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15/04/2021

Five key considerations for an air quality strategy that matters

High levels of air pollution near protected sites are stymiying development in some places. Rebecca Broobank considers how develoeprs can put together an air quality management strategy that will them unlock development while preserving air quality

In some parts of the UK, high levels of air pollution around sites protected by the UK Habitats Regulations have forced a moratorium on development to avoid unacceptable effects to communities and wildlife.

For example, there has been a long-standing moratorium on development in Epping Forest District over concerns about air pollution effects on Epping Forest Special Area of Conservation. This moratorium can start to ease following the adoption of an Interim Air Pollution Management Strategy (APMS) – while challenges still remain regarding an unpopular requirement to deliver a Clean Air Zone by 2025.  

To ensure a way forward for planning applications without more harm to the environment, there are five considerations for an effective APMS:

1. Detailed monitoring, modelling and assessment of predicted air quality impacts that takes account of current guidance. Air quality assessment is complex and ever-changing, with recent court judgments shaking up entrenched practice. Natural England, the IAQM, Highways England and CIEEM have now provided guidance on assessing and interpreting the ecological and legislative implications of air quality change in the context of protected sites. A robust APMS will use the latest guidance to withstand scrutiny.

2. A flexible strategy catering for evolving, evidence-based demands for housing delivery that may reasonably deviate from local plan assumptions will support a smooth planning determination process.

“There has been a long-standing moratorium on development in Epping Forest District”

3. Open, democratic consultation: early, inclusive stakeholder engagement regarding an emerging APMS will ensure the strategy is well received.

4. Accountable deliverability: an APMS must provide confidence that its measures can be secured and delivered to meet the requirements imposed by the Habitats Regulations. This means providing detail on who is responsible for delivering the strategy, on what timescales and how it will be funded.

5. Forward planning: an APMS is most effective in unlocking development when prepared sufficiently in advance of the development it is required to facilitate. Finding mitigation solutions for air pollution on a project-by-project basis can be challenging, so a strategic solution is often required. Liaison with statutory consultees ahead of local plan reviews is advised to pre-empt emerging air pollution issues.

Dr Rebecca Brookbank is technical director and principal ecological consultant with ecological consultancy EPR

Image credit | iStock

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