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Local Air Quality Management Brighton & Hove, England Progress Report 2014
1
2014 Air Quality Progress Report for Brighton and Hove City Council In fulfillment of Part IV of the Environment Act 1995 Local Air Quality Management August 2014
Local Air Quality Management Brighton & Hove, England Progress Report 2014
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Local Authority Officer Samuel Rouse
Department Public Health
Address
Environmental Protection Team Brighton and Hove City Council Bartholomew House Bartholomew Square Brighton BN1 1JP
Telephone 01273 29 2256 e-mail samuel.rouse@brighton-hove.gov.uk Report Reference number BHCC PR_2014
Date August 2014
Local Air Quality Management Brighton & Hove, England Progress Report 2014
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Executive Summary
The council declared a new Air Quality Management Area (AQMA) on 30 August 2013. The new AQMA is a quarter the size of the previous one and includes all exceedance of Nitrogen Dioxide. The council is developing a renewed 2014/15 air quality action plan targeting this area.
Continuous analysis of outdoor air indicates long term improvement in nitrogen dioxide outside of the AQMA. Improvements are recorded in lower density areas, outer roadside locations and suburban neighborhoods where prevailing air quality is good. In combination with source reductions in lead, benzene, sulfur dioxide and carbon monoxide it is likely that where many people live the air inhaled is more healthy than 10 or 20 years ago.
Monitoring at city center roadside sites suggests that nitrogen dioxide concentrations have not improved since 2001/2. At a number of roadside locations NO2 concentrations are the same as those recorded ten or twelve years ago. Provisional indications suggest this remains the case during 2014. Concentrations continue to show levels above the NO2 legal limit within nine meters (30 feet) of confined roads in parts of Brighton, Portslade and Rottingdean. The existing strategy is linked with the Local Transport Plan and is associated with the Sussex Air Quality Partnership. The 2015 bus Low Emission Zone (LEZ) will cover North Street, Churchill Square and Western Road. This is one of the UK’s first LEZ1. In 2013 Brighton and Hove won competitive bids to the Clean Bus Transport Fund, this is matched funded by local bus company support allowing over £ one million for the retrofit of older buses in order to mitigate emissions of oxides of nitrogen. It is recommended that the air quality action plan will promote alternatives to diesel in the new management area (for example methane and electric vehicle use) and influence local planning policies regarding the massing and position of buildings and their energy use. The Environmental Protection Team consults on planning applications and air quality is a material consideration for the planning process.
There has been impressive progress in providing travel choice in the city including a doubling in bus patronage since the early 1990s and encouragement of walking and cycling. However a number of other measures require implementation if the EU and English limits for nitrogen dioxide are to be met. The use of electrical vehicles in Brighton & Hove has increased in recent years, but this category remains a tiny contribution to local transport. The local bus company has secured funds for electrical hybrid buses now in daily operation. It is recommended that the city join with partners in West Sussex in order to utilise anaerobic digestion of organic waste to produce biogas (methane) fuel for local transport use.
1 EU low emission zones public authorities UK Brighton http://lowemissionzones.eu/public-authorities
Local Air Quality Management Brighton & Hove, England Progress Report 2014
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Table of Contents
1 Introduction 8
1.1 Description of Local Authority Area 8
1.2 Purpose of Progress Report 9
1.3 Air Quality Objectives 9
1.4 Summary of Previous Review and Assessments 11
2 Recent and New Monitoring Data 14
2.1 Summary of Monitoring Undertaken 14
2.2 Comparison of Monitoring Results with Air Quality Objectives 25
3 New Local Developments 44
3.1 Major Developments and Brighton’s Air Quality Action Plan 44
3.2 Preston Barracks Development A270 46
3.3 Shoreham Harbour Regeneration 46
3.4 Brighton Centre and Churchill Square A259 47
3.5 AMEX Headquarters (near Circus Street) 47
3.6 Sackville Estate 47
3.7 Circus Street Market: Brighton 48
3.8 Royal Sussex County Hospital 48
3.9 Open Market (London Road near New England Quarter) 48
3.10 New England House 48
3.11 King Alfred Sport Complex and Residential 49
3.12 Anston House Development A23 49
3.13 Pelham College 50
3.14 Falmer Community Stadium and Hotel 50
3.15 Meadow Vale housing 50
3.16 Black Rock A259 50
3.17 Brighton Marina Inner 50
3.18 Brighton Marina Outer 51
4 Pollution Sources 52
4.1 Road Traffic Sources 52
4.2 Other Transport Sources 56
4.3 Industrial Sources 56
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4.4 Commercial and Domestic Sources 57
4.5 New Developments with Fugitive or Uncontrolled Sources 57
5 Local / Regional Air Quality Strategy 58
6 Air Quality Planning Policies 59
7 Local Transport Plans and Strategies 60
8 Climate Change Strategies 61
8.1 Common agreement between climate change and air quality includes: 61
8.2 Potential difference of interest between greenhouse gas reduction and air
quality: 62
9 Implementation of Action Plans 63
9.1 Schedule for AQAP Revision 63
9.2 Area of Exceedance 63
9.3 New Action Plan Measures 63
10 Conclusions and Proposed Actions 73
10.1 Conclusions from New Monitoring Data 73
10.2 Conclusions relating to New Local Developments 73
10.3 Proposed Actions 73
11 References 74
12 Appendix: QA: QC Data 75
12.1 Diffusion Tube Bias Adjustment Factors 75
12.2 Discussion of Choice of Factor to Use 76
List of Tables Table 1-1 Air Quality Objectives included in Regulations for the purpose of LAQM in England 10 Table 1-2 Order of Brighton and Hove LAQM reports 1999 to 2014 11 Table 2-1 Active & Archive Automatic Monitoring Sites in and around Brighton & Hove 19 Table 2-2 NO2 Diffusion Tube Monitoring Sites 2013 West Area 22 Table 2-3 NO2 Diffusion Tube Monitoring Sites 2013 Central Area 23 Table 2-4 Diffusion Tube Monitoring Sites 2013 in East Area 24 Table 2-5 Results of Automatic Monitoring for NO2: Comparison with Annual Mean Objective 26 Table 2-6 Results of Automatic Monitoring for NO2: Comparison with 1-hour Mean Objective 29 Table 2-7 Results of AQMA NO2 Diffusion Tubes 2013 Ranked by Order of Concentration 30 Table 2-8 Results of NO2 Diffusion Tubes 2013 Ranked by Order of Concentration Outside of AQMA33 Table 2-9 Results of NO2 Diffusion Tubes (2009 to 2013) 33 Table 2-10 Results of Automatic Monitoring for PM10: Comparison with Annual Mean Objective 37 Table 2-11 Archive Results of Automatic Monitoring for PM10: Comparison with Annual Mean
Objective 37 Table 9-1 Action Plan Progress Lead Authority BHCC (unless stated) 67
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List of Figures Figure 1-1 Brighton and Portslade 2013 AQMA 13 Figure 1-2 Rottingdean 2013AQMA 13 Figure 2-1 Recent and Active Automatic Monitoring Sites 18 Figure 2-2 Nitrogen Dioxide Diffusion Tubes Monitoring in West Area 2013 20 Figure 2-3 Nitrogen Dioxide Diffusion Tubes Monitoring in Central Area 2013 20 Figure 2-4 Nitrogen Dioxide Diffusion Tubes Monitoring in East Area 2013 21 Figure 2-5 NO2 Distribution through the Calendar Year 2013 27 Figure 2-6 Trends in Annual Mean Concentrations Measured at Automatic Monitoring Sites NO2
µg/m3 2001 to 2014 28 Figure 2-7 Annual Average Nitrogen Dioxide Concentrations measured at Diffusion Tube sites
Central Brighton 2006 to 2013 36 Figure 2-8 Middle North Street (DT77 or C11) diffusion tube since records began in 2006 36 Figure 2-9 Seven PAH molecular structures 41 Figure 2-10 Monthly and seasonal pattern in Benzo[a] Pyrene, Hove 2009 to 2013 42 Figure 3-1 The I-360 Observation Tower is scheduled to open 2016 44 Figure 3-2 Development Areas Brighton & Hove (with former AQMA) 45 Figure 3-3 Major Developments in and around Brighton & Hove and 2013 AQMAs 45 Figure 4-1 Brighton and Hove –Fuel Consumption Trends 2005 to 2012 54 Figure 4-2 Brighton and Hove - Fuel Consumption by Travel Type 2005 to 2012 54 Figure 12-1 Co-Location Questionnaire for BH6 75 Figure 12-2 Co-Location Questionnaire for BH10 76 Figure 12-3 Short-Term to Long-Term Monitoring Data Adjustment 77 Figure 12-4 WASP Proficiency Scheme for Nitrogen Dioxide diffusion analysis 2013 78
Glossary
Abbreviation Explanation AQ Air Quality ambient or outdoor
ADMS Atmospheric Dispersion Model System
AQAP Air Quality Action Plan statutory requirement where an AQMA has been declared
AQMA Air Quality Management Area declared under the part IV of the Environment Act 1995
AQS Air Quality Strategy for England
BAM Bata Attenuation Monitor particulate monitoring method
BHCC Brighton and Hove City Council unitary authority
BQPA Bus Quality Partnership Agreements
BREEAM Building Research Establishment Environment Assessment Methodology
CBTF DfT's Clean Bus Transport Fund
CEMP Construction Environment Management Plan
CIL Community Infrastructure Levy
CRT Continuous Regenerating Trap for tailpipe mitigation of particulate
CVTF DfT's Clean Vehicle Transport Fund
DA Development Areas
DECC Department for Energy and Climate Change
Defra Department for Environment Food and Rural Affairs
DfT Department for Transport
DPF Diesel Particulate Filter
EC European Commission
EPR Environmental Permitting Regulations
Euro Standards European emissions standards set out for light and heavy vehicles
Flywheel Flywheel regenerative breaking or KERS
GIS Geographical Information Systems
HGV Heavy Goods Vehicles
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IPPC Integrated Pollution Prevention Permits for industry
JAAP Joint Area Action Plan that includes development area covering Adur and BHCC
JSNA Joint Strategic Needs Assessment multidisciplinary health report
KERS Kinetic Energy Recovery System
LA Local Authority
LAT Local Action Team
LAQM Local Air Quality Management
LDF Local Development Framework
LEP Local Enterprise Partnership
LES Low Emission Strategy
LEZ Low Emission Zone
LSTF Local Sustainable Transport Fund
LTP4 Local Transport Plan 4
mg/m3 concentration milligrams per cubic meter
NO2 Nitrogen Dioxide
NOx Oxides of Nitrogen including NO and NO2
NPPF National Planning Policy Framework
O3 Ozone near ground level
OLEV Office of Low Emission Vehicles
PAH Poly Aromatic Hydrocarbons
PEMS Portable Emission Monitoring System
PM10 Particulate Matter less than ten microns
PM2.5 Particulate Matter less than two and a half microns
PM1 Particulate Matter less than one micron or nano-particulate
ppb concentration parts per billion
ppm concentration parts per million
RHI Renewable Heat Incentive
S106 Section 106 Funding under Town and Country Planning Act 1990
SA Special Areas
SAQP The Sussex Air Quality Partnership sometimes referred to as Sussex Air
SCR Selective Catalytic Reduction NOX tailpipe abatement
SCRT Selective Catalytic Reduction Technology used in conjunction with CRT
TEA Triethanolamine in water method for NOx diffusion tubes
TEOM Tapered Element Oscillating Microbalance particulate monitoring method
TG(09) LAQM Technical Guidance 2009
TRO Traffic Regulation Order
USA Updating Screening Assessment air quality report
µg/m3 Concentration in micrograms per cubic meter
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1 Introduction
1.1 Description of Local Authority Area Brighton and Hove City Council (BHCC unitary authority) is the majority constituent of
the Brighton-Worthing-Littlehampton agglomeration2 in Sussex on the South Coast of
England. It is estimated that approaching half a million inhabitants live across four
Sussex authorities between Peacehaven in the east and Littlehampton in the west.
The 2011 census indicated that the city’s population rose by 25,000 in the decade
since the previous census3. In June-2014 the local address gazetteer accounted for
over 141,000 residential dwellings in BHCC. On this basis the city’s population is
estimated to pass 290,000 by 2015/16. The urban area between the South Downs
National Park and the English Channel has one of the highest population densities in
the UK; that is similar to a number of London Boroughs. In contrast, part of the
council area includes the South Downs National Park where population densities and
air pollution are amongst the lowest in the South East of England.
A reasonable assumption for vehicle ownership is one vehicle for every two people.
It is estimated there are approximately a quarter of a million vehicles registered
across the Brighton to Littlehampton conurbation. However, 38% of households in
Brighton do not own a car, which is one of the highest proportions in the country.
Brighton is one of the most popular tourist attractions in the South-East and the city
attracts nine million visitors a year, many of them arriving by train.
Under Part IV of the Environment Act (1995) BHCC has declared two amended Air
Quality Management Areas (AQMAs) totalling 243 hectares (600 acres) for none
compliance of Nitrogen Dioxide (NO2) standards (annual mean and hourly). The new
2013-AQMAs are substantially reduced (by 77%) in area compared with the previous
declaration in 2008. It is estimated that 10,000 people live in the current AQMAs.
2 For Defra reports to the EC the UK is divided into 43 rural and urban regions. Brighton and Hove City council is partly within the South East Region and is also part of the Brighton-Worthing-Littlehampton agglomeration recognised a distinct urban conurbation on the South Coast 3 Reference to the 2011 Census Results http://www.brightonbusiness.co.uk/htm/ni20120717.660827.htm
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1.2 Purpose of Progress Report This report fulfils the requirements of the Local Air Quality Management (LAQM)
process as set out in Part IV of the Environment Act (1995), the Air Quality Strategy
for England, Scotland, Wales and Northern Ireland 2007 and the relevant Policy and
Technical Guidance documents. 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
exceedances are considered likely, the local authority must then 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.
