;
  6. implementing low emission strategies;
  7. controlling dust and emissions from construction, demolition and working projects.

[116] Pollution that originates from one place

[117] NPPG, Paragraph: 007 Reference ID: 32-007-20140306

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