Air Quality June 2020 - Supplementary Planning Document - London Borough of Richmond upon Thames
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Supplementary Planning Document Air Quality June 2020
Air Quality
Contents Abbreviations
Introduction........................................................................................................................................................................... 5 AQA Air Quality Assessment
AQAP Air Quality Action Plan
Background............................................................................................................................................................................ 8
AQDMP Air Quality and Dust Management Plan
Planning Policy Context................................................................................................................................................ 10
AQAF Air Quality Action Fund
Planning Conditions and Section 106 Obligations..........................................................................................15 AQFA Air Quality Focus Area
Development Management..........................................................................................................................................17 AQDRA Air Quality and Dust Risk Assessment
AQMA Air Quality Management Area
Assessing Air Quality Impacts...................................................................................................................................25
BEB Buildings Emission Benchmark
Appendix A. Glossary..................................................................................................................................................... 30
CAZ Clean Air Zone
Appendix B. London Atmospheric Emissions Inventory for Richmond.................................................32 CEMP Construction Environmental Management Plan
CCHP combined cooling, heat and power
Appendix C. Location of Air Quality Focus Areas........................................................................................... 36
CHP Combined heat and power
Appendix D. EPUK/IAQM Air Quality Assessment Screening Criteria....................................................37
CIL Community Infrastructure Levy
Appendix E. Standard Conditions.............................................................................................................................39 CLP Construction Logistics Plan
Appendix F. Further Information................................................................................................................................41 EPUK Environmental Protection UK
GLA Greater London Authority
IAQM Institute of Air Quality Management
LAEI London Atmospheric Emissions Inventory
LAQM Local Air Quality Management
LEN Low Emission Neighbourhood
LLAQM London Local Air Quality Management
NO2 Nitrogen dioxide
NOx Nitrogen oxides
NPPF National Planning Policy Framework
NPPG National Planning Practice Guidance
NRMM Non-Road Mobile Machinery
PM Particulate matter
PM10 Particulate matter less than 10 micron in diameter
PM2.5 Particulate matter less than 2.5 micron in diameter
SPD Supplementary Planning Document
SPG Supplementary Planning Guidance
TEB Transport Emissions Benchmark
ULEZ Ultra Low Emission Zone
2 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 3
Introduction 6. Air quality tends to be worst close to major
roads, but emissions over a wide area
1. This Supplementary Planning Document contribute to the background pollution
(SPD) has been produced by the London levels. Health effects can potentially occur
Borough of Richmond upon Thames to below widely accepted international
address common air quality issues affecting standards and objectives. For some
the borough and assist in providing a pollutants, such as particulate matter (PM),
consistent approach to new development. there is no known threshold below which
The primary aim of this SPD is to supplement health effects do not occur. Therefore,
existing Local Plan Policies which seek to there is a need to reduce background levels
improve air quality in the borough. as well as emissions from road traffic to
protect human health.
2. This SPD is a material planning consideration
when determining applications for planning 7. The National Planning Policy Framework
permission, setting out more detailed and (NPPF) requires the planning system
supplementary guidance to the adopted to enhance the local environment by
Local Plan (2018) policy LP 10 (Local preventing new development from
Environmental Impacts, Pollution and Land contributing to, or being adversely affected
Contamination), specifically in relation to by unacceptable levels of air pollution, and
part B of the policy relating to Air Quality. to secure a good standard of amenity for all
It should also be considered as part of the existing and future occupants of land and
Health Impact Assessment process for major buildings. The National Planning Practice
developments as required in the Local Plan. Guidance (NPPG) provides general advice
on the assessment of air quality.
3. It provides advice on:
8. The main purpose of this document is to
the implementation of Policy LP 10, assist developers, decision makers, agents,
Part B. Air Quality; residents and others to identify issues
designing new developments to to be addressed in any application for
minimise the effects on the local development consent in which air quality
community as well as avoiding will be an important consideration when
introducing new exposure in areas of assessing that application. It provides
poor air quality; further advice and supplementary guidance
to Richmond’s Local Plan (adopted in 2018),
the assessment of air quality impacts of in particular in relation to the requirements
development; and set out in Policy LP 10, Part B. Air Quality.
appropriate mitigation measures.
9. Applicants should always check whether
there are any additional requirements with
4. In this SPD the term ‘air pollution’ refers regard to air quality and planning in a
to both those air pollutants that have an specific area within the borough. Air Quality
effect on human health and the natural Focus Areas (AQFAs), Clean Air Zones
environment, and those, such as odour and (CAZs) and Low Emission Neighbourhoods
dust, that can affect the quality of life for (LENs) or similar are all considered to be
those living or working near sources. areas of special importance for air quality,
where additional requirements apply.
5. Air pollution can adversely affect human
health and has been linked to cancer,
asthma, stroke and heart disease, diabetes, 1
The Royal College of Physicians, 2016, Every breath we take:
obesity, and possibly dementia1. Long term The lifelong impact of air pollution. London.
https://www.rcplondon.ac.uk/projects/outputs/every-
exposure has been estimated to result in
breath-we-take-lifelong-impact-air-pollution
9,400 premature deaths in 2010 in London 2
King’s College London, 2014, Understanding the Health
with additional impacts due to short term Impacts of Air Pollution in London, report for Transport for
pollution episodes2. London and the Greater London Authority.
