Draft Black Country Plan

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.