Progress Reports are required in the intervening years between the three-yearly
Updating and Screening Assessment reports. Their purpose is to maintain continuity
in the LAQM process.
They are not intended to be as detailed as Updating and Screening Assessment
Reports, or to require as much effort. However, if the Progress Report identifies the
risk of exceedance of an Air Quality Objective, the Local Authority (LA) should
undertake a Detailed Assessment immediately, and not wait until the next round of
Review and Assessment.
1.3 Air Quality Objectives The air quality objectives applicable to LAQM in England are set out in the Air
Quality (England) Regulations 2000 (SI 928), The Air Quality (England) (Amendment)
Regulations 2002 (SI 3043), and are shown in Table 1.1. This table shows the
objectives in units of micrograms per cubic metre µg/m3 (milligrams per cubic metre,
mg/m3 for carbon monoxide) with the number of exceedances in each year that are
permitted (where applicable).
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Table 1-1 Air Quality Objectives included in Regulations for the purpose of LAQM in England
Pollutant Air Quality Objective Date to be achieved by Concentration Measured as
Benzene 16.25 µg/m3 Running annual
mean 31.12.2003
5.00 µg/m3 Annual mean 31.12.2010
1,3-Butadiene 2.25 µg/m3 Running annual mean 31.12.2003
Carbon monoxide 10 mg/m3 Running 8-hour mean 31.12.2003
Lead 0.50 µg/m3 Annual mean 31.12.2004 0.25 µg/m3 Annual mean 31.12.2008
Nitrogen dioxide
200 µg/m3 not to be exceeded more than 18 times a
year
1-hour mean 31.12.2005
40 µg/m3 Annual mean 31.12.2005
Particulate Matter (PM10)
(gravimetric)
50 µg/m3, not to be exceeded more than 35 times a
year
24-hour mean 31.12.2004
40 µg/m3 Annual mean 31.12.2004
Sulphur dioxide
350 µg/m3, not to be exceeded more
than 24 times a year
1-hour mean 31.12.2004
125 µg/m3, not to be exceeded more than 3 times a year
24-hour mean 31.12.2004
266 µg/m3, not to be exceeded more
than 35 times a year
15-minute mean 31.12.2005
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1.4 Summary of Previous Review and Assessments A comprehensive list of BHCC Review and Assessment submissions is presented in
Table 1-2. The table lists the reports and actions in chronological order. The AQMA
declarations under section 84 of part IV of the Environment Act 1995 are marked as
bold. Stage 1 was completed in 1999. The first AQMA was declared during the
second round of air quality assessment in 2004. The third round of assessment in
2008 declared an expanded AQMA (1050 hectares) for nitrogen dioxide with
exceedances of the objective adjacent to roadside as a result of emissions from road
traffic.
Sustained improvements in nitrogen dioxide concentrations monitored by continuous
analysers and diffusion tubes at outer roadside locations and suburbs justified
revocation of a substantial part of the 2008 AQMA (800 hectares) in August 2013. At
the same time following further monitoring and modelling set out in the 2012 detailed
assessments, two smaller areas were declared. This includes Rottingdean village
High Street in the east of the council’s area and the Preston Road/Preston Drove
area north of Central Brighton.
Table 1-2 Order of Brighton and Hove LAQM reports 1999 to 2014
Review and Assessments Report Words
Dated
Stage 1 Consultation Draft 7,000 January 1999
Stage 2 & 3 Final Report 9,600 June 2000
Second round Updating Screening and Assessment
9,100 May 2003
First Detailed Assessment
5,500
May 2003
Declaration of the 2004-AQMA April 2004
Second round Progress Report 11,200 April 2005
Third round Updating Screening and Assessment
10,400 April 2006
First Air Quality Action Plan for the 2004-AQMA
30,500 March 2007
Second Detailed Assessment leading to declaration of the 2008-AQMA
9,000 September 2007
Further Assessment following 2008-AQMA deceleration
10,000
Final January 2008
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Third round Progress Report 10,000 April 2008 Declaration of expanded AQMA February 2008 AQMA declaration amendment to include the short-term NO2 AQO
October 2008
Fourth round Updating Screening and Assessment
8,000 April 2009
Further Review and Assessment on expanded AQMA
16.900
May-October 2010
Draft Air Quality Action Plan on expanded AQMA
34,300
Fourth Round Progress Report and Action Plan Progress Report
12,700
2011 Air Quality Action Plan 43,000
July-2011
Preston Drove Detailed Assessment 8,000 October 2012 Rottingdean Detailed Assessment
Updated Screening and Assessment 14,500 Revocation and Deceleration of AQMA New AQMA for Rottingdean High Street and Preston Drove Preston Road junction
August 2013
2014 Progress Report August- 2014
1.4.1 Other Local Reporting for Air Quality
The information gleaned from local air quality modelling and monitoring investigations
is used to provide advice and information to the following policies and projects:
• Air Quality Chapter in the Joint Strategic Needs Assessment in association
with the Health Directorate
• Public Health Annual Report
• Assessment and Air Quality Cost Benefit Analysis of the Valley Gardens
Transport Scheme
• Air Quality Section of The Local Transport Plan (LTP4)
• Transport Authorities Key Performance Indicators for Air Quality
• Clean Bus Technology Fund (CBTF) Progress Reports
• Clean Vehicle Technology (CVTF) Fund Bids
• Transport Action Group Progress Report
• City Policy on Sustainable Transport
• City Planning Policy on Special Areas and Development Areas
• The Joint Area Action Plan with Worthing and Adur District Council for the
Shoreham Harbour re-development area
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• Monitoring Feedback to the local CIVITAS (Institute for Study of Civil Society)
project on electrical charging points
• Consultee response to Road Safety Team’s Safer Routes to School
programme and informative to the CIVITAS project on air monitoring at
schools
Figure 1-1 Brighton and Portslade 2013 AQMA
Figure 1-2 Rottingdean 2013AQMA
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2 Recent and New Monitoring Data 2.1 Summary of Monitoring Undertaken Driven by the statutory duties of the Environment Act 1995, LAQM has delivered a
long term sequence of local air monitoring. In recent years a more certain picture
has emerged regarding the distribution of local pollution. This knowledge has been
used to make informed decisions regarding the location of today’s active monitors.
Brighton and Hove aims to better understand why pollution is not improving along
certain transport corridors. Monitoring focuses on the remaining AQMA which is
priority for air quality improvement, emission reduction and pollution avoidance.
Regional or background monitors compliment the AQMA analysis. The city has its
place as part of the UK monitoring network for nitrogen dioxide, particulate matter
(PM2.5) and PAH (Poly Aromatic Hydrocarbons). Local continuous analysers are
coded BH for Brighton and Hove. Some of the BH sites relate to the former Mobile
Air Quality Monitoring Unit (MAQMU). In the past decade MAQMU was from time to
time located at sites for durations shorter than one calendar year. Continuous
cabinet connections in the AQMA on Lewes Road and North Street will remain for
longer durations in order to assess trends. This section provides a description of the
relevant continuous analysers in and around Brighton & Hove.
2.1.1 Lullington Heath Regional Background AURN LH - NOx, O3, SO2
The Defra AURN (UK Automatic Urban Rural Network) monitor is outside of Brighton
and Hove at Lullington Heath within Wealden District Council. Defra’s mapped
concentrations (1km2 resolution) to the north of Brighton’s urban area suggest similar
levels to those monitored at Lullington Heath. The site is representative of the
Sussex Downland Environment remote from roads, towns and industry. Oxides of
nitrogen and ozone concentrations recorded at the site represent regional
background input for the ADMS-urban dispersion model which is useful to assess
how air quality varies across the local authority area. The site complies with the
calibration, validation and ratification requirements of AURN. Monitoring at the site
continues.
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2.1.2 Leyton Road Hove UK PAH network Background LR - PAH
The analyser is part of the UK Poly Aromatic Hydrocarbons (PAH) monitoring
network. The network has a geographical spread of sites from Scotland to the South
Coast. The urban background site in Hove is next to the Brighton to Portsmouth
railway line. Filter plate changes are fortnightly with six monthly local service operator
calibrations carried out by the council. The site is managed and audited by National
Physical Laboratory in accordance with procedures set out by Defra for the UK PAH
network. Results show a consistent seasonal pattern and have consistently been
compliant with objectives for benzo (a) pyrene over many years. Monitoring at the
site continues, but is under review by Defra.
2.1.3 Preston Park AURN Urban Background BH0 –NOx, O3, PM2.5
The Defra AURN monitor in the park records nitrogen dioxide, particulate matter
(PM2.5) and ozone (O3). Nitrogen dioxide at the site has shown improvement since
records began in 2006. The site is useful to verify dispersion models for urban
background outside of the city centre. The site is managed by Bureau Veritas. It
complies with the calibration, validation and ratification requirements of AURN.
Monitoring at the site continues.
2.1.4 Brighton Pavilion Urban former AURN BH1 – NOx, CO, SO2
In the past this site was referred to as Brighton Roadside. The sample inlet, 4m up on
the gatehouse of Pavilion Park is set back from Church Street, a local road link to
Brighton’s North Laines. In accordance with LAQM technical guidance (TG09) the
sample point cannot truly be characterised as a roadside site. It is set back from the
main road (A23 Northbound Marlborough Place) by 18 metres. Diffusion tubes
suggest concentrations of 150% within a few metres of the A23. Monitoring
discontinued after 2010 as the grade II listed building was required by site
management. The location is very close to the 2013-AQMA boundary and is now
most likely compliant with the NO2 annual average at the height of the former sample
inlet. Defra have used the former AURN site (1998-2010) to verify their model for
submission to the commission. This is not representative of nitrogen dioxide levels in
the Brighton AQMA.
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2.1.5 Hove Town Hall Roadside BH2 - NOx
The monitoring site is above Church Road in Hove and was active for more than a
decade up to 2012. The street is broad and a number of the local bus routes turn
inland away from this transport corridor before passing this monitoring location.
Monitoring and modelling evidence suggest higher concentration elsewhere so the
location does not represent worst case. Regular calibrations were carried out by
the council with biannual audits certified by National Physical Laboratory (NPL).
From 2001 the monitor showed a continued improvement in nitrogen dioxide.
Combined with modelling and tube evidence this helped justify 2013 revocation of the
AQMA across the majority of Hove with the exception of some crossroads with
associated queuing traffic.
2.1.6 Lewes Road Kerbside BH6 – NOx, PM10
The monitor adjacent to the Lewes Road academic corridor and bus lanes is a short
distance south of the Vogue Gyratory. The sample location is in the AQMA and the
Local Sustainable Transport Fund (LSTF) corridor. The site started in 2012 for NOx
and 2014 for PM10 using a Beta Attenuation Monitor (BAM). Records can be
compared with a mobile monitoring unit also south of the Gyratory during 2005 and
2006. Fortnightly filter changes and calibrations are carried out by Transport
Research Laboratory (TRL). The sample inlet is co-located with three diffusion tubes
used to derive a local bias correction factor that is verified by NPL. Concentrations
recoded at BH6 have been: 50 µg/m3 NO2 over some years. Monitoring at the site
continues.
2.1.7 Stanmer Park Rural BH8 – O3
The rural location is 100 m above sea level and is separated from the A27 dual
carriageway and the city by a wooded ridge. The site provides data to the Sussex
Ozone Network and the air alert service that is managed by the Environmental
Research Group (ERG) Kings College, University of London. Since 2012 monthly
filter changes and calibrations are carried out by Transport Research Laboratory
(TRL). Ozone monitoring at Stanmer continues and replaces Foredown Tower (BH3)
as that building is no longer leased by the council.
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2.1.8 Beaconsfield Road BH9 – NOx, O3, PM10
The monitor adjacent to the A23 southbound is close to the boundary of the current
AQMA. The site is influenced by; emissions from traffic rounding a corner of the road
but also by good prevailing air quality from nearby parks and gardens. The site was
active for three years spanning 2011 to the end of 2013. NOx analysers and PM10
Tapered Element Oscillating Microbalance (TEOM) equipment were transferred to
monitoring sites BH6 or BH10 and the ozone analyser will be used to support the
Sussex network in Worthing. During this period nitrogen dioxide showed an
improvement and is now clearly compliant with all objectives at BH9. Fortnightly filter
changes and calibrations have been carried out by Transport Research Laboratory
(TRL) from mid-2012. The sample inlet was co-located with three diffusion tubes
used to help derive a local bias correction factor that was verified by NPL.
2.1.9 North Street BH10 - NOx, PM10
The monitor is located 6m back from one of the busiest bus routes in the UK. The city
centre location has high pedestrian counts and is a busy retail area. The sample
location is in the AQMA and the Brighton bus Low Emission Zone (LEZ agreed by
committee to commence 01.01.2015). The site started in 2012 for NOx and 2013 for
PM10. The compact cabinet houses NOx analyser and PM10 TEOM. Fortnightly filter
changes and calibrations are carried out by Transport Research Laboratory (TRL).
Records can be compared with several diffusion tube samplers along the transport
corridor within 1km. The sample inlet is co-located with three diffusion tubes used to
help derive a composite local bias correction factor that is verified by NPL.
Concentrations recoded at BH10 are approximately; 60 µg/m3 NO2 as a three year
mean. Monitoring at the site continues. Other evidence including; diffusion tube,
emission analysis and dispersion modelling suggest that BH10 is not at the worst
location for nitrogen dioxide in Brighton. This is likely nearer to the eastern approach
to the Clock Tower junction close to tube monitor C11-12; about 300 metres to the
west of BH10. The location of BH10 and all the other active and recent analysers in
the city centre is shown in Figure 2-1. Continues analyser details are listed in Table
2-1.
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Figure 2-1 Recent and Active Automatic Monitoring Sites
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Table 2-1 Active & Archive Automatic Monitoring Sites in and around Brighton & Hove
Site Name Site Type Active
Monitoring Period
X OS Grid Ref
Y OS Grid Ref
Pollutants Monitored
In NO2 AQMA?
Monitoring Analyser
TechniquesRelevant
Exposure?
