New Air Quality guidance for London and the impact on developers
Huge progress has been made in improving London’s air quality over recent years, but still tens of thousands of Londoners breathe illegally polluted air. The London Plan 2021 Spatial Development Strategy for Greater London, published in March 2021, strives to improve air quality in the capital by introducing a new requirement for larger developments to be Air Quality Positive. Air Quality specialists Fiona Prismall and Kathryn Barker explain how air quality guidance has changed with the emergence of Air Quality Positive statements and the likely implications for developers.
18 March 2022 | 4 min read
Kathryn Barker
Air Quality Neutral vs Air Quality Positive
Previous London Plans had already included the concept of Air Quality Neutral which applied to developments with 10 or more residential dwellings or 1,000 m2 of non-residential floorspace. Air Quality Neutral is designed to address the problem of multiple developments that individually add only a small amount to pollution, but cumulatively lead to pollution levels creeping up. In other words, it focuses on controlling the growth in London’s regional emissions. For larger developments, it is still necessary to assess the local impacts which are not captured by the Air Quality Neutral approach.
To streamline assessment procedures for minor developments, the latest London Plan varies the existing approach to demonstrating air quality neutrality and, for larger projects, introduces the concept of Air Quality Positive.
While the Air Quality Neutral assessment is quantitative, the Air Quality Positive statement is more qualitative – it outlines how air quality considerations have influenced the design of the scheme and signposts the location of the evidence.
The new London Plan promised further guidance to explain the new approaches and in November 2021, the Greater London Authority (GLA) published two new draft guidance documents related to air quality: Air Quality Neutral Guidance and Air Quality Positive Guidance. The consultation period for the draft guidance closed on 27th February and the final guidance is expected to be published later this year.
How has the Air Quality Neutral guidance changed?
The new Air Quality Neutral guidance applies to all developments in London, where previously it was only required for developments with 10 or more residential units or 1,000 m2 of other floorspace. This means that air quality will now be a consideration for every development, at least to some extent. The good news is that the new streamlined approach introduces some new simpler criteria that will mean that some developments can be deemed Air Quality Neutral without the need for a detailed Air Quality Neutral assessment. Simple assessments are likely to apply to developments that generate little to no traffic and use ultra-low NOx boilers or zero emission heat sources, such as air or ground source heat pumps.
Detailed Air Quality Neutral assessments require a comparison of emissions generated by the development with benchmark values. Like the current approach, emissions from the exhausts of additional vehicles on the roads and/or from the flues of plant in energy centres are quantified and compared with benchmarks. If the benchmarks are exceeded, the development is not air quality neutral, and the scheme will need to be modified to ensure the benchmarks are met.
If, after the scheme is modified, the benchmarks are still not met there is the option for offsetting. This involves an assessment to determine the monetary value of emissions generated by a development that should be paid to offset the emissions. This is likely to be a significant cost to the applicant and early consideration of measures to reduce emissions, preferably built into the development's design, are important both environmentally and financially.
What is an Air Quality Positive Statement?
An Air Quality Positive Statement is a new requirement for masterplans and development briefs for large-scale development proposals subject to Environmental Impact Assessments. Despite being similar in name to Air Quality Neutral, the methodology is very different.
While the Air Quality Neutral assessment is quantitative, the air quality positive statement is more qualitative and requires “planners, designers, architects and air quality experts to show what measures have been taken during the design stages to achieve the best possible outcomes for air quality”[1]. Air Quality Positive Statements outline how air quality considerations have influenced the design of the scheme and signpost the location of the evidence. They also highlights how measures to improve air quality can be secured e.g., approved plans, conditions etc. which would require agreement with the council.
As the statement needs to summarise the air quality considerations undertaken, it's important to get an air quality consultant involved in your scheme during the design stage. Air quality consultants can advise on ways to reduce both the future occupants’ exposure to poor air quality and the development’s impact on air quality.
What do I need to submit with my planning application?
Based on the draft guidance documents, developers will potentially need to provide evidence that the development is Air Quality Neutral through an air quality impact assessment and/or an Air Quality Positive Statement.
The diagram to the right summarises what is required. Click on the image to magnify.
Air quality experts
We are keeping a close eye so that when the final guidance is released later in the year, we are ready to help clients ensure they have the appropriate assessments.
For EIA projects in their early stages, it's likely that the final guidance will be published by the time the application is ready to be submitted - so it’s important to consider getting an air quality consultant on board earlier in the design stage than you previously would.
Once the final guidance is published, we will be drafting a quick guide to help developers understand what is required for their developments. Watch this space. And for any questions in the meantime drop us a note and we'll be happy to help.
References
[1] https://www.london.gov.uk/what-we-do/planning/implementing-london-plan/london-plan-guidance/air-quality-positive-aqp-guidance-consultation
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