4 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 5
Objectives Scope Figure 1: The role of this SPD and its relationship to national, regional and local
policy and guidance, and the AQAP
10. The objectives of this Air Quality SPD are to: 12. This SPD applies to development that may
have an impact on air quality:
National Planning
help ensure consistency in assessing LLAQM Review and
Guidance on Air Quality
and when considering planning all major development, Assessment
NPPF and NPPG
applications; any development (including
highlight the existing planning policy conversions) that introduces new
framework in London and the Borough, exposure into areas of poor air quality;
and provide detailed guidance on the and Declaration of an
implementation of Local Plan policy LP AQMA
smaller development that may emit London Plan
10; odours, dust, smoke, and other fumes, GLA Sustainable Design
emphasise the importance of air quality for example, commercial kitchens and Construction SPG Local Development
as a material planning consideration; and construction of basement & GLA Control of Dust and Plan
Emissions During Construction Publication of an
identify the circumstances where developments.
and Demolition SPG AQAP
detailed assessments will be required as
part of planning applications; 13. Major development includes any one or
provide guidance on the requirements more of the following3:
of air quality assessments and the
circumstances under which these will a. working of minerals or the use of land
be required; for mineral-working deposits;
provide guidance on measures that b. waste development;
can be implemented to mitigate the c. the provision of dwelling houses where: Borough SPD on Air Quality
potentially harmful effects of new i. the number of dwelling houses to be
developments on air quality and public provided is 10 or more; or
health; and
ii. the development is to be carried
provide guidance on the use of planning out on a site having an area of 0.5
conditions and Section 106 obligations hectares or more and it is not known
to improve air quality. whether the development falls within
sub-paragraph (c)(i);
d. the provision of a building or buildings
Relationship between Air Quality and
where the floor space to be created by
Planning
the development is 1,000 square metres
or more; or
11. The role of this SPD and its relationship
to the national, regional and local policy e. development carried out on a site
and guidance on air quality, as well as its having an area of 1 hectare or more.
relationship to the Borough’s air quality
action plans (AQAPs), are illustrated
in Figure 1. The relevant air quality and
planning policy and guidance are outlined in 3
As defined by the Town and Country Planning (Development
Chapters 2 and 3. Management Procedures) (England) Order 2015.
6 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 7
Background shortest possible time. This includes the London LAQM Framework
Ultra Low Emission Zone (ULEZ) introduced 32. New development will be subject to more
14. This section sets out the air quality in 2019 in central London and its extension 25. The air quality objectives, set out in the stringent requirements in AQFAs, LENs,
background to this SPD. in 2021 to the area within the North and Air Quality (England) Regulations 2000 CAZs and in any other similar future
South Circular roads in 2021. This ULEZ is as amended by the Air Quality (England) designations, and in areas bordering these
equivalent to a Class D charging CAZ in the (Amendment) Regulations 2002, provide areas if deterioration in air quality will occur,
The Air Quality Strategy for England, Clean Air Zone Framework. the statutory basis for the air quality even if it does not result in an air quality
Scotland, Wales and Northern Ireland objectives under the London local air objective being exceeded.
21. London Boroughs are also planning quality management (LLAQM) system.
15. The Air Quality Strategy4 sets out air quality to introduce charging CAZs in their 33. The Council will require strict mitigation
objectives and policy options to improve air area. Richmond Council, for example, is 26. The Mayor of London has powers8 to measures for developments to ensure that
quality in the UK. The objectives are policy considering plans to introduce one covering intervene and direct local authorities in they do not introduce new exposure where
targets often expressed as a maximum Richmond town centre, which will be Greater London. In support of these devolved air quality exceeds a relevant objective.
ambient concentration not to be exceeded, outside the Greater London Authority’s powers, the Mayor established the LLAQM
either without exception or with a permitted extended ULEZ. system in 2016 for the coordinated discharge 34. The main source of emissions in the
number of exceedances, within a specified of the Mayor’s and Borough’s responsibilities. Borough is road transport. For NOx other
timescale. Local authorities have a legal important sources in the borough include
duty to work towards achieving these air London Environment Strategy 27. The Department of the Environment, aviation and the provision of heat and
quality objectives. Fisheries and Rural Affairs (Defra) and the power. For PM– construction, and domestic
22. The Mayor’s London Environment Strategy7, Greater London Authority require local wood burning are also important. For
16. These objectives were largely set in the published in May 2018, contains a authorities to report on the pollutants PM10 resuspension of deposited particles
1990s, since when there has been significant comprehensive list of measures to improve of greatest concern to the health of is also an important local source. (Note
new evidence on the health effects. In air quality. The aim is “for London to have Londoners. These are nitrogen dioxide this is based on the London Atmospheric
addition, in setting the objectives the the best air quality of any major world city (NO2), particulate matter (PM10 and PM2.5) Emission Inventory (LAEI) 2016, not
Government took account of a number by 2050, going beyond legal requirements and sulphur dioxide (SO2). roadside monitoring data). Further details
of factors, such as economic efficiency, to protect human health and minimise are provided in Appendix B.
practicality, technical feasibility and inequalities”. 28. Richmond’s LAQM/LLAQM statutory
timescale of achieving them. For these reports can be found at: 35. The Richmond Air Quality Action Plan
reasons public health can be affected below 23. This strategy includes setting new targets www.richmond.gov.uk/progress_reports_ (AQAP) sets out measures to reduce
these levels. for PM2.5 with the aim of meeting World and_air_quality_action_plans.htm emissions from key sources of air pollution
Health Organization guidelines by 2030, in the borough, with the aim of working
the establishment of zero emission zones 29. To help the Boroughs undertaken their towards achieving the objectives. The
National Air Quality Plan from 2020, the introduction of an air quality LLAQM duties the Mayor has identified a AQAP can be found at the following link:
positive development, the phasing out the number of areas where there are both high https://www.richmond.gov.uk/services/
17. The Government’s 2015 Air Quality Plan5 use of fossil fuels to heat, cool and maintain concentrations of air pollution and high environment/pollution/air_pollution/air_
to achieve the EU limit values for nitrogen London’s buildings and the introduction of public exposure. These are known as Air quality_reports/progress_reports_and_air_
dioxide (NO2) introduced a programme of a low emission zone for non-road mobile Quality Focus Areas (AQFAs). quality_action_plans
mandatory and voluntary Clean Air Zones machinery (NRMM).