Triangular Distance to kerb of main road
(m)
Does this location
represent worst-case exposure?
Beaconsfield Road Monitor BRM BH9 Roadside Feb 2011 to Jan
2014 531002 105918 NOx, O3, PM10 Yes near Boundary API and TEOM
Nearby houses and doctors
surgery 3 No
Lewes Road Monitor
BH6 Roadside Since June 2012 532082 105694 NOx
Yes
API Yes (3) 1.5
Yes North Street Monitor
BH10 Roadside Since April 2012 530995 104271 NOx API Yes (0) 6
Preston Park BH0 Urban
Background Since 2006 530526 106218 NOx, O3, PM2.5 No
API and
Partisol No 200 No
Hove Town Hall BH2 Roadside 1998 to 2012 528963 104731 NOx
No
API In Line 5 No
Brighton Pavilion
BH1 Urban 1998 to 2010 531295 104319 NOx API No 18 No
Stanmer Park
BH8 Rural
Since March
2010 533457 109526 O3 N/A API No > 200 No
Foredown Tower
BH3 Rural Up to 2010 525690 107169 O3 N/A API No 150 No
Lullington* Heath
Wealden AURN
Regional
Background Since 1990s 553800 101600 NOx, O3, SO2, No API No N/A No
Telscombe Cliffs,
LS01 Lewes DC Roadside 2002 to 2009 540010 101305 NOx, O3, PM10 No API, TEOM No 4 No
Leyton Road, Hove
LR
Urban
Background Since 2002 528041 105693 PAH N/A
Anderson
Analyser No N/A No
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2.1.10 2013 Non-Automatic Monitoring Sites
Figure 2-2 Nitrogen Dioxide Diffusion Tubes Monitoring in West Area 2013
Figure 2-3 Nitrogen Dioxide Diffusion Tubes Monitoring in Central Area 2013
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Figure 2-4 Nitrogen Dioxide Diffusion Tubes Monitoring in East Area 2013
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Table 2-2 NO2 Diffusion Tube Monitoring Sites 2013 West Area
Archive Diffusion
Tube Number or year started
Diffusion Tube
change order in
West Area
X OS Grid Ref
Y OS Grid Ref Street
Near A or B
Road?
Horizontal Distance to kerb of road (m)
Estimated Height (m)
Triangular Distance to kerb of road (m)
Does this location
represent worst-case exposure?
DT 05 W01-C12 530969 104785 Queens Road A2010 3.5 2.8 4.5 Y 2010 W02 530963 104837 Surrey Street A2010 4.6 2.6 5.3 Y DT 06 W03 530963 104994 Terminus Road Hill A2010 1.8 3 3.5 Y DT 73 W04 530809 105338 Chatham Place-New England Road B2122 1.6 3 3.4 Y DT 74 W05 530778 105362 Old Shoreham Road- Hill A270 1.7 3.2 3.6 Y DT 64 W07 530554 105142 Dyke Road-Seven Dials RS* A2010 0.2 3 3.0 Y DT 69 W08 530586 105104 Buckingham Place-Seven Dials A2010 7.6 3.5 8.4 Y DT 76 W10 530302 104415 Western Road west of Churchill Sq B2066 3.2 3.2 4.5 Y 2012 W12-12 528423 104809 Church Road Hove B2066 3 2.7 4.0 Y DT 57 W16 526248 104857 Wellington Road-Basin Road A259 2.1 2.7 3.4 Y
DT 59a W17 525931 104961 Wellington Road-Church Road A259 1.3 2.7 3.0 Y 2010 W18 525970 105230 Vale Park, Portslade BG 97 2.8 97.0 N
DT 58a W19 525657 105696 Trafalgar Road, Portslade facade B2139 2.7 2.8 3.9 Y 2010 W20-13 525653 105717 Trafalgar Road, Portslade kerbside B2139 1.5 2.8 3.2 Y DT 52 W21 528388 105934 Sackville Road-Old Shoreham Rd A2023 2 2.8 3.4 Y
All West Area sites are inside the 2013 revised AQMA with exception of W18 background. West Area (“W” codes) include a tube replacement circuit orienteered from the City Centre through Hove to Portslade.
All monitors are located on residential building-lines or facades with exception of those denoted with: RS = Roadside and BG = Background.
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Table 2-3 NO2 Diffusion Tube Monitoring Sites 2013 Central Area
Archive Diffusion
Tube Number or year started
Diffusion Tube
change order in Central
Area
X OS Grid Ref
Y OS Grid Ref Street
Near A or B
Road?
Horizontal Distance to kerb of road (m)
Estimated Height (m)
Triangular Distance to kerb of road (m)
Does this location
represent worst-case exposure?
2010 C01 531171 103962 East Street 2.7 2.4 3.6 N 2010 C02 531231 103919 Near Pool Coach Station 1.2 2.5 2.8 Y DT 40 C03 531439 104045 Saint James Street B2118 2.7 2.7 3.8 Y 2010 C04 531228 104088 Lower North Street-Castle Square B2066 5 2.7 5.7 Y 2012 C05-12 531230 104260 Pavilion Gardens Background BG N/A 102 2.8 102 N DT 86 C08 531292 104321 Brighton Pavilion Lower A23 18 2.4 18.2 N DT 09 C09 531302 104392 Marlborough Place A23 2.8 3.2 4.3 Y DT 77 C11 530947 104284 North Street Central B2066 5.8 3 6.5 Y 2011 C12 530900 104451 Queens Street north of Clock Tower A2010 3 3 4.2 Y
DT 68a C13 530761 104371 Lower Dyke Road-Churchill Square B2121 1 3.1 3.3 N 2010 C14 530833 104276 West Street south of Clock Tower A2010 3.9 2.8 4.8 N DT 10 C15 531401 104669 Gloucester Place re-instated 2014 A23 7.8 3 8.4 Y DT 11 C16 531400 104844 York Place A23 4 2.8 4.9 Y
DT 15a C17 531319 104974 Cheapside nr Pelham Street A270 2.4 2.4 3.4 Y 2010 C18 531373 105136 Oxford Street-London Road 2.2 2.5 3.3 Y
DT 27a C19 531472 105161 Oxford Street-Ditchling Road 2.2 2.6 3.4 Y DT 25 C20 531496 105315 Ditchling Road-Viaduct Terrace A23 4.2 2.2 4.7 Y DT 24 C21 531451 105356 Viaduct Terrace A23 1.8 3.1 3.6 Y DT 26 C22 531424 105286 Kingsbury Street ceased >2013 BG 57 3 57.1 N DT 17 C23 531189 105375 London Road-Preston Circus A23 4.5 3 5.4 Y DT 16 C24 531101 105443 New England Road-Preston Circus A270 2.2 2.8 3.6 Y 2010 C25 530985 105419 New England Road-Argyle Road A270 2.3 2.7 3.5 Y 2010 C27 531151 104850 Trafalgar Street B2199 1.3 2.5 2.8 Y 2010 C28 531032 104843 Frederick Place B2199 1.4 2.4 2.8 Y
All Central Sites are inside the 2013 AQMA with exception of C01 East Street and C05-12 Pavilion Gardens Background. All Central (“C”) diffusion tube monitors are located in Central Brighton.
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Table 2-4 Diffusion Tube Monitoring Sites 2013 in East Area
Archive Diffusion
Tube Number or
year started
Diffusion Tube
change order in
East Area
X OS Grid Ref
Y OS Grid Ref Street
Near A or B
Road?
Horizontal Distance to kerb of road (m)
Estimated Height (m)
Triangular Distance to kerb of road (m)
Does this location
represent worst-case exposure?
DT19 moved E01 531090 105510 Preston Road-Preston Circus A23 3.5 2.8 4.5 N DT21 E02 530233 106508 Preston Road-Preston Drove A23 3 2.7 4.0 Y 2010 E03-E05 531002 105918 Beaconsfield Road Co-location A23 2.5 2.6 3.6 Y DT 22 E06 531102 105615 Beaconsfield Road-Preston Circus A23 3 2.6 4.0 Y DT 30 E08 532085 105740 Lewes Road-Inverness Road A2073 3.5 2.6 4.4 Y 2010 E09 532105 105735 Lewes Road opposite previous A2073 3.8 2.7 4.7 Y 2010 E10 532126 105838 Vogue Gyratory Island A270 4.1 2.7 4.9 Y 2010 E11 532146 105832 Vogue gyratory opposite previous A270 3.7 2.7 4.6 Y DT 31 E12 532021 105946 Hollingdean Road C1060 1.7 2.9 3.4 Y DT 82 E13 532415 106190 Coombe Road 4 2.8 4.9 Y DT 32 E14 532377 106313 Lewes Road Lectern Pub A270 2.7 2.6 3.7 Y 2010 E15 532306 106173 Lewes Road Coombe Terrace A270 3.6 2.6 4.4 Y DT 38 E16 531465 104628 Grand Parade Middle A23 3.8 3.2 5.0 Y DT 08 E17 531402 104365 Grand Parade University Building A23 4.2 2.7 5.0 Y 2013 E17-13 532614 103813 Paston Place adjacent to taxi rank 1 3 3.2 Y DT 43 E18 532759 103810 Eastern Road opposite Hospital C5260 1.9 2.9 3.5 Y DT 78 E21 536914 102446 High Street-Vicarage La, Rottingdean B2123 0.8 2.6 2.7 Y DT 79 E22 536970 102280 High Street Rottingdean East Side B2123 1.7 2.6 3.1 Y 2010 E23 536966 102273 High Street Rottingdean West Side B2123 0.4 2.6 2.6 Y
All East Areas Sites are within the 2013 AQMA with the exception of E17-13. The East Area (“E”) circuit includes north and east of the city centre, Royal County Hospital and Rottingdean Village which has its own separate AQMA.
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2.2 Comparison of Monitoring Results with Air Quality Objectives All monitors show compliance with pollutant objectives with the exception of Nitrogen Dioxide. Recent monitoring confirms 24-hour
and annual PM10 standards set out in the English Air Quality Strategy (AQS) are met. However it should be noted these are not as
stringent as World Health Organisation (WHO) recommendations. For a true health assessment it would be appropriate to monitor
PM2.5 at roadside in order to help determine more accurately the cost benefit analysis of air quality improvement.
2.2.1 Nitrogen Dioxide (NO2)
Background monitoring away from roads shows an encouraging picture of improvement. Background monitors in the area show levels
of nitrogen dioxide less than half the objective levels. All exceedances are adjacent to transport corridors and road intersections within
the city. The low levels of NO2 at urban and regional background emphasize the importance of local sources. Concentrations above
limit levels are recorded within several metres of stop-start transport corridors and busy bus routes.
The use of continuous regenerating traps on euro-III diesel vehicles to mitigate particulate has almost definitely increased nitrogen
dioxide emissions. For the AQMA we cannot say with confidence that health effects are predominately because of particulate. Locally
nitrogen dioxide is the much more plentiful pollutant. Typically in the AQMA nitrogen dioxide (max monitored; 114 µg/m3 as a two year
mean) is 2.3 to 4.4 times more concentrated than PM10 (24 to 32 µg/m3 recent annual means). In reality health impact will be due to
the mixture of pollutants in both particulate and gaseous phases. Results from recent continuous nitrogen dioxide monitoring are set
out in Table 2-5. The abnormal distribution of hourly levels through 2013 is given in Table 2-5 for four sites; one background and three
at roadside. Trend analysis over several years suggests a lack of improvement in nitrogen dioxide along certain transport corridors or
confined streets. These patterns are supported by repeated diffusion tube evidence over a substantial geographical area.
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Automatic Monitoring Data
Table 2-5 Results of Automatic Monitoring for NO2: Comparison with Annual Mean Objective
Site ID Site Type Within AQMA?
Valid Data Capturefor First six
months 2014 % aValid Data
Capture 2013 % b
Annual Mean Concentration (µg/m3)
2010 2011 2012 2013 Half 2014
LH Regional Background N 98.7 94.9 10.3 7.5 9 8.5 6.4
BH0 Urban Background N 99 97 21.7 16.9 16 16.7 15.1
BH6 Kerbside Y 95 92 d e 50f 48.4 50
BH9 Roadside Close to boundary N/A 99.5 N/A 36.3 35.9 31 N/A
BH10 Roadside Yes & LEZ 99.9 95 63 59.7 58.1
In bold, exceedance of the NO2 annual mean AQS objective 40µg/m3. Likely Exceedance of the NO2 hourly objective > 200 µg/m3, more than 18 hours in the year are underlined.
Lullington Health (LH) is outside of the local authority area all other sites within Brighton & Hove City Council a Data for half year monitoring period, 2014 six months up to 30/06/2014 b Data capture for the full calendar year 2013 d Continuous analyser close to BH6 for part of 2005 result = 45.3 e Continuous analyser close to BH6 for part of 2006 result = 46.5 f 2012 results for BH6 for partial year annualised with ratio reference to local BH9 in accordance with LAQM (TG09)
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Figure 2-5 NO2 Distribution through the Calendar Year 2013
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Figure 2-6 Trends in Annual Mean Concentrations Measured at Automatic Monitoring Sites NO2 µg/m3 2001 to 2014
0
10
20
30
40
50
60Lullington Heath Downlan
BH0 Preston Park AURN
BH1 Brighton Pavilion AUR
BH2 Hove Town Hall
BH5 Viaduct Road Firestat
BH6 Lewes Road nr Gyrato
BH7 Gloucester Quad Que
BH9 Beaconsfield Road
BH10 North Street
Table 2-6 shows NO2 annual mean results compared to the legal limit of 40µg/m3 since 2001 for Brighton & Hove sites and Lullington
Health Defra’s Automatic Urban Rural Network (AURN) that is representative of regional background or open downland. The
council’s Mobile Air quality Monitoring Unit (MAQMU) moved from BH5 to BH6 to BH7 and was active for three years at site BH9
close to the AQMA-boundary. It ceased to monitor after 2013. BH8 & BH3 are and were ozone analyser sites that never recorded
NOx. The site at Leyton Road is part of the UK PAH network. Fixed cabinets were installed at Lewes Road (BH6) and North Street
for 2012 (BH10). Regional trends show an improvement in NO2 across Sussex sites away from confined or stop-start roads. An
improvement has not been recorded for a number of streets and transport corridors within the 2013-AQMA.
