The UK annual limit for NO2 pollution is 40 µg/m3. This was the same as the WHO guideline until 2021, when the WHO recommended limit was updated to 10 µg/m3.
DEFRA Clean Air Strategy 2019 – We are now also proposing tough new goals to cut public exposure to particulate matter pollution, as recommended by the World Health Organization.
Air Quality Management Areas (AQMAs) are declared when there is an exceedance or likely exceedance of an air quality objective.
The above map overlays the Wates “R” report modelling NO2 levels based on third party reports with the ACTUAL NO2 readings provided by Kent University to Bray Parish Council (Full reports below).
At the RBWM Planning Meeting on 2nd November 2022 application 22/00934 was considered and following the meeting I shared Bray Parish Councils Air Quality Report with RBWM Planning Officers.
On 5th October, planning app 23/00582, 135 homes were given the go ahead by Cllrs at AL21 North, new homes have recently been built at the old Squires site, film studios are being constructed at Bray Studios and a quarry being excavated opposite the studio, all offering new sources of NO2.
It is very clear from the following differentials between modelled and actual diffusion tube monitoring that the modelling is way off and real measurements are needed over 12 months before any more significant planning applications in the area are granted.
Picking two areas for comparison between MODELLED and ACTUAL NO2 readings.
Wates Modelling Report shows the following readings for R7, R8 & R9.
2019 – 18.9, 18.3, 21.5
2023 – 15.7, 15.2, 17.6
Bray Parish B4, an actual monitoring diffusion tube in the same area, showed a bias corrected actual for 2021 of 18.9 with a January 2023 reading of 29.9.
R3 on Squires Roundabout is showing predictions of 17.7 in 2019 and 15.0 in 2023, while the B3 bias corrected actual reading for 2021 was 19.2 and January 2023 read 29.2, almost 2x the Wates modelling.
B2 Dedworth Road ACTUAL bias corrected reading is 25.7 for 2021 and 39.8 for January 2023. B5, Oakley Green / Windsor Road junction is 15.5 bias corrected for 2021 and 20.3 for January 2023 with plans for two sets of traffic lights within 100m.
Why have Bray Parish Councils readings been ignored? Constant reminders from officers that if not permitted by Cllrs then it would go to the Inspector who would permit and RBWM would incur costs. Would the inspector ignore the NPPF, BLP and legal obligation to review the need for an AQMA around this part of Dedworth?
All the information below, much of it presented by Wates in their Air Quality Assessment Report, supports a call for RBWM to commission independent monitoring of the area to consider the need for a AQMA before any more significant development applications are granted.
Wates Air Quality Assessment (Full doc below)
4. ASSESSMENT METHODOLOGY
4.1 Baseline
In order to establish baseline air quality in the study area of the site, relevant third party monitoring data was collected, reviewed and assessed. Data was obtained from the following sources: Automatic and diffusion tube monitoring data from the RBWM Annual Status Report17; and Department of Environment, Food and Rural Affairs (Defra) background maps18 . No additional site-specific air quality monitoring was carried out.
3.1.2 Clean Air Strategy, 2019 Defra published a new Clean Air Strategy 2019 in January 2019, setting out how the UK will significantly reduce harmful air pollutant emissions by 2020 and 2030. The Clean Air Strategy contains an intention of working towards the World Health Organisation guideline value for PM2.5 of 10µg/m3 .
3.1.4 Where a local authority’s review and assessment of its air quality identifies that air quality is likely to exceed the NAQOs, it must designate these areas as AQMAs and draw up an Air Quality Action Plan (AQAP) setting out measures to reduce pollutant concentrations with the aim of meeting the NAQOs.
3.1.5 NPPF Paragraph 174 on conserving and enhancing the natural environment states: “Planning policies and decisions should contribute to and enhance the natural and local environment by: … e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land stability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality …
Paragraph 186 states that: “Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas.
Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement. So far as possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.”
3.1.6 Planning Practice Guidance The Planning Practice Guidance (PPG)15 was launched as an online resource in March 2014 to support the NPPF and has separate guidance on air quality. Paragraph 001, Reference 32-001- 20191101 06 (revision date 01 11 2019) of the PPG provides the following summary as to why air quality is a consideration for planning: “…It is important that the potential impact of new development on air quality is taken into account in planning where the national assessment indicates that relevant limits have been exceeded or are near the limit, or where the need for emissions reductions has been identified.”
Policy EP2 Air Pollution states: ‘1. Development proposals will need to demonstrate that they do not significantly affect residents within or adjacent to an Air Quality Management Area (AQMA) or to residents being introduced by the development itself. 2. Development proposals which may result in significant increases in air pollution must contain appropriate mitigation measures, (such as green infrastructure, sustainable travel, electric vehicle charging parking points, limited vehicle parking, awareness raising, and enabling smarter travel choices) thus reducing the likelihood of health problems for residents. 3. Development proposals should aim to contribute to conserving and enhancing the natural and local environment, by avoiding putting new or existing occupiers at risk of harm from unacceptable levels of air quality. Development proposals should show how they have had regard to the UK Air Quality Strategy or any successive strategies or guidance, ensuring that pollutant levels do not exceed or come close to exceeding national limit values
2022 Air Quality Annual Status Report (ASR)
1. Local Air Quality Management
The LAQM process places an obligation on all local authorities to regularly review and assess air quality in their areas, and to determine whether or not the air quality objectives are likely to be achieved. Where an exceedance is considered likely the local authority must declare an Air Quality Management Area (AQMA) and prepare an Air Quality Action Plan (AQAP) setting out the measures it intends to put in place in pursuit of the objectives.
2. Actions to Improve Air Quality
2.1 Air Quality Management Areas Air Quality Management Areas (AQMAs) are declared when there is an exceedance or likely exceedance of an air quality objective. After declaration, the authority should prepare an Air Quality Action Plan (AQAP) within 12 months setting out measures it intends to put in place in pursuit of compliance with the objectives.
Conclusion
RBWM need to follow their own guidance, recognise the professionally assessed data provided by Kent University to Bray Parish Council and ask them or another independent contractor to review the need for an area bounded by Oakley Green Road, Dedworth Road, Maidenhead Road, Ruddlesway be declared an AQMA and prepare a Air Quality Action Plan.
LINKS TO DOCUMENTS
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