(CAZs) outside London. It acknowledges
that London has high NO2 concentrations 24. The Mayor of London has introduced Low Air Quality in Richmond
but did not explicitly propose any measures Emission Neighbourhoods (LENs) which
for the capital because responsibility for air are area-based schemes that includes a 30. The entire Borough of Richmond has been
quality is delegated to the Mayor of London. package of measures focused on reducing designated as an air quality management
emissions and promoting sustainable living area (AQMA) due to poor air quality. This
18. A Clean Air Zone Framework was published more generally. A LEN is delivered by a AQMA was declared in 2000.
by the Government in May 2017. Borough with support from Transport for
London, the Greater London Authority and 31. The Greater London Authority (GLA) 4
Defra et. Al., 2007, Air Quality Strategy for England, Scotland,
Wales and Northern Ireland, Vol. 1.
19. The 2015 Air Quality Plan was replaced by a the local community. LENs are focused on has identified four Air Quality Focus
new plan in July 20176 which reiterated the areas of high exposure to high pollution Areas (AQFAs) in Richmond (shown in
5
Defra, 2015, Improving Air Quality in the UK: Tackling nitrogen
dioxide in our towns and cities, UK overview document.
need for London to improve air quality. which can be reduced through local AppendixC), this is subject to review and
6
Defra, 2017, UK Plan for tackling roadside nitrogen dioxide
measures, and locations with high trip change in the future. There are currently no concentrations, Detailed plan.
20. The Mayor of London has introduced generation and the potential to reduce Low Emission Neighbourhoods (LENs) or 7
Mayor of London, 2018, London Environmental Strategy.
a package of measures to achieve the emissions in the wider road network. Clean Air Zones (CAZs), but this may also
8
Under Part IV of the Environment Act 1995
statutory NO2 limit values in London in the change in the future.
8 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 9
Planning Policy Context 2. mitigation measures to reduce the
Greater London Policy
1. Development proposals should not:
development’s impact upon air quality, a) lead to further deterioration of existing
Introduction 40. The overarching aim of the Mayor of
including the type of equipment poor air quality;
London’s Environment Strategy is to reduce
installed, thermal insulation and ducting
36. In assessing planning applications that may air pollution in London so that the health b) create any new areas that exceed air
abatement technology;
affect air quality in Richmond borough of Londoners is improved. The strategy quality limits, or delay the date at which
or give rise to new exposure to poor air 3. measures to protect the occupiers states that all new major development is compliance will be achieved in areas that
quality, the Council will have regard to of new developments from existing required to be Air Quality Neutral (AQN). are currently in exceedance of legal limit;
policies in their Local Development Plan sources; Development that meets or is better than
c) create unacceptable risk of high levels
including this SPD, their AQAPs, the London 4. strict mitigation for developments to the AQN benchmarks are considered
of exposure to poor air quality.
Plan including the London Supplementary be used by sensitive receptors such to avoid any increase in NOx and PM
Planning Guidance (SPG) and national as schools, hospitals and care homes emissions across London and are therefore
2. In order to meet the requirements in
planning policy. in area of existing poor air quality; “Air Quality Neutral”. This influences the
Part 1, as a minimum:
this also applies to proposals close background air pollution in London.
Local Policy to developments used by sensitive a) development proposals must be at least
receptors. 41. Larger developments have the potential air quality neutral;
Richmond to go further and improve local air quality
b) development proposals should use design
by effective design. For example, by the
solutions to prevent or minimise increased
37. The strategic objectives of the Richmond Section D on odours and fume control provision of low or zero emission heating.
exposure to existing air pollution and
Local Plan, adopted in July 2018, include the states that the Council will ensure that This is considered to be Air Quality Positive
make provision to address local problems
need to: any potential impacts relating to odour development and the Mayor is committed
of air quality in preference to post-design
and fumes from commercial activities are to providing guidance for developers and
or retro-fitted mitigation solutions;
reduce or mitigate air pollution, adequately mitigated by requiring the others on the most effective approach to
(including odour and fumes) and following: take to ensure a development is Air Quality c) major development proposals must
encourage improvements in air quality, Positive. be submitted with an Air Quality
particularly along major roads that 1. an impact assessment where necessary; Assessment. Air quality assessments
already exceed acceptable air quality 42. The London Plan is due to be formally should show how the development will
2. information on the type and nature of
standards; and adopted early 2020. It contains Policy SI1 meet the requirements of B1;
filtration to be used;
ensure local environmental impacts of on improving air quality. The version of d) development proposals in Air Quality
3. information on the height and position this policy from the consolidated changes
development are not detrimental to Focus Areas or that are likely to be used
of any chimney or outlet; version of the Draft London plan (July
the health, safety and the amenity of by large numbers of people particularly
existing and new users or occupiers of a 4. the use of new abatement 2019), produced after the end of plan’s vulnerable to poor air quality, such as
development or the surrounding area. technologies.” examination is reproduced below. This children or older people, which do not
may change in the final version of the demonstrate that design measures have
London Plan. The adopted version will take been used to minimise exposure should
38. In assessing schemes that may affect air 39. The Richmond Local Plan 2018 makes precedence over the one below. be refused.