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Table 2-6 Results of Automatic Monitoring for NO2: Comparison with 1-hour Mean Objective
Site ID Site Type Within AQMA?
Valid Data Capture for First six months 2014
% a
Valid Data Capture 2013
% b
Number of Hourly Means > 200µg/m3
2011* c 2012* c 2013* c 2014 to date c
BH6 Kerbside Y 95 92 (6) 17 0
BH9 Roadside Close to boundary 99.5 5 1 0 N/A
BH10 Roadside Yes & LEZ 99.9 95 (32) 11 1
In bold, exceedance of the NO2 hourly mean AQS objective (200µg/m3 – not to be exceeded more than 18 times per year
2012 data for <75% of the year results factored for a full year in (brackets)
a i.e. data capture for the monitoring period, in cases where monitoring was only carried out for part of the year
b i.e. data capture for last full calendar year
c If the data capture for full calendar year is less than 90%, annualised to one year
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Diffusion Tube Monitoring Data
Table 2-7 Results of AQMA NO2 Diffusion Tubes 2013 Ranked by Order of Concentration
Site ID Location Triplicate? Full Calendar Year Data Capture 2013 (Number of Months
2013 Annual Mean Concentration (µg/m3) -
Bias Adjustment factor = 0.9b
Adjacent Transport Corridor
C11-12 North Street East of Clock Tower* N 10 114.8 B2066 Central Brighton 2350 buses a day
C11 North Street Middle N 12 84.6 B2066 Central Brighton 2350 buses a day
C18 Oxford Street near London Road N 10 68.6 A23 London Road Area 1800 buses a day
E08 Lewes Road South West of Gyratory N 8 67.8 A2073 Lewis Road Corridor >1000 buses a day
E07-12 Lewes Road Elm Grove Junction N 11 65.8 A2073 Lewis Road Corridor >1000 buses a day
C10-12 North Street next to Ship Street Co-Located with BH10 11 65.5 B2066 Central Brighton
2350 buses a day
C09 Marlborough Place (A23) N 11 60.2 A23 Valley Gardens >1000 buses a day
C04 Castle Square east of East Street N 12 58.1 B2066 Central Brighton 2350 buses a day
C21 Viaduct Terrace nr Ditchling Road N 12 57.9 A23 City Approach ~ poor flow at lights
C17-12 Cheapside nr London Road Junction N 12 56.9 A23 London Road Area Confined Space
W10 Western Road west of Churchill Sq N 10 55.8 B2066 Central Brighton 1250 buses a day
W05 Old Shoreham Rd Hill nr Chatham N 11 55.3 A270 western approach to Preston Circus
C19 Oxford Street near Ditching Rd N 12 54.6 A23 London Road Area
C25 New England Road nr Argyle Road N 12 53.2 A270 western approach to Preston Circus
W03 Terminus Road nr Brighton Station N 9 53.1 A2010 approach to Main Station
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Site ID Location Triplicate? Full Calendar Year Data Capture 2013 (Number of Months
2013 Annual Mean Concentration (µg/m3) -
Bias Adjustment factor = 0.9b
Adjacent Transport Corridor
C28 Frederick Place, North Laine N 12 51.6 Confined North Laine
W19 Trafalgar Road, Portslade N 11 51.1 B2139 Portslade Freight Route > 900 HGV a day
E02-12 The Drove West of Railway Tunnel N 8 50.7 Confined Hill Climb
W17 Wellington Rd - Church Rd Junction N 12 50.2 A259 Portslade Freight Route
W20-12 Trafalgar Road Lamppost, Portslade N 12 49.9 B2139 Portslade Freight Route > 900 HGV a day
C23 London Road near Preston Circus N 11 49.8 A23 London Road Area
C12 Queens Road north of Clock Tower N 12 49.7 A2010 approach to Main Station
C24 New England Road nr Preston Circus N 12 49.6 A270 western approach to Preston Circus
C16 York Place (A23) N 12 49.3 A23 Valley Gardens
BH6 Lewes Road south of Gyratory Co-Located with BH6 11 49.2 A2073 Lewis Road Corridor
C12-12 Main Station taxi rank Queens Road N 8 48.8 A2010 approach to Main Station
W04 Chatham Place nr New England Road N 11 48.2 A270 western approach to Preston Circus
E02 Preston Road near Preston Drove N 12 48.2 A23 City Approach
W21 Sackville Road at Hove Park PH N 12 47.7 A2023 Sackville Road
approach to Old Shoreham Road
E12 Hollingdean Road N 9 47.6 Spur off A2073 Lewes Road
E23 High Street Rottingdean (west side) N 11 47.0 B2123 Rottingdean High Street
E15-12 Coombe Terrace, Lewes Road N 11 46.5 A2073 Lewis Road Corridor
E09 Lewes Road south of Gyratory N 12 46.3 A2073 Lewis Road Corridor
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C20 Ditchling Road near Viaduct Terrace N 11 45.7 A23 City Approach
E16 Grand Parade nr Morley St (A23) N 11 45.5 A23 Valley Gardens
E10 Lewes Road Vogue Gyratory East N 10 45.2 A2073 Lewis Road Corridor
W16 Wellington Rd - Basin Road Junction N 11 45.0 A259 Portslade Freight Route
E17 Grand Parade nr Edward St (A23) N 11 44.8 A23 Valley Gardens
E22 High Street Rottingdean (east side) N 11 44.5 B2123 Rottingdean High Street
E14 Lewes Road north of Gyratory N 8 43.8 A2073 Lewis Road Corridor
E01 Preston Road nr Preston Circus N 11 42.8 A23 Out of City
W01 Queens Road nr Brighton Station N 9 42.7 A2010 approach to Main Station
E18 Eastern Road opposite hospital site N 9 42.2 Eastern Road Corridor (remaining tube of four)
E06 Beaconsfield Road nr Ditchling Rise N 11 41.2 A23 City Approach
C03 St James Street N 11 39.9 B2118 Central Brighton
W08 Buckingham Place nr Seven Dials N 11 39.9 A2010 approach to Main Station
C27 Trafalgar Street, North Laine N 11 38.7 Confined North Laine
W12-12 Church Road Hove near Hove Street N 12 36.8 B2066 Hove west of LEZ
E21 Vicarage Lane, Rottingdean N 11 36.5 B2123 Rottingdean
Vicarage Lane nr High Street
C02 Pool Valley Coach Station N 10 35.6 Close to Coach Station & Sea Front
C22 Kingsbury Street 57m back from main road 12 35.1 Set back from A23 City
Approach
C08 Pavilion Gardens North Gate 18m back from main road 10 34.6 Set Back from A23 Valley
Gardens
EO3-E05 Beaconsfield Road Groundhog Co-Located with BH9 11 34.1 A23 City Approach AQMA
boundary Results in bold are 90% or more compared to the legal limit concentration. Bold Locations are in the bus low emissions zone.
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Table 2-8 Results of NO2 Diffusion Tubes 2013 Ranked by Order of Concentration Outside of AQMA
Site ID Location Triplicate Co-
Location? Roadside unless stated
Full Calendar Year Data Capture 2013 (Number of Months
2013 Annual Mean Concentration (µg/m3) -
Bias Adjustment factor = 0.9
C01 East Street, Old Town N 11 29.3
E17-13 10/11 Paston Place next to 8th taxi rank space N 6 (July to December) 28.2
C05-12 Pavilion Gardens, Brighton Background N 11 26.1
W18 Vale Park, Portslade Background N 12 23.0
In bold, exceedance of the NO2 annual mean AQS objective of 40µg/m3. Underlined, annual mean > 60µg/m3, indicating a potential exceedance of the NO2 hourly mean AQS objective
Table 2-9 Results of NO2 Diffusion Tubes (2009 to 2013)
Site ID Site Type Within AQMA LEZ?
Annual Mean Concentration (µg/m3) - Adjusted for Bias a 2009 (Bias
Adjustment Factor = 0.84
2010 (Bias Adjustment Factor =
0.85
2011 (Bias Adjustment Factor
=0.82
2012 (Bias Adjustment Factor
=0.91
2013 (Bias Adjustment Factor
=0.9 C11-12 K AQMA &
LEZ 114.3 114.8
C11 F 71.5 73.4 79.0 83.0 84.6C18 F
AQMA 76.6 65.4 65.0 68.6
E08 F 60.7 74.0 65.5 63.9 67.8E07-12 F 67.4 65.8
C10-12 F-CL AQMA & LEZ 61.6 65.5
C09 F AQMA 59.4 62.6 61.5 57.6 60.2
C04 F AQMA & LEZ 69.5 65.9 53.1 58.1
C21 FAQMA
68.7 72.8 70.9 62.4 57.9C17-12 F 62.9 56.9
W10 F AQMA & LEZ 65.3 65.8 57.7 57.0 55.8
W05 F AQMA 54.8 60.9 54.4 42.6 55.3
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Site ID Site Type Within AQMA LEZ?
Annual Mean Concentration (µg/m3) - Adjusted for Bias a 2009 (Bias
Adjustment Factor = 0.84
2010 (Bias Adjustment Factor =
0.85
2011 (Bias Adjustment Factor
=0.82
2012 (Bias Adjustment Factor
=0.91
2013 (Bias Adjustment Factor
=0.9 C19 F 54.6 58.5 49.3 53.3 54.6C25 F 63.6 58.0 55.5 53.2W03 F 58.7 64.9 53.9 52.6 53.1C28 F New 51.6 50.0 47.7 51.6W19 F 57.9 59.2 51.3 52.1 51.1
E02-12 F 46.4 50.7W17 F 52 57.8 47.5 41.8 50.2
W20-12 F 49.3 49.9C23 F 56.4 58.3 53.6 50.9 49.8C12 F 49.7 67.7 55.8 55.5 49.7C24 F 53.3 62.8 51.9 53.8 49.6C16 F
AQMA AQMA
51.8 59.3 52.9 55.0 49.3BH6 K-CL 49.2
C12-12 F 48.8W04 F 53 56.2 47.7 46.8 48.2E02 F 50.5 55.1 48.2 44.0 48.2W21 F 56.2 46.4 45.8 47.7E12 F 49.7 51.2 46.4 47.2 47.6E23 F 53.7 48.4 46.2 47.0
E15-12 F 59.7 47.4 46.5E09 F 53.4 48.9 45.0 46.3C20 F 50.4 55.0 46.5 45.5 45.7E16 F 47.1 54.8 49.2 46.0 45.5E10 F 50.9 45.9 45.4 45.2W16 F 47 53.0 45.0 47.9 45.0E17 F 49.1 56.6 51.4 51.7 44.8E22 F 46 48.5 44.0 42.5 44.5E14 F 47.1 52.5 49.0 46.6 43.8E01 F 50.1 43.8 41.0 42.8W01 F 54.3 68.3 55.5 46.8 42.7E18 F 47.5 52.1 46.7 43.5 42.2E06 F 45.9 47.4 44.9 39.7 41.2C03 F 46.9 55.2 45.1 42.0 39.9
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Site ID Site Type Within AQMA LEZ?
Annual Mean Concentration (µg/m3) - Adjusted for Bias a 2009 (Bias
Adjustment Factor = 0.84
2010 (Bias Adjustment Factor =
0.85
2011 (Bias Adjustment Factor
=0.82
2012 (Bias Adjustment Factor
=0.91
2013 (Bias Adjustment Factor
=0.9 W08 F 49.3 52.7 46.7 39.9 39.9C27 F 48.9 41.5 41.8 38.7
W12-12 F 41.0 36.8E21 F 41.5 47.6 40.9 38.4 36.5C02 F 40.3 44.6 35.6C22 B 32.5 32.9 27.8 30.6 35.1C08 F 38.2 34.6 41.1 34.6
EO3-E05 R-CL 41.5 40.3 37.1 34.1C01 F
Not in 2013
AQMA
40.3 35.1 32.8 29.3E17-13 K 28.2C05-12 B 25.4 26.1
W18 B 26.2 24.1 22.8 23.0
Underlined, annual mean > 60µg/m3, indicating a potential exceedance of the NO2 hourly mean AQS objective
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Figure 2-7 Annual Average Nitrogen Dioxide Concentrations measured at Diffusion Tube sites Central Brighton 2006 to 2013
Figure 2-8 Middle North Street (DT77 or C11) diffusion tube since records began in 2006
NB: typical bias correction 0.8 or 0.9. Bus flows diverted away from North Street during part of 2007.
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2.2.2 Particulate Matter (PM10)
Background PM10 in Brighton is likely between 14 and 20 µg/m3, rising to between 22 and 34 at roadside. Monitors suggest an
improvement may have happened in recent years, although results are influenced by local conditions such as wind velocity and
rainfall. Airborne particulate matter is made up of black carbon, organics, sulphates, nitrate, ammonia, salt, mineral dust and metals.
Table 2-10 Results of Automatic Monitoring for PM10: Comparison with Annual Mean Objective
Site ID Site Type Within AQMA
for NO2?
Valid Data Capture for First six months 2014
% a
Valid Data
Capture 2013 % b
Confirm Gravimetric Equivalent (Y or N/A)
Annual Mean Concentration (µg/m3)
2011 c 2012* c 2013* c Part year
2014 c BH6 BAM Roadside Yes 91.1 N/A Y Started 2014 22
BH9 Roadside Near Boundary N/A 99.3
(2012) Y 22 27.7 Ceased
BH10 TEOM Roadside Yes 99.5 94.3 Y Started 2013 26 26 a Data capture for first half of 2014, monitoring continues
b Data capture for the last full calendar year where available
Table 2-11 Archive Results of Automatic Monitoring for PM10: Comparison with Annual Mean Objective
Site ID Site Type Within AQMA
for NO2?
