Air Quality and Land Use Planning

1. Air Quality and Land Use Planning Land Use Consultants 11th March 2008 Susanne Underwood

2. Overview • Study aims and objectives • Method and Findings • Conclusions • Recommendations

3. Study aims and objectives • Aim • to undertake research to inform SEPA planning staff and local air quality specialists about how best to achieve SEPA’s outcomes for air quality through the planning system • Objectives • to research the interface between land use planning and the protection and improvement of air quality • to assess the impact and effectiveness of planning decisions and policy on air quality

4. Air Quality and Planning • Scottish Planning Policy (SPP) 1 The Planning System (2002) • sets out role of integrated and sustainable transport to help improve air quality, address climate change and protect environmental resources from the damage caused by pollution • Scottish Planning Policy (SPP) 17 Planning for Transport (2005) • promotes an integrated approach to land use planning, economic development, transport and the environment, in order to meet Government commitments and targets on greenhouse gases and local air quality

5. Air Quality and Planning • Planning Advice Note (PAN) 51 Planning, Environmental Protection and Regulation (Revised 2006) • provides detailed advice on the role of the planning system in relation to air quality issues • sets out SEPA’s role as a statutory consultee on Local Air Quality Management

6. Method and Approach Main stages: 1. Review of all structure and local plans in Scotland adopted since 2001 for references to air quality 2. Review a sample of English structure and local plans adopted since 2001 in local authorities with AQMA for references to air quality 3. Review of Supplementary Planning Guidance on air quality

7. Method and Approach 4. Review of planning appeals in Scotland, England and Wales where air quality was an issue 5. Review of a sample of development control decisions 6. Consultation with planning officers and environmental health officers, Scottish Executive, and the Environment Agency

8. Development Plan reviewFindings • Approaches to air quality policy vary • Structure plans are not typically providing clear framework for local plans • Even where the Structure Plan provided a framework generally poor coverage of air quality issues in Scottish local plans • Some plans address air quality in relation to a wide range of developments, other plans are topic specific • More recent plans provide more comprehensive coverage of air quality in plan policies • Air quality policies often lack qualification

9. Supplementary Planning Guidance • Role and purpose • Provides guidance for applicants and planners • Provides additional detail to plan policies • Raises the profile of air quality issues • Identifies circumstances when an AQA likely to be required • Guidance on conditions and how to use them • Can provide guidance on mitigation and cumulative impacts

10. Review of planning appeals and development management • Reviewed appeals where the environmental impact on air quality was a significant issue • Reviewed planning applications for references to air quality • Difficult to identify where air quality was an issue in planning applications due to inconsistent use of terms relating to air quality and limited search options • Limited examples of air quality related conditions or air quality as a determining issue

11. Consultation • Aims of consultation: • To identify the mechanisms for triggering consideration of air quality issues; • To identify the information or advice each local authority uses in relation to air quality issues; • To identify examples of planning applications where air quality issues should have been a consideration, but weren’t; • To identify what changes would help ensure that air quality was addressed more comprehensively.

12. Conclusions and Recommendations

13. Conclusions • Relatively low profile of air quality in planning • Inconsistent approach to air quality through development plans • Inconsistent use of terminology relating to air quality in development management • SPG beneficial in informing air quality in planning, but no examples of SPG in Scotland • Joined up approach between local authority environmental health officers and planners brings significant benefits for addressing and understanding air quality issues

14. Recommendations • Context • SEPA is a consultee on development plans and a statutory consultee for SEA • Future changes to the planning system – strategic development plans and local development plans • Under the new planning act, pre-application discussions will become mandatory for some developments – this presents future opportunities for SEPA involvement

15. Recommendations • Consultation responses to development plans • Evaluate policy coverage of air quality issues and make recommendations on changes • How significant are air quality issues within this local authority? • Is there a stand alone air quality policy? • Is air quality covered in other environmental protection policies? • Are air quality issues addressed in relation to specific development types? • Does the policy seek to improve air quality?

16. Recommendations • Air quality policy • Statement supporting improvement of local air quality • Consideration of air quality standards in selecting locations for new development • Consideration of air quality impacts when assessing development applications including departures from the development plan • Reducing the need to travel • Promoting public transport and an integrated transport system • Key links to be made with policies on sustainable development, quality of life and environmental justice

17. Recommendations • Supplementary Planning Guidance • Identified as beneficial for local authorities in providing clarity on when to consider air quality issues • SEPA could produce guidance on scope and content of SPG on air quality to encourage more local authorities to develop this

18. Recommendations • Improved guidance on air quality and planning • Air quality information not always submitted as part of a planning application • Decision may be made with air quality information outstanding • Requirement for guidance on air quality related conditions for planning • Undertake a workshop event with SEPA staff, planners and environmental health officers to identify ‘model’ conditions to address air quality considerations in planning applications

19. Recommendations • Requirement for guidance on addressing cross boundary impacts between local authorities • Further research into need and scope for air quality modelling at a local authority scale and to assess cumulative impacts of developments

20. Recommendations • Promote and support cross departmental working • Within local authorities • Workshop events • At a national level • Promoting integration of air quality issues between government departments

21. Recommendations • Sharing good practice experience • Within Scotland • Within UK • Raise the profile of local authorities in addressing air quality issues when responding to development management consultations