quality in Richmond the Council will have reference to the Council preparing this SPD
particular regard to Local Plan Policy LP 10 on air quality. It also sets out other policy 43. Policy SI1 Improving air quality states: C. Masterplans and development briefs
Local Environmental Impacts, Pollution and requirements, relating to transport and for large-scale development proposals
Land Contamination. parking, green infrastructure, biodiversity, “A. Development plans, through relevant subject to an Environmental Impact
and trees, many of which also have a role in strategic, site specific and area-based Assessment should consider how local
Section B on air quality states: addressing air quality and will be relevant in policies should seek opportunities air quality can be improved across
the consideration of planning applications. to identify and deliver further the area of the proposal as part an Air
“The Council promotes good air quality improvements to air quality and should Quality Positive approach. To achieve
design and new technologies. Developers not reduce air quality benefits that this a statement should be submitted
should secure at least ‘Emissions Neutral’ result from the Mayor’s or borough’s demonstrating:
development. To consider the impact of activities to improve air quality.
introducing new developments in areas a) how proposals have considered ways
already subject to poor air quality, the to maximise benefits to local air quality,
following will be required: B. To tackle poor air quality, protect health and
and meet legal obligations the following
b) What measures or design features will
1. an air quality impact assessment, criteria should be addressed:
be put in place to reduce exposure, and
including where necessary, modelled
how they will achieve this?
data;
10 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 11
D. In order to reduce the impact on 44. The Mayor has published two SPGs that Air Quality Neutral (AQN) Control of Dust and Emissions during
air quality during the construction deal with air quality: Construction and Demolition
and demolition phase development 46. Calculation of emissions compared to the
proposals must demonstrate how Sustainable Design and Construction Air Quality Neutral (AQN) benchmarks must 52. The London SPG on Construction and
they plan to comply with the Non- SPG9 which includes guidance on be carried out as part of the assessment of Demolition requires developers to produce
Road Mobile Machinery Low Emission preparing air quality assessments, air quality impacts (see Section 6). an Air Quality and Dust Risk Assessment
Zone and reduce emissions from the minimising emissions, addressing (AQDRA) and sets out minimum emission
demolition and construction of buildings exposure to air pollution, air quality 47. If the AQN benchmarks cannot be met requirements for non-road mobile machinery
following best practice guidance. neutral requirements, and emissions planning consent will be refused. (NRMM) (see paragraphs 81 to 83).
standards for combustion plant; and
48. Following the publication of the 53. In addition, the Council has adopted a Local
The Control of Dust and Emissions Government’s Housing Standards Review Code of Practice for Construction and
E. Development proposed should ensure
during Construction and Demolition in March 2015, the Air Quality Neutral Demolition Sites, this provides simple advice
that where emissions need to be
SPG10, which describes requirements for benchmarks, and the on-site energy to developers on environmental controls
reduced to meet the requirements
dust assessments, pollutant monitoring generation emission limits referenced below, required by the Borough.
of Air Quality Neutral or to make the
and standards. All Non-road Mobile cannot be required for developments that
impact of development on local air
Machinery (NRMM) used during the are residential only. However, the Mayor
quality acceptable, this is done on-site.
course of the development that is within of London and national government have National Policy
Where it can be demonstrated that
the scope of the GLA ‘Control of Dust legal obligations regarding compliance
emissions cannot be further reduced, by
and Emissions during Construction and with the EU limits for ambient air quality. 54. The NPPF11 contains a number of policies
on-site measures, then off-site measures
Demolition’ Supplementary Planning In order to address those obligations, in directly relevant to air quality:
to improve local air quality may be
Guidance (SPG) dated July 2014, or any particular with respect to nitrogen dioxide
acceptable, provided that equivalent air
successor document, shall comply with (NO2), residential developers are strongly
quality benefits can be demonstrated “170. Planning policies and decisions
the emissions requirements therein. encouraged to ensure that emissions meet
within the area affected by the should contribute to and enhance the
development.” the AQN benchmarks. natural and local environment by …
45. The most recent version of these guidance
documents, or equivalent, must be followed. a) Preventing new and existing
Air Quality Positive (AQP) development from contributing
to, being put at unacceptable risk
9
Mayor of London, 2014, Sustainable Design and 49. At the time of writing this SPD the Mayor of
Construction, Supplementary Planning Guidance, London from, or being adversely affected by,
Plan 2011 Implementation Framework. London had not produced guidance on Air unacceptable levels of soil, air, water
Mayor of London, 2014, The Control of Dust and Emissions
10 Quality Positive development. As soon as or noise pollution or land instability.
During Construction and Demolition, Supplementary Planning this has been published it should be used to Development should, wherever possible,
Guidance, London Plan 2011 Implementation Framework. inform the design of large developments. help to improve local environmental
conditions such as air and water quality,
taking into account relevant information
On-site Combustion Plant such as river basement plans; …”
50. The London SPG on Sustainable Design “181. Planning policies and decisions
and Construction sets emission limits for should sustain and contribute towards
certain combustion plant and requires the compliance with relevant limit values
use of ultra-low nitrogen oxides (NOx) or national objectives for pollutants,
boilers. These limits for individual boilers taking into account the presence of Air
must be met at all times. In addition, stack Quality Management Areas and Clean
discharge velocities should be above Air Zones, and the cumulative impacts
the recommended minimum and be at from individual sites in local areas.
