Part One: Spatial Strategy and Policies (Regulation 18)

Ended on the 22 December 2023

Air Quality

12.33 Promoting healthy living is a key component of the Dudley Local Plan. Reducing exposure to poor air quality will improve the health and quality of life of the population and support the aims and objectives²¹ of the Plan. 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.

12.34 The World Health Organisation 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 pollution22.

12.35 According to the 2019 Clean Air Strategy published by DEFRA²³,

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.

12.36 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.

(4) Policy DLP44 Air Quality

Strategic Approach

The DLP will promote 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 authorities inside and outside the Black Country) 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. requiring the provision and protection of green open spaces and significant additional tree cover (see also DLP33);
4. ensuring the sustainable location of new residential and employment development to minimise commute times; and
5. 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.
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

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.
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.
Whenever development is proposed in locations where air quality does not / 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 in order that it will meet air quality 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 of pollutants to air on the scheme (pollution that originates from one place) must also be considered.
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.
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.
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.

Justification

12.37 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.

12.38 The main cause of poor air quality in Dudley is transport related. 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. Dudley is working to reduce pollutant concentrations and to minimise exposure to air quality that does not meet with national objectives. Air quality management areas have been declared in locations across the borough to try to address the government's national air quality objectives, which have been set to provide protection for human health.

12.39 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 Dudley where air quality is, or is likely to become, a concern. The majority of 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 latest 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.

12.40 AQAs should be proportionate to the type and scale of development proposed, in accordance with the guidance provided by the latest Air Quality SPD 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 mitigation24.

12.41 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 latest Air Quality SPD should be agreed with the development management team / officer on a case-by-case basis.

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

increasing the distance between the development and the pollution source;
using green infrastructure, particularly trees, to help absorb dust and other pollutants (see DLP33 - Trees – care must be taken to ensure the type and location of such trees do not exacerbate air pollution by trapping it close to the street²⁵);
using ventilation systems to draw cleaner air into buildings;
improving public transport access to all development;
implementing travel plans to reduce the number of trips generated;
implementing low emission strategies; and
controlling dust and emissions from construction, demolition and working projects.

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