Confirm Gravimetric Equivalent
Annual Mean Concentration (µg/m3)
2005c 2006* c 2007* c 2008c 2009
BH1 Kerbside Roadside Yes Partisol 31.7a 34.2 30.8 32.4b ceased
BH7 Gloucester Quad Queens Road Roadside Yes TEOM-VCR 33a 32.3a Telscombe Cliffs Lewes DC near
Saltdean, Brighton Roadside NO TEOM-VCR 29 29 29 26.5 24 a Data capture for part of the year.
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Site BH1 kerbside moved by Defra in 2009 to AURN at Preston Park to monitor for PM2.5. Further information re archive monitors is given in the 2012 LAQM reports.
Table 2.12 Results of Automatic Monitoring for PM10: Comparison with 24-hour Mean Objective
Site ID Site Type Within
AQMA for NO2?
Valid Data Capture for First six
months 2014 % a
Valid Data
Capture 2013 % b
Confirm Gravimetric Equivalent (Y or N/A)
Number of Daily Means > 50µg/m3
2011* c 2012* c 2013* cFirst Half
2014 c
BH9 Roadside Near Boundary Y 0 15 ceased
BH10 Roadside Yes 99.5 94.3 Y 3 7
In bold, exceedance of the PM10 daily mean AQS objective (50µg/m3 – not to be exceeded more than 35 times per year)
a i.e. data capture for the monitoring period, in cases where monitoring was only carried out for part of the year
b i.e. data capture for the full calendar year (e.g. if monitoring was carried out for six months the maximum data capture for the full calendar year would be 50%)
c If data capture for full calendar year is less than 90%, include the 90.4th percentile of 24-hour means in brackets
Local Air Quality Management Brighton & Hove, England Progress Report 2014
LAQM Progress Report 2014 39
2.2.3 Sulphur Dioxide (SO2)
There has been no monitoring of Sulphur Dioxide in Brighton and Hove since 2007.
Prior to that time all monitors suggested compliance with longer and short-term
objectives and there was no need to declare an AQMA for SO2. SO2 is one of the
few pollutants where traffic is not the main source; shipping and solid fuel burning are
more important. The English Channel shipping lane is approximately thirty miles
offshore from Brighton and is nearer to land at Dungeness and Folkestone. 2010
was the first year that SO2 was complaint with European standards across the EU4.
However the UK 15-minute mean objective is more stringent. Past UK AQMA
declarations for SO2 have been associated with a concentration of ferries such as in
Dover or crude oil refining for example Fawley in Hampshire. Ultra low sulphur diesel
and petrol contains < 10 ppm (parts per million) sulphur. As long as local coal
burning is not constant, prevailing SO2 concentrations after dispersion and dilution
are likely to be a few ppb (parts per billion). Acid rain is a phenomenon of the past
due to large combustion plant reduction of coal burning since the 1960s and 1970s.
Sulphur sensitive lichen species are expected on firm substrates in local cemeteries.
Local school projects have plotted the increase of lichen growth and diversity
between the Lewes Road Gyratory rising uphill through the Woodvale cemetery.
2.2.4 Benzene
Benzene monitoring results are included in the BHCC 2010 Progress Report.
Monitoring for a number of years using passive diffusion tubes at the busy Preston
Circus junction (A23 and A270) in Brighton suggests long term compliance with the
more stringent 2010 UK objective. The legislative requirement for larger petrol
stations to have vapour recovery has helped to reduce benzene emissions from the
petrol source. It may be that slightly higher concentrations in the winter are
associated with older petrol cold starts and domestic solid and fuel burning as
recorded for benzo[a]pyrene and explained in 2.2.6.
4 Air Quality in Europe 2012 Report http://www.eea.europa.eu/publications/air-quality-in-europe-2012/view
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2.2.5 Particulate Matter PM2.5
Defra’s automatic urban and rural network includes an air monitoring station in
Preston Park, Brighton. The site location is mapped in Figure 2-1. This site monitors
for PM2.5 using the partisol method. The very finest particulate can travel long
distances and legislation acknowledged that national and international action is
required in order to reduce ambient concentrations of finest particulate matter across
regions. At this time PM2.5 (Particulate Matter > than 2.5 microns) is not a statutory
duty on local authorities. Results from the national monitoring network located in
Preston Park are set out in Table 2-.
Table 2-13 Results of Automatic Monitoring for PM2.5 at Preston Park (Urban Background )
Year 2009 2010 2011 2012 2013
PM2.5 annual
mean µg/m3 11.1 10.6 12.1 10.9 11.2
Data Capture % 85.2 61.1 78.6 98.9 97.8 Comparison Annual Mean indicative annual limit value of 20 µg/m3
Urban Background at the Preston Park monitor is 200 metres from the main road (A23) Levels compare to the EU target of 25 µg/m3 for the calendar year5. The most
stringent EU standard for PM2.5 is the 2020 indicative annual limit value of 20 µg/m3.
PM2.5 is not monitored at roadside in the administrative area. If we assume city
centre PM10 is close to 30 µg/m3 and an 80% fraction is made up of PM2.5 within a few
metres of diesel traffic, this would suggest that PM2.5 at central roadside locations is
close to 24 µg/m3. Further funding and PM2.5 monitoring is required to determine with
greater certainty if this is the case. Anecdotal evidence suggests Continuous
Regenerating traps and diesel particulate filters have helped mitigate some particles,
but possibly not the smallest nano-particulate which make up part of the PM2.5 size
fraction.
2.2.6 Polycyclic Aromatic Hydrocarbons (PAH)
PAHs are a group of organic compounds some of which are toxic. Benzo[a]pyrene
(B[a]P) is carcinogenic and the PAH most harmful to human health; it is specified for
monitoring in the EC Fourth Daughter Directive (Directive 2004/107/EC). B[a]P is
5 European Air Quality Standards http://ec.europa.eu/environment/air/quality/standards.htm
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established as a suitable indicator to assess all PAH trace levels in ambient air6. The
UK monitoring network records seven different PAH molecular structures as shown in
Figure 2-9. The UK PAH network includes a continuous analyser at urban
background, Leyton Road in Hove. The location is mapped in Figure 2-1.
Figure 2-9 Seven PAH molecular structures
The EC target value for Benzo[a]pyrene (B[a]P) is 1.0 ng/m3 annual mean and the
more stringent UK air quality objective is 0.25 ng/m3 as an annual mean. Since
monitoring began at Hove in 2002 (data capture >90%) results indicate compliance
with both objectives. The highest recorded annual average occurred in 2010.
Table 2-14 Annual average Results from the PAH monitor, Hove
Monitor 2009 2010 2011 2012 2013
Leyton
Road (LR)
ng/m3
0.18 0.21 0.16 0.16 0.19
It is thought peaks relate to colder winters and higher incidence of domestic solid fuel
burning (coal, wood logs or refuse) for example freezing periods during Dec 2009
and Jan 2010, as shown in Figure 2-10. Interestingly, a consistent seasonal pattern
in Benzo[a] Pyrene is detected by the Hove monitor. Given that Brighton and Hove is
one of the least industrialised urban centres in Europe it is most likely these seasonal
patterns relate to domestic and small commercial burning of solid fuel as a winter
heating source. Using Defra funding Brighton and Hove has carried out a project to
increase awareness regarding the air quality implication of solid fuel burning; further
information is included on our webpages. It is also thought that PAH levels will be
6 UK PAH monitoring and analysis network annual report 2012, published January 2014 http://uk-air.defra.gov.uk/library/reports?report_id=782
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higher where diesel traffic emissions are concentrated i.e. where we record elevated
levels of NO2 in the AQMA.
Figure 2-10 Monthly and seasonal pattern in Benzo[a] Pyrene, Hove 2009 to 2013
2.2.7 Ground Level Ozone (tropospheric O3)
There is no statutory duty on local authorities to monitor ozone or declare an AQMA
for it. However nine monitors across Sussex including three continuous analysers in
Brighton and Hove feed valuable data into the Sussex air alert service7.
The stringent UK objective of no more than ten days where the max 8 hour mean >
100 μg/m3 O3 is consistently exceeded at monitoring locations across the region.
Results are presented in Table 2-. It is expected that rural sites at moderate altitudes
such as on the South Downs will have higher concentrations than roadside localities.
This is because the greater amounts of available NOx in higher density urban areas
can react with ozone, purging it from the lower atmosphere.
Table 2-15 Recent Results from ozone analysers
Site ID No of days max 8 hour mean > 100 μg/m3 objective = 10 Year 2009 2010 2011 2012 2013
Preston Park BH0 19 7 24 19 27Stanmer Park BH8 19 23 36 19
Beaconsfield Road BH9 Started 2011 2 5Exceedances of the objective in bold
7Sussex Air Alert Pollution Information Service http://www.airalert.info/
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Summary of Compliance with AQS Objectives
Brighton & Hove City Council has examined the results from monitoring in the City.
Concentrations within the AQMA still exceed the hourly and annual standards for
nitrogen dioxide within the amended 2013-AMQA and the AQMA should remain.
Following recent update of the AQMA the council’s next actions for LAQM will be to
update the air quality action plan within 18 months. This should be delivered by
February 2015.
Concentrations outside of the AQMA are all below the objectives at relevant
locations, therefore there is no need to proceed to a Detailed Assessment since the
one issued Decmeber-2012.
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3 New Local Developments 3.1 Major Developments and Brighton’s Air Quality
Action Plan National Planning Policy Framework (NPPF 2012)8 states that air quality is a material
consideration for planning applications. Developer contributions such as Section 106
or Community Infrastructure Levy (CIL)9 may be justified in order to support
mitigating measures to reduce the health impacts of poor air quality on the
population. This funding stream can support further assessment and cost benefit
analysis of air quality action plan measures. Running in parallel, major transport
schemes have the potential to improve the local environment and be of benefit to
local air quality. Major city developments have progressed recently, for example a
new community stadium is open for business and construction has started on the I-
36010.
Figure 3-1 The I-360 Observation Tower is scheduled to open 2016
The Rampion offshore wind farm is proposed to be one of the most substantial
infrastructure investments in Sussex for a century11.
8 National Planning Policy Framework https://www.gov.uk/government/publications/national-planning-policy-framework--2 9Community Infrastructure Levy https://www.gov.uk/government/policies/giving-communities-more-power-in-planning-local-development/supporting-pages/community-infrastructure-levy 10 I-360 Observation Tower http://www.brightoni360.co.uk/index.html 11 Rampion Offshore Wind Farm update http://infrastructure.planningportal.gov.uk/projects/south-east/rampion-offshore-wind-farm/
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Figure 3-2 Development Areas Brighton & Hove (with former AQMA)
Figure 3-3 Major Developments in and around Brighton & Hove and 2013 AQMAs
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Major developments with potential to alter the local traffic dynamic (flow and ratio of
bus, car, taxi and goods vehicle) around the AQMA are described in this section and
shown in Figure 1-3. Each major development is rated relatively to its potential to
influence the Air Quality Management Area (AQMA) and Air Quality Action Plan
(AQAP).
3.2 Preston Barracks Development A270 Potential to influence the AQAP: VERY HIGH The major development is next to the Lewes Road transport corridor. The proposal
includes mixed use employment-led redevelopment in the Academic Corridor
between the city centre and the universities. The land is especially valuable to the
cities development.
Preston Barracks site is included in the Core Strategy Submission document
(Development Area 3) as a Strategic allocation in the Academic Corridor. There is
potential to assist in meeting housing and employment floor space targets, with
scope for educational space. The site has potential for rapid electrical vehicle
charging and much needed taxi rank spaces.
A planning brief has been in place since 2011 and forms the basis for the future
development of the site in combination with adjacent and nearby land owned by the
University of Brighton. As at June 2014 the council is working and nearing
completion on a land deal to sell the Preston Barracks site to the university and
Cathedral Holdings Ltd. Transport measures have been implemented by the council
along Lewes Road, providing considerably improved bus and cycle lanes between
the city centre and the two university campuses at Falmer.
3.3 Shoreham Harbour Regeneration Potential to influence the AQAP: HIGH. The Joint Area Action Plan (JAAP) straddles the boundary between Brighton and
Hove and West Sussex. Land surrounding east and west river basins is proposed for
mixed land use regeneration12. The most important development considerations for
the western part of the city’s AQMA are the proximity of new residential units to 12 Harbour Regeneration Plan http://www.adur-worthing.gov.uk/media/media,121462,en.pdf
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Wellington Road and Trafalgar Road (A259) and any change to the traffic dynamic
along the A259 and B2193. In this part of the AQMA it is recommended that small
scale near ground level combustion is avoided. Any gas fired boilers should have
vertical flues and meet the most stringent ultra low NOx standards.
3.4 Brighton Centre and Churchill Square A259 Potential to influence the AQAP: HIGH. The concept includes replacement of the existing centre with a new world class
convention facility; integrated development to further expand Churchill Square
Shopping Centre (bus hub) and provision of 4/5 star hotel facilities. Core Strategy
Submission document (Development Area 1) includes the provision of a new
conference centre (28,000 m3 conference facility; 6 screen cinema; 317 bed hotel)
and expanded shopping centre. The City Council is working in an informal
partnership arrangement with Standard Life to advance a scheme which incorporates
the comprehensive redevelopment of Brighton Centre/ Kings West/ Oak Hotel site to
provide: a new international convention facility; ‘branded’ hotel; replacement cinema
and major extension to Churchill Square retail hub.
3.5 AMEX Headquarters (near Circus Street) Potential to influence the AQAP: HIGH.
The new headquarters for American Express (Europe) were delivered in 2012.
Edward Street Quarter and the new AMEX building are included in the Core Strategy
Submission document (policy Development Area 5). A planning brief for the Edward
Street Quarter was approved by the council in 2013. The next phase will be planning
application for development of the original building on Edward Street likely to be
considered from 2016.
3.6 Sackville Estate Potential to influence the AQAP and revoke part of the AQMA: HIGH Substantial mixed retail-residential development. In the years of operation the
development is predicted to add between 4% and 7% additional general traffic to
Sackville Road.