appropriate heights above nearby buildings. Opportunities to improve air quality or
mitigate impacts should be identified,
51. The emissions from any centralised on- such as through traffic and travel
site energy plant must form part of an Air management, and green infrastructure
Quality Assessment (AQA). provision and enhancement. So far as
possible these opportunities should be
considered at the plan-making stage,
12 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 13
to ensure a strategic approach and limit 55. The latest version of the NPPF should Planning Conditions and Section 61. Conditions and planning obligations
the need for issues to be reconsidered be used. At the time of writing this SPD 106 Obligations seeking to improve air quality may take a
when determining individual applications. the most recent version was published in number of forms depending on the nature
Planning decisions should ensure that February 201912. Introduction of the proposed development. Standard
any new development in Air Quality conditions, applicable to many major
Management Areas and Clean Air Zones 56. National guidance on when air quality is 58. Planning permission can be granted subject developments, are included in Appendix E.
is consistent with the local air quality relevant to a planning decision, what should to planning conditions. Conditions are a Additional conditions may be included in
action plan. be included in an air quality assessment necessary tool to enhance the quality of planning consents on a case by case basis.
and mitigation can be found on the a development and to mitigate adverse
“182. Planning policies and decisions government’s planning portal13. impacts that might otherwise arise. They
should ensure that new development can only be imposed where they are Air Quality Action Fund (AQAF)
can be integrated effectively with necessary, relevant to planning and the
existing businesses and community Industrial processes development, and are enforceable, precise 62. A proposed development can be air quality
facilities (such as places of worship, and reasonable in all other respects. neutral but also have an adverse impact on
pubs, music venues and sports clubs). 57. Industrial processes which may range from Conditions relating to the air quality local air quality. Developers should seek to
Existing businesses and facilities should large industrial plant to dry cleaners and impact of a development will meet these mitigate these impacts and provide local
not have unreasonable restrictions paint spraying workshops, are regulated requirements. measures to deal with any adverse impacts
placed on them as a result of by the Environment Agency (Part A1 associated with development proposals
development permitted after they were processes) and the local authorities (Part 59. A planning obligation (under Section 106 during the construction and operational
established. Where the operation of an A2 and Part B processes). The planning of the Town and Country Planning Act phases.
existing business or community facility regime must assume that the pollution 1990 (as amended)) may also be used as
could have a significant adverse effect control regime will ensure that processes a site specific mitigation mechanism. The 63. Where it is not possible to fully mitigate the
on new development (including changes comply with their permits. The planning NPPF states that “Planning obligations must air quality impacts of a new development
of use) in its vicinity, the applicant (or regime can, however, consider whether a only be sought where they meet all of the on-site, developers will be required to
‘agent of change’) should be required to land use is appropriate for the local area following tests: contribute to off-site measures by making
provide suitable mitigation before the and it must consider public exposure to a financial contribution to the Borough’s
development has been completed. pollution. For industrial developments a) necessary to make the development Air Quality Action Fund (AQAF) through a
requiring planning consent this is done acceptable in planning terms; Section 106 agreement.
“183. The focus of planning policies at the planning application stage, and for b) directly related to the development; and
and decisions should be on whether existing processes it is done through the 64. This will be levied at the following rates, and
proposed development is an acceptable LLAQM regime. c) fairly and reasonably related in scale updated periodically:
use of land, rather than the control of and kind to the development.”
processes or emissions (where these building impacts – residential
are subject to separate pollution control 60. Developments may be required to pay the development:
11
MHCLG, February 2019, National Planning Policy Guidance
regimes). Planning decisions should Community Infrastructure Levy (CIL), which
https://assets.publishing.service.gov.uk/government/
10 £100 for 1 or 2 bedroom properties
assume that these regimes will operate uploads/system/uploads/attachment_data/file/810197/ may contribute to improving air quality in
effectively. Equally, where a planning NPPF_Feb_2019_revised.pdf the borough The CIL Regulations 2010 (as £150 for 3 or 4 bedroom properties
decision has been made on a particular Planning Practice Guidance on air quality, https://www.gov. amended) require that by the 31 December £200 for 5 bedroom or more properties
development, the planning issues should uk/government/collections/planning-practice-guidance
2020, the Council must publish an Annual
not be revisited through the permitting Infrastructure Funding Statement. This building impacts – non-residential
regimes operated by pollution control statement will provide details of which development
authorities.” Infrastructure CIL and Section 106 funding mixed use/commercial/community/
has been allocated to, as well as any public schemes should contribute £10
non-financial planning obligations that per 10 m3 gross building volume.
have been secured. Infrastructure that is
necessary to make development acceptable
in planning terms may be the subject of
a Section 106 agreement as part of the
planning consent.
14 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 15
65. The AQAF will be used to implement 66. For further information see Richmond Development Management 71. In assessing the impacts of development
measures in the Air Quality Action Plan Borough’s air quality action plan (see on human health the air quality assessment
(AQAP) relevant to the development and its paragraph 35 above). General Principles levels used should be based on the World
impacts. Examples of the use of this fund Health Organization guidelines. These are
include: 67. Developers will also need to pay the 68. Richmond Council requires the sustainable based only on the scientific and medical
Council’s costs of regulating the air design principles as set out in the Local evidence and therefore are a better
public education campaign to change quality impacts of new development Plan (2018). The Richmond Sustainable indicator of the public health impacts of
behaviours; and enforcement of air quality planning Construction Checklist and the London development than the objectives.
the purchase, servicing and conditions to ensure that there is no Sustainable Design and Construction
maintenance of air quality monitoring detrimental impact on air quality. This SPG should be built into the design of all
equipment to ensure the construction fee will depend on the type and size of proposed development. Design should Construction Phase
and operational phases of the development. ensure that:
development do not negatively impact 72. The construction phase of major development
on the local area; emissions associated with the can result in emission of air pollutants
development are minimised; that adversely affects human health as
the provision of advice to developers well as dust that may lead to nuisance or
and their contractors, on the control existing occupants are not exposed to
increased levels of air pollution; and disamenity. To ensure that emissions are well
of emissions during demolition and controlled all planning consents for major
construction works; occupants of new developments will development will include relevant planning
not be exposed to poor air quality. conditions to reduce these impacts.
