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08/08/2008
Making air quality improvements sustainable
Garry Gray, associate – air quality, Scott Wilson explains how the new European Air Quality Directive reflects a wider change of focus away from addressing local pollution hotspots and towards achieving sustainable reductions in the level of community exposure to air pollutants
On the 14th April 2008 the European Council of Ministers announced the EU’s continuing commitment to realising a minimum standard of ambient air quality in European towns and cities and less developed areas by adopting the Ambient Air Quality and Cleaner Air For Europe Directive. The new directive replaces the current Air Quality Framework Directive and associated legislation, which in the UK, gave rise to Air Quality Management Area (AQMA) Orders, Low Emission Zones and a range of local policies and plans aimed at managing the publics exposure to air pollutants. In turn, these issues are now clearly set out in national planning guidance (PPG 23) as being material to the consideration of a planning application.
The new directive was published in May 2008 and retained much of the previous framework directives requirements, although it also introduced the possibility of some relaxation of deadlines, it introduced targets and limits for one new pollutant, termed PM2.5. The approach to the management of population exposure to PM2.5 takes the form of an annual mean target/limit concentration and also a concentration reduction target of 20 percent (relative to 2008-2010 period by end of 2018-2020 period).
The use of a concentration reduction target is a first for EU air quality standards and although there are some parallels to current approaches to carbon management, this approach has several implications for the way in which local air quality impacts are considered within the UK planning process. The Air Quality Strategy for England, Scotland, Wales and Northern Ireland, published in July 2007, already contains an objective of a 15 percent reduction in PM2.5 annual mean concentrations at urban background sites by 2020.
The basic approach is a simple one. By making small reductions to the amount of pollution emitted from many sources across large areas, the background level of pollution that the whole population are exposed to will be reduced. This means that for a given amount of local emissions (from road traffic, heating or industrial sources), measured pollutant concentrations at a location with a low or moderate background level of pollution is less likely to exceed the air quality objective concentration values than it would be with a higher contribution from background pollution.
From a development perspective, this means that if the exposure reduction approach works, then in the long-term, local air quality will become less of an issue when seeking planning permission. This remains a big ‘if’ at present. In the short to medium term there will be a growing expectation for developers to demonstrate how each project contributes to the local authorities wider sustainable development goals for air pollution exposure reduction, even if the development will increase local levels of total pollution at specific locations.
This is a problem that Scott Wilson has encountered on an increasing number of projects in recent years, and our experience is that for larger developments there is already considerable potential within many proposals to demonstrate that a development will contribute to achieving exposure reduction goals. By working together, specialists in air quality and sustainable construction can build in these benefits at the design stage, thereby removing the need for potentially expensive mitigation measures.
Two recent projects undertaken by Scott Wilson’s Sustainable Construction team illustrate how local air quality benefits would contribute to wider sustainable reductions in background air pollutant levels being achieved. The DEFRA Agency HQ building in Surrey and the Water’s Edge Centre in Barton-on-Humber both employed Scott Wilson’s advisory services in order to achieve Excellent BREEAM ratings. The Water’s Edge development achieved the highest score in a Bespoke BREEAM assessment to date, and A DEFRA project – due for completion this year – is to be an exemplar in sustainable construction.
Further details of the sustainable construction input to the projects mentioned can be obtained from phil.garlick@scottwilson.com or Garry Gray can be contacted at our Nottingham office on 01159 077 025 or by email garry.gray@scottwilson.com.
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