The Sackville Road-Old Shoreham Road intersection near Hove Park is recognised
for many years as a NO2 hotspot with concentrations above legal limits. Much of the
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surrounding area is compliant with air quality and with some improvement the
junction and adjoining A roads could be revoked from the AQMA.
3.7 Circus Street Market: Brighton Potential to influence the AQAP and revoke part of the AQMA: HIGH. In Central Brighton, redevelopment proposal is for a zero carbon mixed use
development including 180 residential units (40% affordable), student
accommodation a dance studio for South East Dance and university library for
University of Brighton. The development is currently at the planning stage.
3.8 Royal Sussex County Hospital Potential to influence the AQAP: MODERATE to HIGH.
Eastern Road, Brighton. Redevelopment of the Barry Building and other buildings on
southern half of site with 68,000 m3 of floor space for new medical facilities, including
new trauma and neurological facilities as well as new Cancer care unit and helicopter
landing pad.
Expansion of the Royal Sussex County Hospital is referred to in Core Strategy
Submission document (Development Area 5 ‘Eastern Road and Edward Street’) to
provide 30,000sqm additional hospital (D1 use) floor space. Planning permission was
approved by committee and it is anticipated that the final funding for the scheme will
be approved by central government later in 2014.
3.9 Open Market (London Road near New England Quarter)
Potential to influence the AQAP: MODERATE to HIGH.
Redevelopment of Open Market with continental style covered market, artist
workshops and residential units. Draft scheme: 87 residential units, 45 market units
and 12 artist workshops. Work on this scheme was nearing completion in June
2014.
3.10 New England House Potential to influence the AQAP: MODERATE to HIGH.
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New England House to be refurbished in order to establish a new business centre for
digital media and innovation; to include an enterprise hub with a consortium of
partners.
The refurbishment or redevelopment of site was included as a proposal in the
London Road Central Masterplan SPD10.
The council issued a brief for consultant support to develop a joint business case for
the refurbishment of New England House to provide a digital media innovation and
enterprise hub and to create additional workspace. Consultants have been
appointed and have initiated work. Funding for the refurbishment will be available
through the council’s City Deal.
3.11 King Alfred Sport Complex and Residential Potential to influence the AQMA: MODERATE. The city council has recognised for some time that this sports centre requires
modernisation13. The 1.7 hectare site on the sea front in Hove remains a major
development opportunity. The mixed retail and leisure development will require
detailed assessment of air quality to determine potential benefits or changes to the
traffic dynamic along the A259 transport corridor. At this stage the most likely
schedule for a major new build is 2018-20.
3.12 Anston House Development A23 Potential to influence the AQAP or revoke part of the AQMA: MODERATE. The proposed residential development is west of Preston Road (A23) to the north of
Central Brighton. There are no immediate air quality issues at the site which is set
back from the main road and the AQMA by several metres. During operation this
development is predicted to add up to 2.2% traffic to the A23. The council has
requested developer contributions to support air quality investigation in order to
better understand the potential air quality impact in and around the Preston Circus
junction which has been part of a broader AQMA for ten years). Further investigation
could establish a cost benefit analysis and support new measures in the future action
plan.
13 King Alfred Development http://www.brighton-hove.gov.uk/content/planning/major-developments/king-alfred-redevelopment
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3.13 Pelham College Potential to influence the AQMA: MODERATE. Demolition and re design of the tertiary college. The plan is to provide; educational
space, student accommodation and create new residential space. The site is in the
AQMA but has limited influence on local traffic.
3.14 Falmer Community Stadium and Hotel Potential to influence the AQAP AQMA: MODERATE.
The site is between A27 and Village Way, near to the Universities of Sussex and
Brighton. The £93 million new community football stadium with a capacity of 30,750
has been successfully completed through phased expansion. The Stadium has the
highest average attendances of any football stadium in England outside of the
Premier League. Most supporters arrive by train, bus, cycling or walking.
The Stadium is included in the Core Strategy Submission document (policy
Development Area 3) as a Strategic land Allocation in the Academic Corridor.
Adjacent to the stadium there are plans for a £55 million development to include 120
room hotel and accommodation for 850 students.
3.15 Meadow Vale housing Potential to influence the AQAP AQMA: MODERATE The development needs to be considered for its potential influence on the
Rottigndean AQMA especially in respect of additional traffic to the High Street and
any additional deliveries and bus services that may be required after construction.
3.16 Black Rock A259 Potential to influence the AQAP and revoke part of the AQMA: LOW to MODERATE. Black Rock is located on Brighton seafront at the east end off Madeira Drive next to
the Marina. The site is outside of the AQMA but has the potential to influence traffic
on the A259. A major leisure proposal is anticipated in due course.
3.17 Brighton Marina Inner Potential to influence the AQAP and revoke part of the AQMA: LOW.
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The Inner Marina includes a living and leisure scheme with approximately 1300
residential units; new retail, a bridge link from the cliff and a new square.
Brighton Marina is included in the Core Strategy Submission document (policy
Development Area 2). A master plan planning advice note for the Marina was
formally approved by Environment Committee in 2008.
3.18 Brighton Marina Outer Potential to influence the AQAP and revoke part of the AQMA: LOW. Brunswick Developments scheme: 853 flats (40% affordable), retail and community
uses, 2 new bridges and a 40-storey tower.
Brighton Marina is included in Core Strategy Submission document (policy DA2).
Planning permission was granted on 4th July 2006 to Brunswick Developments for a
mixed use development. All pre-commencement conditions have now been
discharged. An amended planning application is being submitted in 2014.
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4 Pollution Sources 4.1 Road Traffic Sources 4.1.1 Discussion of Monitoring Results relating to Road Sources
The problem of continued NO2 pollution in the Brighton AQMA is similar to other
small cities with historical centres as reported for York14, Oxford and Cambridge.
The majority of Brighton’s streets and buildings in the AQMA were built before the
popular use of motorised vehicles in the 1920s. Emission performance of the internal
combustion engine can be compromised in historical urban centres where there is
limited space and a combination of vehicle queuing, hill climbs, standing starts and
nippy accelerations. This interrupted drive sequence is unlike an idealised emission
test scenario that can assume vehicle coasting and much lower demands on fuel
consumption. We know that Selective Catalytic Reduction (SCR for mitigating NOX)
does not perform optimally <200ºC in stop-start, extra urban driving environments.
High mileage vehicles are at greater risk of abatement degradation15 and these
vehicles will spend the most hours on the road. There are economic arguments in
favour of diesel above 20,000 miles per annum, it is therefore logical that the highest
mileage users on the road for the greatest durations will be diesel cars, taxis, and
heavy vehicles.
4.1.2 Influence of Traffic Tally and other variables
On some road links there is evidence from continuous traffic counters in Brighton and
West Sussex that suggests traffic growth may have declined since a peak around
2007/08. Further work is required to determine how traffic numbers and flow might
have changed in areas of poor air quality. A growing hypothesis is that total traffic
tally and mass emission rates are not the most important variables that determine
pollutant concentrations in urban streets where people live. For example the narrow
Saint James Street in Brighton (B2118) carrying approximately 2,200 vehicles a day
records similar roadside NO2 levels to parts of the sea-front Kingsway (A259) which
can carry 38,000 vehicles a day (since mid-1990s). Key variables influential on
ambient pollutant concentrations at pavements and building facades parallel to the
carriageway are: wind penetration, street-width, road gradient, degree to which
14 Air Quality Problems in small cities. Air Quality Bulletin May 2012, Issue 73, Page 7 15 Abatement meaning emission mitigating technology such as particulate traps, filters and catalytic converters
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buildings enclose the traffic, vehicle age and type and the fuel burned. The micro-
environment in an enclosed street canyon is less favourable for emission dilution and
entrainment of fresher ventilation. In narrow streets, residential buildings are nearer
to exhaust sources. A significant proportion of the city’s residential areas are at
roadside.
4.1.3 Fuel Type
At the 2010 open meeting of Defra’s air quality expert group, evidence was
presented that NO and NO2 (NOx) emissions from diesel vehicles have not improved
since the late 1980s. Evidence from remote sensing of vehicle exhausts has shown
NOx emissions from diesel vehicles in urban environments have not improved in
twenty-five years16. The study suggested that NOx emissions from petrol vehicles
has improved during the same period, however the emissions performance of petrol
vehicles risks degradation with use and age. Although hybrid and electrical have
made some gains; there is no substantial market penetration to date. As stated in
the introduction it is estimated there could be quarter of a million vehicles in the
conurbation; a small percentage will be active every day. A few hundred local cars
and motorbikes are now utilising the provided electrical charging points. Exponential
growth in the use of electric and hybrid vehicles is anticipated as costs come down.
The first rapid charging points are scheduled to be connected in 2014. Diesel engines have greater tail-pipe emissions of NO and NO2 compared with
alternatives such as modern petrol and gas (methane and propane). We observe
that key road corridors in the Brighton AQMA are frequented by vehicles that are
fuelled by between 65% and 99% diesel engines. Practically all lorries, vans and
taxis use diesel and the local bus fleet currently runs on about 92% diesel after the
introduction of 13 hybrids and diesel fuel is mixed with 5% vegetable oil. The
Department of Energy and Climate Change (DECC) has published road fuel
consumption quantities for each local authority17. Figure 4-1 presents the fuel shift
from petrol to diesel and Figure 4-2 the decline in fuel consumption likely due to a
combination of traffic measures, more efficient engines and slightly less road
movement since the recession. These trends are important to understanding the
16 Trends in NOx and NO2 emissions and ambient measurements in the UK, March 2011 http://uk-air.defra.gov.uk/reports/cat05/1103041401_110303_Draft_NOx_NO2_trends_report.pdf 17 Regional and Local Authority Road Transport Consumption Statistics https://www.gov.uk/government/statistical-data-sets/road-transport-energy-consumption-at-regional-and-local-authority-level
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stubborn levels of NO2 in the AQMA and suggest that indiscriminate traffic reduction
is unlikely to further improve local air quality.
Figure 4-1 Brighton and Hove –Fuel Consumption Trends 2005 to 2012
Figure 4-2 Brighton and Hove - Fuel Consumption by Travel Type 2005 to 2012
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Figure 4-1 shows trends in fuel consumption in Brighton and Hove for eight years up
to 2012. Bus consumption of diesel in Brighton & Hove appeared to peak in 2007 at
4,700 tonnes per year and has fallen to 3,600 tonnes; a 23% reduction in five years.
This compares very favourably with the increase in bus patronage during the same
period. The introduction of automatic engine cut out when stationary and hybrid
vehicles allows delivery of fuel savings without compromising services. Drivers also
aim for the maximum fuel efficiency.
The cities Heavy Goods Vehicle (HGV) consumption of diesel peaked in 2008 at
9,000 tonnes and declined to 7,700 in 2012. Light diesel goods vehicles now have a
larger share of the freight market. Evidence points to a substantial decline in petrol
consumption by cars down 33% (2005-2012). There is no doubt that a modal shift
from petrol to diesel cars has occurred locally and nationally; during the same period
diesel consumption by cars in Brighton & Hove increased by 24%. Likewise, light
goods vehicles (vans) in Brighton consumed less petrol and more diesel fuel. Sales
of diesel cars outstripped petrol for the first time in 2011. Light vehicle (car and van)
diesel consumption for is set to overtake petrol in 2013/14.
Overall the data indicates a decrease in personal fuel demand whilst fuel
consumption by road freight has remained fairly constant. Where an authority
reports or predicts declines in the total tally of general traffic it should not be
assumed that air quality will improve. If diesel combustion and emissions of NOx
increase (regardless of total vehicle tally) this has the potential to be adverse for local
air quality. Since the Updating Screening Assessment (2012) there are no newly identified:
• Narrow congested streets
• Busy streets where people may spend one hour or more
• Roads with a high flow of buses and/or HGVs
• Junctions
• New roads constructed or proposed since the last Updating and Screening
Assessment
• Roads with significantly changed traffic flows
• Bus or coach stations
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4.2 Other Transport Sources Since the Updating Screening Assessment (2012) there are no newly identified:
• Airports
• Locations where diesel or steam trains are regularly stationary for periods
of 15 minutes or more, with potential for relevant exposure within 15m
• Locations with a large number of movements of diesel locomotives, and
potential long-term relevant exposure within 30m
• Ports for shipping
4.3 Industrial Sources Since the Updating Screening Assessment (2012) there are no newly identified:
• Industrial installations: new or proposed installations for which an air
quality assessment has been carried out
• Industrial installations: existing installations where emissions have
increased substantially or new relevant exposure has been introduced
• Industrial installations: new or significantly changed installations with no
previous air quality assessment
• Major fuel storage depots storing petrol
• Petrol stations
• Poultry farms
A new combustion process to run on recovered oils is proposed approximately 800 m
to the west of the council’s administrative area. The access road runs through the
BHCC area, but the developer proposes that the majority of deliveries will arrive by
sea. Brighton and Hove and Adur District Councils have considered the proposed 50
MW (thermal) power station. A Detailed Assessment for planning requirements has
been submitted. Detailed comments including monitoring and receptor locations
were sent to the developer’s consultant assessing air quality. The Environment
Agency are scheduled to determine the permit proposal as a part A process under
the Environmental Permitting Regulations (formerly IPPC integrated pollution
prevention control). As part of the LAQM process the council will also consider the
process in combination with existing emission sources.
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4.4 Commercial and Domestic Sources Since the Updating Screening Assessment (2012) there are no newly identified:
• Biomass combustion plant – individual installations
• Areas where the combined impact of several biomass combustion sources
may be relevant
• Areas where domestic solid fuel burning may be relevant
4.5 New Developments with Fugitive or Uncontrolled Sources
Since the Updating Screening Assessment (2012) there are no newly identified:
• Landfill sites
• Quarries
• Unmade haulage roads on industrial sites
• Waste transfer stations, etc.
• Other potential sources of fugitive particulate emissions
Brighton and Hove City Council confirms that there are no new or newly identified
local developments which may have an impact on air quality within the Local
Authority area.