69. The following broad principles will be 73. A contribution to any additional resourcing
applied when considering planning required by the Council to fulfil additional
applications for development that has the regulatory duties associated with the
potential to impact on air quality, result development may be required.
in an increase in the number of people
exposed to poor air quality or cause
disamenity: Air Quality and Dust Management Plan
avoid during construction and operation 74. An Air Quality and Dust Management Plan
of new development impacts on air (AQDMP) must be submitted for approval
quality to protect the health of people in accordance with The Control of Dust
living and working in the borough; and Emissions during Construction and
avoid during construction and operation Demolition SPG. The AQDMP will set out
of new development adverse effects measures to be implemented to reduce the
on local amenity of people living and impacts during the construction phase.
working in the borough;
75. Monitoring of dust may be required for all
reduce to a minimum emission from major development. The techniques to be
new development, including from the used will depend on the development. For
associated road traffic, to improve air medium and high risk construction sites
quality across the borough; real-time monitoring for PM10 and PM2.5 will
prevent development which is be required. The monitoring system should
unacceptable in terms of air quality, include an automatic alert direct to the site
odour, dust or other air emissions; and manager so that when dust levels breach
employ good air quality design. acceptable limits action can be taken swiftly
and effectively. This monitoring must be
undertaken for a reasonable period before,
70. Richmond Council expects developers to during and after the works.
use appropriate mitigation measures to
avoid adverse impacts. Contributions to 76. The AQDMP may be integrated within
the Air Quality Action Fund will be required a wider Construction Environmental
wherever impacts are not fully mitigated. Management Plan (CEMP).
16 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 17
77. The AQDMP should include the following; Non Road Mobile Machinery (NRMM) 82. Deliveries at sensitive locations, such as 87. Developers should seek to mitigate the air
close to schools, will be required to avoid quality impacts, preferably through on-site
the emissions standards that the non- 80. All Non-Road Mobile Machinery (NRMM) used peak hours on grounds of both air quality measures, but where this is not possible,
road mobile machinery (NRMM) used during the course of the development that and safety. through off-site measures. Developers will
on-site will meet (see below); is within the scope of the Greater London be required to contribute to the Borough’s
details of dust monitoring; Authority “Control of Dust and Emissions 83. Planning consents for major developments Air Quality Fund to mitigate any residual
during Construction and Demolition” will include a condition requiring the impacts.
details of the site specific mitigation SPG dated July 2014, or any subsequent submission of a detailed CLP to be
measures that will be employed on-site; amendment or guidance, shall comply with submitted for approval by the local planning 88. Planning consents for major developments
and the emission requirements therein. authority. This will commit the developer will include one or more conditions
Construction Logistics Plan. to implement the plan for the duration requiring mitigation measures to make
of the construction works. There may be development acceptable in air quality terms.
Transporting Waste and Construction a requirement for a CLP on other sites,
78. Information on mitigation measures during Materials including sites in confined locations or near 89. Developers may also be asked to submit a
construction (including demolition and sensitive receptors, in accordance with the Delivery and Service Plan where applicable.
earthworks) is available from the Institute 81. To avoid congestion on the local road Council’s Local Validation Checklist.
of Air Quality Management14 (IAQM) and in network, an outline Construction Logistics
The Control of Dust and Emissions during Plan (CLP) will be required with the 84. For development sites in and close to Development Design
Construction and Demolition SPG. The SPG planning application. Advice on the AQFAs, LENs and CAZs the Construction-
is based on the IAQM guidance. The most preparation of a CLP is provided by Logistic Plan should include: 90. New development should be designed to
recent version of the IAQM guidance should Transport for London (TfL) in Construction minimise air quality impacts:
be used (at the time of writing the latest Logistics Plan Guidance16. consideration of alternative transport
version was published in June 2016). measures including transporting waste the layout and design of all sites must
and construction materials to and from consider the impact of poor air quality
79. IAQM also produce Guidance on the 14
Institute of Air Quality Management, 2016, Guidance on development sites by train or water; on existing and new receptors. The
Monitoring of Construction Sites15 which the assessment of dust from demolition and construction,
delivering materials over the ‘last mile’ layout should site buildings as far from
version 1.1.
includes alert levels. It is also recommended by electric vehicles, or at times to be main roads as possible, should avoid
that the most recent version of this guidance Institute of Air Quality Management, 2018, Guidance on
15
windows and habitable rooms fronting
Air Quality Monitoring in the Vicinity of Demolition and agreed by the local planning authority;
is used. The latest update at the time of Construction Sites. and main roads and where possible use
writing was published in October 2018. buildings as a screen against poor
Transport for London, 2017, Construction Logistics Plan
16
restrictions on the use of certain types
Guidance. air quality. Non habitable rooms and
of vehicles e.g. very large vehicles if corridors in residential developments
they may add to local congestion; and communal halls, canteens, changing
restrictions based on vehicle emission rooms etc in commercial or community
standards; and/or other restrictions developments, schools and hospitals
deemed appropriate by the Borough. should be sited fronting main roads
wherever practical.
the impact of existing sources of air
Operational Phase pollution, including road traffic and
the exhaust from energy plant in
85. Richmond Council requires the design adjacent buildings may affect air quality
principles as set out in the Local Plan (2018), within new development. This must
Sustainable Construction Checklist SPD and be considered in an early stage of the
as described in The Sustainable Design and design process.
