Policy CC4 – Air Quality

Support

Representation ID: 10983

Received: 19/09/2021

Respondent: Jonathan Browning

Support, but the policy should also identify a potential need for a Clean Air Zone to bring air quality standards in line with national legal limits, if required.

Comment

Representation ID: 11290

Received: 29/09/2021

Respondent: Mrs Morag Howell

Building more houses here will take away our "on the doorstep" family walks and will create more pollution.

Comment

Representation ID: 11295

Received: 29/09/2021

Respondent: Mr Melvyn Wilson

Public health will suffer from new car exhausts from the site.

Comment

Representation ID: 11386

Received: 30/09/2021

Respondent: Mr David Miller

Why not try building less houses, and none on the Green Belt

Support

Representation ID: 12044

Received: 10/10/2021

Respondent: Miss Emma Thompson

none

Object

Representation ID: 12779

Received: 08/10/2021

Respondent: Miss Angela Davies

And the pollution would obviously increase drastically! Leading to more childhood asthma and other pollution causing illnesses, this is not fair for our children and we as parents and residents of the area are not prepared to let this happen!

Comment

Representation ID: 13484

Received: 18/09/2021

Respondent: [None] Beddard

More traffic
More pollution

Comment

Representation ID: 15802

Received: 08/10/2021

Respondent: University of Birmingham

EVIDENCE BASE (SA...)
Black Country Plan 2039- from Wm-Air NERC funded research project hosted at University of Birmingham
In the evidence bases behind the plan, both the site assessment and the centre assessments fail to reference air quality as a consideration; even under their environment assessments.
In the Sustainability Appraisal there is an acknowledgement that a proportion of these proposed developments will lead to increased poor local air quality; from traffic related pollution.
In Well Designed Place policy CSP4 again there is no mention of air quality;
Yet within Policy CC4 Air Quality It recommends that all developments must be at least air quality neutral; which could appear in your Place-Making policy? However with the revised WHO Guidance on Air Quality this ambition must surely be raised beyond the current position rather than only expecting a neutral impact; when the vast majority of the geography is under a current AQMA.
The car parking study also highlights many existing sites already at capacity; so it's difficult to see how an increase in vehicle numbers will not impact local air quality when additional car parking is being identified.
With relation to housing in particular there should be a guarantee of a Health Impact Assessment- which would include air quality and green infrastructure appraisal and its public access.

There is reference to air quality mitigation and more than one reference to tree planting. For this to be truly effective please see the recommended latest evidence led guidance document form Trees Design Action Group, based on evidence from University research: https://www.tdag.org.uk/first-steps-in-urban-air-quality.html;

Additional paper on roadside air quality and green infrastructure
http://www.tdag.org.uk/uploads/4/2/8/0/4280686/futurebuild_2020_gi4raq_james_levine.pdf;


Finally seeing reference to the Local Nature Recovery Opportunity Maps being used to inform decision-making, compiled by the local Wildlife Trust & EcoRecord; is comforting.

Support

Representation ID: 20982

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.25 - Supports a diverse approach to dealing with air quality.

Object

Representation ID: 20984

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.25 - Identifies conflict between Criterion 2 and 4, and suggests that Criterion 2 should be amended so that in overall terms air quality is not diminished by development rather than "an in principle objection to any proposal that could have even the slightest degradation of air quality." Also concludes that Criterion 1 is also amended.

Comment

Representation ID: 21194

Received: 06/10/2021

Respondent: Mrs Margaret Owen

With regard to the Great Barr/ Streetly area in which I reside, experience of the development of Netherhall Estate has shown the impact of congestion by traffic, particularly on the Queslett Road which is used numerous times daily by ambulances attending presumably either Sandwell or Good Hope Hospitals.
I would be interested to know if this and other heavily congested areas are & will be closely monitored for air pollution pre & post stages within areas being developed.

Comment

Representation ID: 21274

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy CC4 – Air Quality
New development is expected to be ‘air quality neutral’ within Policy CC4. Further clarity is sought as to whether this includes mitigation.

