How new planning guidance on air quality changes the system: the Planning Briefing

What the latest changes to government guidance are, and how they affect practitioners. By Isabella Kaminski.

Air pollution (pic: Alan Stanton, Flickr)
Air pollution (pic: Alan Stanton, Flickr)

What has changed?

The November update follows the publication of the government’s Clean Air Strategy in January as well as last year’s revised National Planning Policy Framework (NPPF), which put more stress on better air quality. The overall ordering of this section has changed and MHCLG has removed explicit references to the European Union. For the first time, the updated guidance stresses that considering air pollution at the plan-making stage "can ensure a strategic approach to air quality and help secure net improvements". It also clarifies that all development plans can "influence air quality in a number of ways".

It specifies that plans should consider the impact of new development on Clean Air Zones, which five English councils have introduced to tackle nitrogen dioxide levels that are above legal limits. Plan-makers are newly advised that they should take account of "trends" in air quality, while plans are expected to identify opportunities to "improve air quality or mitigate impacts" using measures such as "travel management and green infrastructure provision".

When considering planning applications, the guidance says authorities should consider "what would happen to air quality in the absence of the development". The types of issues likely to trigger the need for developers to submit an air quality assessment to support their application have been refined to align with recent public concerns, such as worries about new schools in areas with poor existing air quality.

The provision of electric vehicle charging infrastructure has been added to the list of specific issues that authorities may consider when assessing the air quality impacts of a proposed development. Authorities are also newly advised that any air quality mitigation must be location-specific.

Practical implications

Kate Hodson, principal planner at consultancy Land Use Consultants, says the guidance ups the ante for authorities to consider air quality in plan-making, but does not provide much detail on what this means in practice. "It’s putting the onus on developers to come up with their own solutions on air quality."

In terms of development management, Hodson says: "The guidance is certainly pushing for more scrutiny of air quality assessments and requiring more conditions related to air quality on planning applications, and that’s during construction and occupation as well."

A spokesperson for the Planning Officers Society, which represents local authority planners, says the update provides "a number of helpful clarifications", including better recognition of the importance of air quality in relation to biodiversity.

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