Construction SPG to be built into the design
of all proposed developments. Design should high thermal insulation, the use of
also ensure that existing occupants are not heat pumps and passive solar heating
exposed to increased levels of pollution and through building orientation and
that occupants of new developments will not good design will reduce the use of
be exposed to poor air quality. gas heating and air conditioning and
therefore reduce emissions of nitrogen
86. The London Plan requires all major oxides (NOx).
developments to be air quality neutral and
large developments to be air quality positive.
18 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 19the use of electric heating/cooling is
Traffic Reduction car club parking bays should be building with an associated car parking
encouraged and Combined Heat and
provided in all residential developments space to have a charging point and every
Power (CHP) should be ultra-low, NOx
91. Emissions from road traffic are the of 25 or more dwellings, at a rate of new non-residential building with more
boilers to reduce the amount of NOx
dominant source of elevated pollutant 1 per 25 dwellings, unless acceptable than 10 car parking spaces to have at least
emitted in the borough (see Heating,
concentrations in London. Richmond grounds can be given for alternative one charging point and a cable route for
Cooling and Power Supply section
Council promotes modes of transport with numbers. Financial contributions must electric vehicle charging for one in five
below).
low impacts on air quality in the Local Plan be provided to car clubs to provide parking spaces.
developments to be used by vulnerable and Local Implementation Plan. free membership for the users of
groups of the population, especially the development for two years as an 94. Car parking should be provided with active
children17, should not generally be 92. The following transport measures alternative to providing private parking and passive electric vehicle charging
located on busy roads or in the Air contribute to minimising the impact of new spaces for residents and employees to facilities21 consistent with the Local Plan
Quality Focus Areas, Low Emission developments on air quality and will be reduce car trips; and London Plan. At the time of writing
Neighbourhoods or Clean Air Zones. required where relevant: this SPD, the current requirements are: 20%
dedicated car parking area(s) should
The distance between busy roads and active provision (i.e. fully installed from
be located near the site entrance where
buildings must be maximised to reduce active travel infrastructure (cycling and the outset) plus 20% passive provision
practicable. Individual parking spaces
exposure of building occupants to poor walking); (i.e. cabling provided for easier future
next to houses will be discouraged. This
air quality. installation of charging equipment) in
public transport infrastructure and/ is to encourage walking.
where façades of buildings are close to or additional public transport services, residential developments, and 10% active
main roads, the installation of screens including financial contributions for public provision plus 10% passive provision in all
will be required to help reduce exposure transport improvements (in addition other developments.
for occupants to pollution from vehicles to those required to mitigate transport Electric Vehicles
the design of new developments should impacts). Adequate public transport will
be required for any new senior school; 93. To improve air quality the number of 19
Department for Transport, 2018, Road to Zero: Next steps
ensure that ‘street canyons’, which restrict
low emission vehicles needs to increase towards cleaner road transport and delivering our Industrial
the dispersion of emissions from road traffic management measures to Strategy.
substantially, and it is Government policy
traffic, are not formed or made worse. reduce the impact of traffic by reducing to encourage the use of electric vehicles19. 20
Department for Transport, 2019. Electric vehicle
inlets to ventilation systems should congestion that improves air quality; At the time of writing this SPD the
chargepoints in residential and on-residential buildings.
be located as high as practical above high trip generating development will Department for Transport were consulting
21
Active car parking spaces are fully wired and connected,
ready to use for charging electric vehicles. Passive car
ground level, preferably at roof height. only be permitted in areas which are on changes to the Building Regulations20 parking spaces have the electricity infrastructure provided to
They should not be located where the easily accessible by the public and are that would require every new residential enable connection at a later stage.
exhaust from energy plant will affect well located to local services;
the quality of the inlet air.
all major development must have
there should be no opening windows a travel plan. The travel plan must
where the façade of the building is demonstrate how it will be maintained
located in an area that exceeds an air and how it will encourage all members
quality objective. It is important that of the development, residents,
over-heating is avoided for the amenity occupants, staff and visitors to travel
for the future residents and that sustainably. It must quantify emission
developments have adequate ventilation reductions and air quality benefits.
in place. Residential development in
developments should provide cycle
multi-storey buildings should ideally be
parking in accordance with the standards
on higher levels to avoid exposure to
set out in the London Plan as a minimum.
road traffic pollution.
Cycle parking should be suitable for long
flues and exhaust vents should be a stay parking as set out in the London
minimum of 1 metre above the height Cycle Design Standards18 or subsequent
of the highest roof in the vicinity; and revisions. Development proposals
may need to be significantly higher should demonstrate how cycle parking
depending upon local conditions. facilities will cater for larger cycles, those
Dispersion modelling should be used to catering for the carriage of children and
determine the optimum height. cycles adapted for disabled people.
Exposure to air pollution can affect lung growth. This can
17
Mayor of London & Transport for London, 2014, London
18
have lifelong implications on an individual’s health. Cycling Design Standards.