Comment

Representation ID: 23072

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy CC4 – Air Quality
New development is expected to be ‘air quality neutral’ within Policy CC4. Further clarity is sought as to whether this includes mitigation.

Comment

Representation ID: 23469

Received: 11/10/2021

Respondent: Birchills Agenda 21 Group

Number of people: 339

Paragraph 185 of the Revised NPPF (July 2021) states that planning policies should take into account the likely effects of pollution on health. This is relevant given that
Walsall Council is encouraging the re-development of critically important "urban green space lungs" on the edge of the M6 motorway network. Notably, Pouk Hill
woodland green space and the urban green space bordering Churchill Road.

In accordance with central Government (London) national planning guidance in paragraph 174 (indent e) of the Revised National Planning Policy lung containing areas of mature and semi-mature broadleaved woodland
it therefore helps to mitigate the effects of very fine particulate harmful air pollution from the heavily congested M6 motorway network. By helping to filter-out, remove and reduce harmful levels of air pollution from vehicular traffic using the adjacent congested M6 motorway network, this urban green space area therefore helps to play a fundamental role in helping to protect the
health of thousands of local residents living within the wider Reedswood area.

As local residents, we have a fundamental Legal right to 'Clean Air'. This Legal Right is supported within the European Convention on Human Rights (The Human Rights Act) and should therefore be identified and respected within the emerging Black Country Plan (Review). On this basis, the Pouk Hill green space area 'Urban Green Lung Air Quality Enhancement Benefits'
should therefore be specifically identified and shown as an 'Urban Green Lung Air Quality Enhancement' designation on the main Policies Map of the emerging Black Country Plan (BCP) (Review). This special designation should also cover the area of urban green space located on the opposite side of the M6 motorway network, bordering the Jane Lane Primary School and
Churchill Road. These important urban green space buffers on both sides of the M6 are critically important to the health and well-being of thousands of local residents for the reasons explained above.

Object

Representation ID: 43884

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.37 Policy CC4 deals with air quality. It states the Plan will promote a diverse approach to addressing the issue of poor air quality. Taylor Wimpey supports this approach. However, Criterion 2 states new development must be air quality neutral and, amongst other things, should not lead to a deterioration of existing poor air quality. The Policy should be amended to indicate that mitigation measures which would in overall terms ensure that air quality was not diminished, would be a legitimate way forward rather than an in principle objection to any proposal that could have even the slightest degradation of air quality. Other parts of the Policy already provide such a scenario. In addition, whilst Criterion 2 states development must be air quality neutral, Criterion 4 indicates that where proposals have a moderate air quality impact which can be dealt with standard mitigation measures, there will not be a requirement for air quality assessment. This appears to provide an inherit contradiction with the approach set out in the Policy. This all points to the need to revise Criterion 1 of the Policy.

Comment

Representation ID: 45903

Received: 11/10/2021

Respondent: Transport for West Midlands

Under policy CC4 Air Quality, paragraph 10.179 should also be expanded to include the following text: “This revised version will need to take into account the current Environment Bill and it’s requirement for new UK targets, to be set by October 2022, for annual average levels of PM 2.5 in ambient air, and for population exposure reduction to PM 2.5. The University of Birmingham-led WM-Air Project, which is supported by West Midlands local authorities and WMCA, will then help inform the development of the new Black Country Air Quality Supplementary Planning Guidance document”

Furthermore, under the Strategic Approach (point 1a) the policy should include public transport and read “the integration of cycling, walking, public transport and electric charging points as part of their transport provision”. Also point 1b should include walking and cycling and read “promoting and supporting (including through continued joint working with authorities outside the Black Country) a modal shift from private motorised vehicles to use of clean, fast and accessible public transport alternatives such as rail, the Metro and bus transport networks and cycling and walking”.

In summary, greater acknowledgement of decarbonizing the transport system is required in this chapter, through ensuring new developments do not result in additional trips and carbon emissions, through using far less energy intensive personal vehicles and more sustainable modes and ensuring our land use policies result in people travelling far less and over shorter distances. Aligning this chapter with that of the transport chapter is therefore imperative, to demonstrate the links transport plays in tackling the climate emergency.

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.