Brighton and Hove confirms that all the following have been considered:
• Road traffic sources • Other transport sources • Industrial sources • Commercial and domestic sources • New developments with fugitive or uncontrolled sources.
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5 Local / Regional Air Quality Strategy The city council’s Air Quality Action Plan (AQAP)18 was initially written back in 2006
and underwent extensive updates and consultation in 2010/2011. Following
amendment to the AQMA in 2013 a new AQAP is required for 2015. This will be
linked to the Local Transport Plan (LTP4) and low emission initiatives developed by
the Sussex Air Quality Partnership SAQP. Detailed action plan measures for
Brighton’s transport corridors, streets and junctions will be justified by evidence from;
traffic data, emission rates, dispersion modelling and vehicle category source
apportionment.
18 2011 Air Quality Action Plan http://www.brighton-hove.gov.uk/sites/brighton-hove.gov.uk/files/downloads/airquality/BHCC_AQAP_2011_%5Bpdf_1.9_mb%5D.pdf
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6 Air Quality Planning Policies Planning comments by Environmental Health relating to air quality refer to the
following planning policies:
• City Policy SU9 relating to the avoidance of introducing new residential spaces
to areas of known poor air quality
• Development Area Policies for the set areas in Figure 3-2 that relate to the
core strategy and Local Development Framework (LDF)
• Sussex Air Quality and Emission Mitigation Guidance19
• Environmental Protection UK Development Control: Planning for Air Quality
• London Councils Air Quality Planning Guidance20
• Institute of Air Quality Management (IAQM 2012) Guidance on the
Assessment of the Impacts of Construction on Air Quality and the
Determination of Significance21
• Construction Environment Management Plans CEMP
19 Sussex Air Quality and Emission Mitigation Guidance http://www.sussex-air.net/Default.aspx 20 London Councils Air Quality Planning Guidance http://www.londoncouncils.gov.uk/policylobbying/environment/air/airqualityplanningguidance.htm 21 IAQM 2012 Guidance on the Assessment of the Impacts of Construction on Air Quality and the Determination of
Significance21 http://iaqm.co.uk/guidance/
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7 Local Transport Plans and Strategies The first LAQM reports fifteen years ago recognised that road transport was the main
source of local pollution, most especially for NO2. The Local Transport Plan LTP3
(2011) written by the unitary authority can be found on the council’s web pages22.
LTP4 will follow with updates. This fits with the coast to capital Local Enterprise
Partnership (LEP). LTP3 onwards seeks to integrate transport policy with other
areas of work by involving people more in developing ideas and decision making.
Joint areas of interest that address transport-related air quality issues include:
• Information on transport and the decisions people make when they travel
• Real time information on public transport, ticketing and congestion
• Educational initiatives such as; travel to school, personal travel plans, anti-
engine idling signs to promote emission reduction,
• Sessions in schools and universities developing topics around: transport
choice, emission and dispersion science, chemistry, geography and human
health relating to active travel and air quality
• Aim for smooth traffic and reduced queue durations
• Measures to help introduce cleaner vehicles
• Maintaining road services
• Smoother road services with the aim of reducing fuel consumption
• Improving pavements, concourses and cycle lanes
• Phasing of traffic light sequences to reduce traffic queuing duration and
frequency especially where queuing duration causes poor air quality
• Innovation and the use of technology
• Encouraging active sustainable forms of travel especially cycling & walking
• Bus Quality Partnership Agreements and applications to the green bus fund
• Improvements to the urban realm environment achieved through pedestrian
areas, tree and shrub planting transport schemes and projects
• Better tires campaign for improved safety, lower fuel demand and reduced
emissions
22 LTP3 http://www.brighton-hove.gov.uk/content/parking-and-travel/travel-transport-and-road-safety/local-transport-plan
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8 Climate Change Strategies The sustainable community strategy aims to reduce the city’s greenhouse gas
emission by 42% by 2020 and 80% by 2050. The city’s Climate Change Strategy
can be found on the council’s webpages23. It includes focus on:
• Reducing the city’s greenhouse gas or carbon equivalent emissions
• Adapting to the challenges and opportunities of a changing climate
Further information can be found in Defra’s short publication Air Pollution in a
Changing Climate24.
8.1 Common agreement between climate change and air quality includes:
• Avoid energy waste in transport and buildings
• Reduce the need to travel and switch to modes with the lowest fuel demand
• Reduce dependence on fossil fuel hydrocarbons for; heat, electricity and
transport, increase renewable energy share; given the requirement to
regionally import energy, energy security, peak oil and associated price rises
• Growth in the environmental industries sector and a low carbon economy
• Black carbon particulate emissions likely detrimental to air quality, health and
climate by changing the reflectivity of ice and altering the atmospheric balance
of heat absorption and scatter
• NOx emissions go on to react with other chemicals in the atmosphere to form
particulate nitrate and photochemical smog. N2O is a potent greenhouse gas.
This mixture can influence air quality, health and climate
• Pollution episodes are more likely to happen in a changing atmosphere where
excess NOx in the presence of sunlight and free radicals form seasonal ozone
23 BHCC Climate Change Strategy http://present.brighton-hove.gov.uk/Published/C00000120/M00003226/AI00022734/$20111031151124_001100_0002279_MicrosoftWordBrightonHoveCityClimateChangeStrategyNOVEMBER2011.pdfA.ps.pdf 24 Air Pollution in a Changing Climate https://www.gov.uk/government/publications/air-pollution-action-in-a-changing-climate
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8.2 Potential difference of interest between greenhouse gas reduction and air quality:
• Compared to the alternatives diesel vehicles usually have better Miles per
Gallon (MPG), lower CO2 but higher emission of NOx, PM1 & PAH. It is not
advisable to emit these pollutants to AQMA streets in cities and villages
• UK tax regime encourages efficient low carbon vehicles which has effectively
promoted diesel for cars, taxis and vans (previously used for HGV and bus)
• Diesel Particulate Filters (DPF) trap soot and particulate, but this needs to
flushed out which periodically discharges particulate, NO2 and CO2
• Continuous Regenerating Traps create NO2 in order to mitigate particles in a
platinum catalyst. This increases emission of NO2 and even the best
performing traps may not stop emission of the finest diesel nano -particualte
• Some diesel abatement technologies such as SCR may mitigate the majority
of NOx but increase CO2
• Carbon neutral wood burning has higher emissions of particulate and NOx;
commercially this is not advisable in the AQMA with its dense population
• Buildings and structures of various heights in the urban realm can hinder
effective dispersion of emissions from a low height tailpipe or chimney. This is
critical for the resulting impact on localised air quality at street level, but is of
no relevance to the emission of greenhouse gases generally to the
atmosphere, which are an issue from any place
• Priority for the air quality action is to avoid and reduce low height emissions to
confined spaces amongst densely populated areas. This priority is not of
direct consequence for climate change emissions strategies which deal in
mass emission rates and sinks regardless of their location; a distinction should
be realised between global (atmosphere and climate) and localised (health)
requirements
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9 Implementation of Action Plans 9.1 Schedule for AQAP Revision Following revocation of much of the 2008-AQMA (1050 hectares) on 30th August
2013 the city council now focuses bids and investigation on two smaller AQMAs
(combined area 243 hectares) with a population to the order of 10,000. The revised
AQMA follows closely the known area of nitrogen dioxide exceedance. BHCC has
statutory duty to deliver a revised air quality action plan 18 months after the last
AMQA declaration i.e. by the end of February 2015. The action plan will be
supported by a detailed update of dispersion modelling and source apportionment for
key streets within the AQMA.
9.2 Area of Exceedance In 2014/15 BHCC estimates that 20 to 30km of road length continue to exceed the
NO2 annual average limit along the building-line façade running parallel with AQMA
road carriageways. Initial GIS (Geographical Information System) analysis suggests
approximately 2,250 residential dwellings in BHCC are at risk of exposure to levels
above the AQS objective or legal limit. In addition retail and pedestrian areas in the
AQMA exceed hourly and annual limit values for NO2. Likely concentrations vary
between 40 and 115 µg/m3 as a five year mean. Defra’s assessment to the
commission (EC) needs to take account of local evidence and experience when
estimating future NO2 progress within the Brighton-Worthing-Littlehampton
agglomeration. To this end the AURN affiliated monitor BH1 (ceased in 2010)
requires replacement so that regional assessment can be suitably verified with a
roadside monitor. It is recommended that NOx analysers at BH10 or BH6 are
affiliated to AURN and used for all model verification for the zone.
9.3 New Action Plan Measures The summary in Table 9-1 outlines a flavour of air quality action plan measures
driven forward by the Sussex Air group, Brighton and Hove Buses and the
Environmental Protection team at BHCC since 2013. A much more comprehensive
set of measures is included in the 2011 air quality action plan which will be re-written
in 2014/15. Air quality recommendations have been forwarded to city planning
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policies, especially those for designated development areas outlined in Figure 3-2.
The local transport plan LTP4 is pending and will include updates on local travel
plans and inclusive measures to encourage and grow sustainable travel choices.
9.3.1 Local Sustainable Transport Fund (LSTF) and Air Quality
We have urged DfT to highlight where LSTF corridors are concurrent with AQMAs.
To date DfT guidance on LSTF applications has prioritised carbon savings and
economic improvement. Greater emphasis should be placed on air quality
assessment and improvement as priority for LSTF where road transport is the reason
for nitrogen dioxide exceedance and an established AQMA is part of the LSTF area.
9.3.2 Cleaner Vehicle Projects
Recent progress includes success with the 2013 Clean Bus Transport Fund (CBTF
£750,000) and applications to the 2014 Clean Vehicle Transport Fund (CVTF) for
buses and taxis outlined below. This compliments the city’s bus low emission zone
scheduled for implementation from 2015. All frequent bus services will be at least
euro-five (original manufacture equipment or retrofitted). The next round of Brighton
& Hove bus procurement (20 to 25 vehicles) will be Euro-6. There are 13, euro-5
diesel electric hybrid vehicles already in operation. Brighton and Hove Bus Company
is seeking to reduce engine idling time to less than one minute. Supported by the
Office of Low Emission Vehicles (OLEV) Sussex Air and BHCC are working on an
electromotive project to deliver rapid chargers (25 minutes) to the region including
sites within the city. Dialogue with supermarkets is exploring infrastructure for
methane as a transport fuel. There has been recent participation at meetings in
London with Competence Centre Civil Economics, Energy & Infrastructure regarding
alternative power trains in public transport considering hydrogen cell electric
technology as trialled in a number of cities including London and Aberdeen. EC
funding to the order of €900 million could be available to incentivise for “bus cities”
from 2017. Information has been passed on to Brighton & Hove buses. Brighton and
Hove buses in conjunction with Ricardo have carried out a PEMS monitoring project.
9.3.3 Taxi Licence Policy
Taxi activity is associated with Central Brighton’s 24-hour entertainment economy.
Licenced cabs have an important role to play in assisted transport for people in care
and those with disabilities. In the last twelve months Environmental Health and
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Licencing have made proactive progress with taxi licence policy. All taxi ranks in the
city now have: “when not moving, cut engine cut pollution signs” and similar bumper
stickers have been issued for cabs and minibuses. Recommendations have been
made to major planning applications regarding the location of taxi ranks; to be away
from residential, but to encourage new ranks in commercially active zones. The taxi
licence forum is exploring low emission strategies instead of age limits and changes
to taxi licencing to allow a niche market for smaller lighter vehicles licenced for one or
two passengers. It is now possible for taxis to achieve wheelchair access with fairly
compact cars as well as larger minibus taxi licenced for eight passengers. The latter
are being considered for a flywheel and SCR retrofit project.
9.3.4 Annual Health Report
Each year Environmental Protection submits an update on noise and air quality to the
public health Joint Strategic Needs Assessment. In addition contribution on air
quality is made to the annual health report which has a different theme each year.
This time the innovative approach was to write it as if the year 202425.
9.3.5 Local Community Engagement
In the last year suggestions relating to air quality improvement have been fed into the
St James Street LAT (Local Action Team) and Rottingdean Parish Council’s vision
and strategic objectives for their neighbourhood plan.
9.3.6 Combustion Plant Planning Policy
The new air quality action plan recommends that in or adjacent to the AQMA
planning policy follow the following hierarchy:
1. Consider renewable alternatives instead of fixed plant combustion
2. If no alternative is possible seek ultra-low NOx gas boilers
3. Vertical flue termination at least 1.5 m above the tallest premises roof apex
Air quality action plan policy is likely to recommend refusal for planning applications
seeking low height commercial (>32kw peak) solid fuel burning in the AQMA. Web
based and pamphlet information has been provided on urban solid fuel policy relating
25 Annual Report of the Director of Public Health http://www.brighton-hove.gov.uk/sites/brighton-hove.gov.uk/files/2013%20DPH%20Annual%20Report_WEB_version_0.pdf
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to the air quality action plan, the clean air act, smoke control areas, climate change
and statutory nuisance.
9.3.7 Construction Environment Management Plans (CEMP)
Influence on the routing of construction vehicles with the aim of reducing distance
travelled through the AQMA. Agree emission standards for working HGV on major
construction sites in the AQMA. Seek opportunities for cost spread and low emission
vehicle sharing between city centre construction sites (2015-2021) for example;
Circus Street, Royal County Hospital, American Express European Headquarters,
City College Pelham Street, Preston Barracks on Lewes Road.