20 Supplementary Planning Document: Air Quality Supplementary Planning Document: Air Quality 21Heating, Cooling and Power Supply 100. Ideally, only gas-fired boilers with ultra-low for the National Grid. These generators can 111. Applications for development that has
nitrogen oxides (NOx) emissions should be result in high short-term concentrations of air emissions will be required to provide
95. The Chancellor in the Spring Statement 2019 used in new developments. The Sustainable NO2 and for diesel generators, particulate evidence of the:
announced the introduction of a Future Design and Construction SPG defines these matter. The STOR plant typically operate
Homes Standard, which will mandate the end as boilers with emissions below 0.04 gNOx/ for 200-300 hours per year which is pollution control system;
of fossil-fuel hearing systems in all new houses kWh. sufficient, if the emissions are high, to maintenance schedule; and
from 2025. At the time of writing this SPD have a significant impact on long term
this Standard has not been finalised. This SPD 101. Gas plant will be required to meet high average concentrations. Therefore, back-up management systems to mitigate the
will be kept under review and if necessary, standards of air pollution control, with generators installed in the borough should impact.
updated in light of any potential future particular emphasis on: only be used for the sole use of emergency
changes to the standards of new homes or power and not for generating power to sell 112. For those developments not subject to the
other updated government guidance. boiler design and operation; to the grid. pollution control regime, planning consent
stack height; will include a planning condition requiring
96. In Air Quality Focus Areas (AQFAs), Low 106. In Air Quality Focus Area (AQFA), Clean the servicing and maintenance of the
Emission Neighbourhoods (LENs) and Clean pollution abatement equipment; Air Zone (CAZ) or Local Neighbourhood pollution control system.
Air Zones (CAZs), heating, cooling or power servicing and maintenance; and Zone (LNZ) STOR plants are entirely
for new developments should be derived ultra-low NOx emissions. inappropriate.
from grid electricity, solar power or heat Air Quality Focus Areas (AQFAs), Low
pumps rather than through the combustion 107. Air quality assessments must take account of Emission Neighbourhoods (LENs) and
of fossil fuels. Wood burning stoves or other 102. Flues from energy plant must be at least the cumulative impact of the emissions from Clean Air Zones (CAZs)
combustion plant must not be provided. 1m above the highest part of the building, the generator(s) and the local road traffic
and in many circumstances will need to be emissions. The local planning authority may 113. AQFAs, LENs and CAZs have been
97. The use of low emission gas-fired plant significantly higher. The appropriate stack use a planning condition to limit the hours of designated in locations where there is
will be permitted outside these areas, but height should be determined using dispersion operation of the generators to those used in unacceptable air pollution and for AQFA
not the use of biomass, due to its higher modelling not using the Memorandum the air quality assessment. and LENs high exposure, which needs to be
emissions compared to gas. on Chimney Heights22 or the Technical reduced as quickly as possible to protect
Guidance Note (Dispersion) (known as a 108. A planning condition will be imposed human health. Introducing new emission
98. The use of centralised boilers, combined D1 calculation)23, which are not suitable for requiring all plant to be serviced and sources into these areas, or areas bordering
heat and power plants (CHP) and combined considering annual mean NO2 concentrations. maintained according to the manufacturer’s and having an adverse effect on them, is
cooling, heat, and power (CCHP) plants specification (see appendix E). In addition, contrary to this aim and not consistent with
has been promoted as more sustainable 103. Flues should not be ‘hidden’ behind structures a planning condition will be imposed the Borough’s Air Quality Management
than a large number of small boilers. These that affect the dispersion of emissions. that requires details of the plant and its Plans and therefore contrary to the NPPF.
centralised energy systems can be more abatement system to be approved by the All developments proposed in or adjacent
efficient than individual boilers, particularly 104. An air quality assessment (AQA) of the local planning authority prior to the building to these areas must play their part in
when it comes to reducing carbon dioxide impact of boiler emissions should be being occupied. ensuring that air quality in these areas does
emissions. It is noted that these types of undertaken to show that there will not be an not worsen and must contribute towards an
plants can impact on local air quality as unacceptable impact on local air quality (see overall improvement in air quality.
pollutants are typically emitted from a single Section on Assessing Air Quality Impacts, Industrial and Commercial Premises
point rather than from many over a larger especially paragraphs 95 to 108). The 114. Therefore, development within these
area, resulting in a greater impact on local specification of ultra-low emission boilers 109. The air quality assessment of the impacts areas need to robustly demonstrate that
air quality close to the point of emission. does automatically negate this requirement. of industrial emissions depends on the type the impact of both direct and indirect
of process and may include the impact of emissions24 can be fully mitigated.
99. Combined heat and power (CHP) plants are 105. Backup generators that operate the traffic associated with the development
discouraged from an air quality perspective. infrequently are becoming more common as well as the emissions from the process 115. Combustion plants should be avoided in
When sited and sized in accordance with for the supply of emergency power (e.g. itself. All potentially significant impacts from these areas. Buildings are expected to use
the energy demands of the building, they for large offices and data centres as well major development on air quality must be electric space and water heating, preferably
can have benefits in terms of reduced as industrial processes) and the supply of assessed, typically using a dispersion model. generated using renewable energy sources,
carbon dioxide emissions. However, it short-term operating reserve (STOR) power such as solar power and heat pumps.
should be noted that they usually give 110. For smaller operations that may give rise
rise to higher emissions of NOx and/or to odours, dust, smoke, dust or other air
particulate matter (PM) than regular gas Department of the Environment, 1981, The 1956 Clean Air
22 emissions, including commercial operations 24
Direct emissions are those from the development itself,
boilers. Therefore, if they are to be used, Memorandum on Chimney Heights. such as nail bars and commercial kitchens, indirect emissions are those associated with the development
abatement technology to reduce emissions information on the pollution control systems such as those from the traffic generated by the development.
23
Her Majesty’s Inspectorate of Pollution, 1993. http://laqm.
to below 0.04 gNOx/kWh will be required. defra.gov.uk/documents/LAQM-TG16-April-16-v1.pdf may be sufficient.
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