The new Air Quality Strategy (AQS) was published on the 28th April 2023, fulfilling the statutory requirement of the amended Environment Act 2021.
Who is it aimed at?
Local authorities. Where there are two tier authorities, upper tier authorities (county councils) are also expected to contribute to district council air quality plans and strategies. The document sets out local authorities powers, responsibilities, and further actions the government expects them to take.
Why is it important?
Air quality continues to present the most significant environmental risk to public health; a hard-hitting reality that often gets overlooked due to its familiarity. It is crucial to acknowledge the most vulnerable members of society, including children, the elderly, and those who are already susceptible to health challenges, are most affected. While it may be tempting to skim over this fact if we don't fall into these categories, it is essential to recognize that at some point, we all will, and many of us have loved ones who are currently in these vulnerable groups.
Therefore, the significance of this document lies in its ability to hold local government accountable for delivering cleaner air for our communities. Local authorities possess both the authority and the intimate knowledge of their regions to effectively address the specific issues that contribute to local pollution.
What is expected of Local Authorities?
Local authorities are already required to monitor air quality in their administrative areas. Monitoring generally covers NO2, PM10 and PM2.5. They are also required to declare Air Quality Management Areas (AQMAs) where limits are being exceeded, and publishing subsequent Air Quality Action Plans which sets out measures they will take to come back into compliance.
With the new legally binding PM2.5 targets, local authorities will be expected to take them into account in decision-making, to help achieve these targets. An expanded coverage of PM2.5 monitoring across the administrative areas may also be necessary to facilitate decision-making.
The government have explicitly stated that if they consider action from individual local authorities to be inadequate, they will initiate consultations regarding the implementation of a distinct legal obligation on these authorities to take decisive action against PM2.5 emissions.
Local authorities have an obligation to publish their own local Air Quality Strategy, outlining a proactive and preventative approach, rather than solely responding to breaches of legal limits. Hence, the new AQS document requires local authorities to plan ahead in regard to air quality.
In respect to planning ahead, local authorities will be expected to actively engage in ensuring the integration of air quality considerations, in conjunction with various other disciplines, at the design and planning stages of proposed developments.
What are the main changes to be aware of?
Currently, the focus of monitoring efforts has predominantly revolved around NO2, with the declaration of Air Quality Management Areas (AQMAs) primarily driven by exceedances or localized concentrations of NO2. However, the spotlight has now shifted to fine particulate matter, specifically PM2.5, demanding increased attention and scrutiny.
The AQS focusses on the reduction of PM2.5 following the introduction of new legally-binding long-term targets. Further information on the new targets can be found in my previous blog post on ‘The Environment Act 2021 Air Quality Targets. What’s the latest?’
On top of new national targets, local authorities have a heightened level of responsibility to improve the local air quality within their respective jurisdictions, alongside an obligation to work towards achieving the national targets.
There is more onus on considering air quality in combination with other disciplines. Air quality needs to be considered in line with health, economic growth, nature, and net zero. Local authorities need to ensure trade-offs and tensions are avoided between air quality and climate change where possible. Impacts of poor air quality on biodiversity has been highlighted as a key consideration.
How will this affect the planning and development industry?
While air quality is already an obligatory factor for numerous planning proposals within local authority areas, the implementation of a comprehensive local air quality strategy, coupled with the government's proactive efforts, indicates that air quality will assume an even greater significance during the planning and design phases of proposed developments nationwide. Nevertheless, it is important to acknowledge that local authorities may progress at varying speeds, underscoring the crucial need for early engagement and effective communication with the respective local planning authority.
The government is pushing for local authorities to use their powers in reducing PM2.5. Consequently, this will necessitate the assessment of PM2.5 emissions associated with proposed devleopment, as well as the assessment of PM2.5 concentrations in the designated project area, as an integral part of the air quality evaluation process for planning applications. Moreover, the emphasis on reducing PM2.5 will inevitably impact the construction phase of these developments.
There is a growing imperative to integrate air quality considerations with various other disciplines at the design stage of a development. The ongoing planning reforms will prioritise environmental issues, placing them at the heart of the reformed system. Design-stage emission prevention means influencing the design of a scheme at an early stage, aiming to minimize pollution emitted during the scheme’s life. This entails advocating for a holistic approach to the design and planning stage of developments, one that encompasses air quality with health considerations, economic growth, preservation of nature, and the pursuit of net-zero objectives.
How can Exe Valley Environmental help?
Exe Valley Environmental provide a range of air quality consultancy services to assist with the planning and design stages of a development. If you’re unsure what assessments your project will require in terms of air quality, drop me a call/message for some non-committal advice.