Object

Representation ID: 46199

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Draft policy CC4 includes a blanket statement that new development must be at least air quality neutral. This element of the draft policy does not reflect the Framework or the Planning Practice Guidance, in its blanket approach. The PPG sets out that plans may need to consider:
- what are the observed trends shown by recent air quality monitoring data and what would happen to these trends in light of proposed development and / or allocations;
- the impact of point sources of air pollution (pollution that originates from one place);
- the potential cumulative impact of a number of smaller developments on air quality as well as the effect of more substantial developments, including their implications for vehicle emissions;
- ways in which new development could be made appropriate in locations where air quality is or is likely to be a concern, and not give rise to unacceptable risks from pollution. This could, for example, entail identifying measures for offsetting the impact on air quality arising from new development including supporting measures in an air quality action plan or low emissions strategy where applicable; and - opportunities to improve air quality or mitigate impacts, such as through traffic and travel management and green infrastructure provision and enhancement.

The PPG continues to explain that the test is the impact of proposed development and potential impact on future occupants:
- whether the proposed development could significantly change air quality during the construction and operational phases (and the consequences of this for public health and biodiversity); and
- whether occupiers or users of the development could experience poor living conditions or health due to poor air quality.

A requirement for development being air quality neutral is justified where there are sensitive receptors such that anything other than air quality neutral would be unacceptable or a proposed development would otherwise lead to a deterioration in existing poor air quality. For the policy to pass the test of soundness it should add criteria into its air quality neutral requirement, to set out on what basis such an expectation is justified and how an applicant might demonstrate the acceptability of a development ion circumstances where such a requirement is justified.