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Table 9-1 Action Plan Progress Lead Authority BHCC (unless stated)
No. Measure Focus Lead Authority
Planning Phase
Implementation Phase Indicator
Target Annual
Emission Reduction
in the AQMA
Recent Progress
Estimated Completion
Date
CommeRelatingEmissi
Reducti
1
Low Emission Zone for Buses
Reduce bus NOX
emissions in the AQMA-LEZ using
Bus Quality Partnership Agreements
(BQPA) Traffic
Regulation Order (TRO)
Brighton & Hove City Council
2013/14
Bus LEZ comes into effect
01.01.2015 Euro-V with
exemption for infrequent services
All frequent services in bus LEZ at least euro-5 standard by 2015 Prior agreement with bus
operators. CCTV in
place
Seeking >2g/km NOx for buses
Primary NO2 not
more than 50%
Traffic Regulation
Order (TRO) for Brighton
bus LEZ unanimously approved by committee
Jan-14
Bus LEZ in force 2015 to continue there after
PortabEmissioMonitor
System(PEMS
exploriemissio
differencbetwee
makes amode
2
SCRT Retrofit
Programme for Buses
Clean Bus Transport
Fund (CBTF)
2013
Q3 2014 to be delivered in time
for bus LEZ 01.01.2015
PEMS Portable on
Board Monitoring
System
Seek 80% NOx
emission reduction
on fifty frequently used Euro III buses
Won £750,000
from 2013-CBTF for
Brighton & Hove buses
matched funded
Retrofits on schedule for the end of
2014
RetrofitEuro I
aiming better th
Euro-Vresult
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No. Measure Focus Lead Authority
Planning Phase
Implementation Phase Indicator
Target Annual
Emission Reduction
in the AQMA
Recent Progress
Estimated Completion
Date
CommeRelatingEmissi
Reducti
3
Flywheel Retrofit
Programme for euro IV
Buses
Clean Vehicle
Transport Fund (CVTF)
and bus company matched funding
2014 Lead
Authority East Sussex CC
2014/15 if CVTF is successful
Euro IV buses fitted with flywheel
Retrofits to pass
through several AQMAs including BHCC
Submission of bid to
CVTF Sep-2014
2015
20%reductio
NOxsubstanreductio
fuel consumpand carb
4 Procurement Strategy for new buses
Green Bus Fund & and bus company matched funding
Ongoing From 2012 Number of hybrid and
euro 6 buses
Test NOx reduction
with PEMS or roadside monitoring
13 hybrid buses
operating in Brighton &
Hove
First twenty+ Euro 6
buses to be purchased
2014
NoneretrofittEuro I
retired frthe fleetend 20
5 Retrofit
proposal for taxis
Clean Vehicle
Transport Fund (CVTF)
and taxi company matched funding
2014 2015 if CVTF is successful
Number of retrofitted
minibus taxis
Flywheel and SCRT to save fuel
Submission of two taxi
related bids to CVTF
Sep-2014
Late-2015
Aim for Ndown b80% Fu
consumpdown b
20%
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No. Measure Focus Lead Authority
Planning Phase
Implementation Phase Indicator
Target Annual
Emission Reduction
in the AQMA
Recent Progress
Estimated Completion
Date
CommeRelatingEmissi
Reducti
6 Taxi
Licencing Policy
Change licence policy to encourage
lighter low emission vehicles
2013/14 Proposed
Encourage niche market in light low
emission taxis licenced for one or two passengers
Aim for emissions
of NOx <50mg/km i.e. better
than euro 6
Discussions with Taxi Licence Forum
2015/16
To besupporteInfrastrucfor gas a
electri
7 Signs not Fines
Anti-Idling signs on all taxi ranks in around the
AQMA
2013/14 Implemented 2014
Action to reduce idling
time for buses and taxis to one minute
Emission and
annoyance
Agreed & funded by
taxi licencing forum
2014
Avoid fuconsump
and emissiowhen nmovin
8
Assess junction light phasing to
reduce AQMA
queuing
Assessment of key AQMA junctions to
see if queuing time
can be reduced
Ongoing Dialogue 2014/2015 Better flow
Reduce breaking and idling
Assessment of Clock Tower
Junction
Ongoing
Prioritise NOx reductionconfined spaces bresidentia
9
Rapid vehicle
charging network
OLEV funded
project with electromotive
2013 Lead Sussex Air 2014
Use of rapid chargers
across the South East
Zero tailpipe
emission of NOx
Identified sites
including Brighton
2015
Strongrowth
e-car shof mark
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No. Measure Focus Lead Authority
Planning Phase
Implementation Phase Indicator
Target Annual
Emission Reduction
in the AQMA
Recent Progress
Estimated Completion
Date
CommeRelatingEmissi
Reducti
10
Alternative fuel
Infrastructure for vehicles
in the AQMA
Seek opportunities for gas & fuel
cell infrastructure
2014/2015 2015/16 Use of bio-
methane as a transport fuel
Aim for emissions
of NOx <50mg/km
Dialogue with supermarkets
Hydrogen fuel cell EC bus project
2015/17
Benefitsair qua
and climchang
11
Valley Gardens
Major Transport Scheme
Urban realm improvement
and LSTF
2012/14 2016/17 Improvements in ambient air
quality
Better flow wider
concourses, planting & amenity green space
Air Quality impact
assessment of the
scheme
2018
Less stostart traff
reducemissio
extra spto hel
dispers
12
Restriction of Vehicle
numbers on certain AQMA
transport corridors
Assess heavy vehicle
capacity of street before NO2 limit is likely to be exceeded
To be balanced with
emission reduction
achieved by other
measures after 2014
Future Substantial reduction in emissions
Emission reductions of >50% NOx sort
From 2015 Long Term
Considapplicatof LondAQ acti
plansOxford
and PutHigh Str
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No. Measure Focus Lead Authority
Planning Phase
Implementation Phase Indicator
Target Annual
Emission Reduction
in the AQMA
Recent Progress
Estimated Completion
Date
CommeRelatingEmissi
Reducti
13
Refusal on new
commercial solid fuel
burning in or adjacent to the AQMA
Avoid solid and liquid
fuel burn in the
designated area
Actively recommended
through the planning process
Policy of the 2014 AQ action
plan
Actively seek alternative renewable
solutions and avoid
combustion plant in the
AQMA
Solid fuel burning prone to emission peaks on start up
Ongoing Permanent
Approprlocation
carbosaving
strateg
14
Any combustion
development to use ultra-
low NOx boilers in
and adjacent to the AQMA
Go beyond requirements for code for sustainable
homes, BREEAM
ratings & RHI
Actively recommended
via the planning
process. If combustion
go for ultralow NOx gas boilers
Policy of the 2014 AQ action
plan
Seek other renewable solutions before
certification of ultralow NOx gas boilers
>20 mg/MJ NOx for new gas boilers in
and adjacent to the AQMA
Ongoing Permanent
By ordemagnitureducti
comparealternati
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No. Measure Focus Lead Authority
Planning Phase
Implementation Phase Indicator
Target Annual
Emission Reduction
in the AQMA
Recent Progress
Estimated Completion
Date
CommeRelatingEmissi
Reducti
15
Where new combustion
plant is proposed
new development in the AQMA
to have vertical flue terminations above roof
apex
Avoid horizontal
flue termination to the street in the AQMA
Actively recommended
through the planning process
Policy of the 2014 AQ action
plan
Conditions on planning
applications
Measure is not about emissions Effective
dispersion and
exposure avoidance
Ongoing
Permanent policy and
best practise
Measurelates
flue heiglocationdispers
and noemissio
rate
16
Avoid introduction
of new planned
residential adjacent to
NOx and PM at roadside
Planning Comments relating to
new residential land use
Actively recommended
through the planning process
Policy of the 2014 AQ action
plan
Conditions on planning
applications
Measure is not about emissions. Effective exposure avoidance
Ongoing
Permanent policy and
best practise
Ventilatstrategyavoid do
and exposu
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10 Conclusions and Proposed Actions
10.1 Conclusions from New Monitoring Data The AQMA has recently been amended and now represents a reasonable outline of
where NO2 risks exceeding the annual mean legal limit value. All monitoring
exceedances are within the two AQMAs declared in 2013. There is no need to carry
out another Detailed Assessment for Air quality. That said an update of detailed
source apportionment work will support a re-write of the air quality action plan that is
due for 2015.
10.2 Conclusions relating to New Local Developments Developers are currently considering air quality impact assessment on developments
at Circus Street and Meadow Vale, Ovingdean.
10.3 Proposed Actions Update of traffic counts, emissions maps, dispersion modelling and source
apportionment. Revise and update the air quality action plan, due 2015.
Bids to CVTF, LAQM, OLEV, S106, EC in support of the revised AQAP where
appropriate.
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11 References 1 EU low emission zones public authorities UK Brighton http://lowemissionzones.eu/public-authorities 2 For Defra reports to the EC the UK is divided into 43 rural and urban regions. Brighton and Hove City council is partly within the South East Region and is also part of the Brighton-Worthing-Littlehampton agglomeration recognised a distinct urban conurbation on the South Coast 3 2011 Census Results http://www.brightonbusiness.co.uk/htm/ni20120717.660827.htm 4 Air Quality in Europe 2012 Report http://www.eea.europa.eu/publications/air-quality-in-europe-2012/view 5 European Air Quality Standards http://ec.europa.eu/environment/air/quality/standards.htm 6 UK PAH monitoring and analysis network annual report 2012, published January 2014 http://uk-air.defra.gov.uk/library/reports?report_id=782 7 Sussex Air Alert Pollution Information Service http://www.airalert.info/ 8 National Planning Policy Framework https://www.gov.uk/government/publications/national-planning-policy-framework--2 9 Community Infrastructure Levy https://www.gov.uk/government/policies/giving-communities-more-power-in-planning-local-development/supporting-pages/community-infrastructure-levy 10 I-360 Observation Tower http://www.brightoni360.co.uk/index.html 11 Rampion Offshore Wind Farm updated http://infrastructure.planningportal.gov.uk/projects/south-east/rampion-offshore-wind-farm/ 12 Harbour Regeneration Plan http://www.adur-worthing.gov.uk/media/media,121462,en.pdf 13 King Alfred Development http://www.brighton-hove.gov.uk/content/planning/major-developments/king-alfred-redevelopment 14 Air Quality Problems in small cities: Air Quality Bulletin 07/2012, Issue 73, Page 7 15 Abatement meaning emission mitigating technology such as particulate traps, filters and catalytic converters 16 Trends in NOx and NO2 emissions and ambient measurements in the UK, March 2011 http://uk-air.defra.gov.uk/assets/documents/reports/cat05/1103041401_110303_Draft_NOx_NO2_trends_report.pdf 17 Regional and Local Authority Road Transport Consumption Statistics https://www.gov.uk/government/statistical-data-sets/road-transport-energy-consumption-at-regional-and-local-authority-level 18 2011 Air Quality Action Plan http://www.brighton-hove.gov.uk/sites/brighton-hove.gov.uk/files/downloads/airquality/BHCC_AQAP_2011_%5Bpdf_1.9_mb%5D.pdf 19 Sussex Air Quality and Emission Mitigation Guidance http://www.sussex-air.net/Default.aspx 20 London Councils Air Quality Planning Guidance http://www.londoncouncils.gov.uk/policylobbying/environment/air/airqualityplanningguidance.htm 21 IAQM 2012 Guidance on the Assessment of the Impacts of Construction on Air Quality and the Determination of Significance1
http://iaqm.co.uk/guidance/ 22 LTP3 http://www.brighton-hove.gov.uk/content/parking-and-travel/travel-transport-and-road-safety/local-transport-plan 23 BHCC Climate Change Strategy http://present.brighton-hove.gov.uk/Published/C00000120/M00003226/AI00022734/$20111031151124_001100_0002279_MicrosoftWordBrightonHoveCityClimateChangeStrategyNOVEMBER2011.pdfA.ps.pdf 24 Air Pollution in a Changing Climate https://www.gov.uk/government/publications/air-pollution-action-in-a-changing-climate 25 Annual Report of the Director of Public Health http://www.brighton-hove.gov.uk/sites/brighton-hove.gov.uk/files/2013%20DPH%20Annual%20Report_WEB_version_0.pdf
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12 Appendix: QA: QC Data (Monitoring Data Quality Assurance Quality Control)
12.1 Diffusion Tube Bias Adjustment Factors The 2013 diffusion tubes are supplied and analysed by Gradko international
laboratories using the 20% TEA in water method corrected to 20°C (293K). Typical
diffusion tube exposure times are around 700 hours but can vary; time weighted
averages have been used to derive annual averages. The limit of detection is
0.017 µg/NO2. Reported results are either rounded up to whole numbers or
expressed to a precision of one decimal place.
Figure 12-1 Co-Location Questionnaire for BH6
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12.2 Discussion of Choice of Factor to Use
The Bias correction used is an orthogonal mean of local sites BH6 & BH10 that are
most representative of the diffusion tubes in the AQMA. The more polluted sites for
NOX show a closer agreement between continuous analysers and diffusion tubes.
Site BH9 on the fringe of the AQMA has much lower concentrations and will cease
after 2013 so this co-located factor was not included to derive a lower bias correction.
For sites along the North Street transport corridor within a few hundred metres of
BH10, this bias correction factor was used as a standalone without refereeing to a
composite average with other sites.
Figure 12-2 Co-Location Questionnaire for BH10
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Individual bias factors are as follows: BH10 North Street 0.98 BH9 Beaconsfield Road 0.73 BH10 Lewes Road 0.84 Orthogonal mean BH6 & BH10 0.9 PM Monitoring Adjustment
VCRM correction method is used for the TEOM that monitors for PM10 at site BH10,
North Street. Raw data from the BAM at site BH6 (started in February 2014) is
divided by 1.211 in line with Defra’s guidance.
Short-term to Long-term Data adjustment
Partial year for NOx at BH6: 21/06/12 to 31/12/12. Ratio derived from data capture
at BH9. Results reported for 2014 are the first six months of the year with monitoring
ongoing.
Figure 12-3 Short-Term to Long-Term Monitoring Data Adjustment
Site Site Type Annualised Mean (µg/m3)
Period Mean (µg/m3) Ratio
BH6 2012 Kerbside 50 46.8 1.068
QA/QC of Automatic Monitoring TRL carry out fortnightly calibrations and filter changes on all continuous analysers.
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QA/QC of Diffusion Tube Monitoring
Figure 12-4 WASP Proficiency Scheme for Nitrogen Dioxide diffusion analysis 2013
Recommended