Low Emission Planning – Progress & Practice

Maidstone, 21st February 2017

Rob Pilling

Programme Manager, The Low Emission Partnership

www.lowemissionhub.org

www.lowemissionstrategies.org

1. Traditional Air Quality Management

Primary emphasis to assessing concentrations

2. Traditional Air Quality Management

with greater emphasis on mitigation

3. Traditional Air Quality Management

with greater emphasis on mitigation

underpinned by single point damage calc

4. Integrated Air Quality/Emissions Management

including assessment of mitigation benefits

EPUK

Bradford

W. Yorks

Sussex

Lancaster

Evolution of Air Quality Planning Approaches

K&M

?

Traditional

Traditional

+ Mitigation

Low

Emission

York

Low Emission Planning – Progress & Practice

(1) Low Emission Planning in Practice

(2) Regional Working

(3) Local Policies

(4) The Low

Emission

Partnership

(1) Low Emission Planning in Practice

Thanks to Liz Bates at York for for the blue backed slides in this section

Policy development - York

• Low Emission ‘Regional Champion’ 2009

• Published first overarching Low Emission Strategy in 2012

• Development of Low Emission Planning Guidance included in the LES measures

• LES measures transposed into an Air Quality Action Plan in 2015, included LES planning guidance as an Annex.

NPPF (para 124) “Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan”

Wider York planning policy• York Local Plan still in development stage

� draft 'Local Plan‘ (April 2005) currently used as basis for planning

decisions

• GP4b- Air Quality Policy

In considering the impact on local air quality the following will be

considered:

� Existing air quality in the vicinity of the proposed development

� Likely impact on local air quality as a result of the proposed

development

� Proposed measures for mitigating the air quality impact of the

development and the compatibility of these measures with the Air

Quality Action Plan (AQAP)

Supported by local air quality guidance for developers which is

regularly updated

Construction Environmental

Management Plans (CEMPs)

Generic CEMP conditions

Prior to any works commencing on site, a construction

environmental management plan (CEMP)shall be submitted to

the local planning authority and approved in writing. The

CEMP shall identify the steps and procedures that will be

implemented to minimise the creation and impact of noise,

vibration, lighting and dust resulting from the site

preparation, demolition, groundwork andconstruction phases

of the development.

REASON: To protect the amenity of local residents and

businesses and protected species.

Air quality specific CEMP condition

Prior to commencement of the development a Construction

Emission Management Plan (CEMP) for minimising the emission

of dust and other emissions to air during the site preparation and

construction phases of the development shall be submitted to

and approved in writing by the Local Planning Authority. The

CEMP must be prepared with due regard to the guidance set out

in the London Best Practice Guidance on the Control of Dust and

Emissions from Construction and Demolition and should include

a site specific dust risk assessment. All works on site shall be

undertaken in accordance with the approved CEMP unless

otherwise agreed in writing by the Local Planning Authority.

• Purpose: To protect amenity and health of surrounding

residents in line with the Council’s Low Emission Strategy and

the National Planning Policy Framework (NPPF)

•

Mitigation checklist

Assessing CEMPs

• Vary considerably in quality - often tend to be a

generic approach rather than risk assessed for the

specific site in question

• Often miss the road transport aspects, particularly

anti-idling and workplace travel planning

• Aim for more consistency by providing pre-planning

advice whenever possible, signpost the CEMP

checklist approach (informative to the condition)

• Don’t underestimate the resource time needed to

review and discharge CEMP conditions

• Reject sub-standard submissions

EV charging

infrastructure

• Bradford – around 4000 EV charging

points conditioned on domestic and

commercial premises since 2013.

• York – around 1000 EV charging points

on medium and large developments

and unquantifed number on small

scale housing schemes

EV charging options

End user Charger type Charging time Approximate cost

Domestic and

Workplace

Slow 7-8 hours £

Fast (wall mounted) 3-4 hours ££

Fast (stand alone) 3-4 hours £££

Public access Fast (wall mounted) 3-4 hours ££

Fast (stand alone) 3-4 hours £££

Rapid 80% charge in 30

minutes

££££

Additional mitigation measures

• Some larger schemes will need emission damage cost calculations

• Residual emissions need to be mitigated against

• WY approach - require financial investment in mitigation measures to a cost which is proportional to the residual damage cost

• LEP approach - involves a more detailed quantification of the mitigation measures and actual level of emission reduction likely to arise

York Community Stadium

• 14/02933/FULM

• Condition 8 - CEMP

• Condition 17 – 8 EV bays with free standing fast

charge units

• Condition 34 – Submission of damage cost

calculation and emission mitigation package

• Other supporting measures:

– Walking and cycling improvements

– Shuttle bus strategy for match days

Condition 34Prior to commencement of the construction works an emission mitigation package for the development shall be submitted in writing to the Local Planning Authority for approval. This shall include a revised emissions damage costs calculation undertaken in line with the DEFRA emissions factor toolkit and Interdepartmental Group on Costs and Benefits (IGCB) and shall adequately demonstrate that the emissions mitigation measures are proportionate to the damage costs. Once approved by the Local Planning Authority the emission mitigation package shall be implemented prior to first occupation of the development.

REASON: to mitigate and/or offset emissions associated with the operation of the site in accordance with National Planning Policy Framework paragraphs 109, 124 and 152, City of York Council's adopted Low Emission Strategy, City of York Council's draft Air Quality Action Plan (AQAP3), and City of York Council's draft local plan air quality policy.

York Community Stadium

• Damage cost £128,233. (NOx and PM prior to Sept 2015)

• Some off setting against sustainable transport measures

• Applicant has agreed to put around £50k into an air

quality mitigation fund. Details still under discussion but

would support:

– Existing low emission taxi scheme

– Low emission taxi procurement for conference facility

– Rapid charge facilities

– On site promotion / incentives for EV use

We can’t afford it!• Dealing with viability issues is difficult, particularly where internal

regeneration projects are involved

• Get all the evidence on the table – Why isn’t it affordable? What is

affordable?

• Look for win – win solutions, are contributions already being made

towards items that will assist in reducing emissions?

• Make use of case studies / advice from other LAs

• Negotiate as far as possible

• Decide whether or not to object - air quality is just one consideration

• Irrespective of recommendation ensure all emissions information is

included in the decision making process

Site Location NOx (t/5yrs) PM10 (t/5yrs)Damage Costs

(£/5yrs)

Housing

(Med, 50, Centre)Town centre 1.0 0.11 £28,100

Housing

(Lge, 500, Edge)Edge of town 16 1.9 £454,000

Food retail

(9,500 sqm, Edge)Edge of town 88 9.5 £2,460,000

Non-food retail

(3,000 sqm, Edge)Edge of town 6.9 0.75 £196,000

Office

(1,000 sqm,

Centre)

Town centre 2.1 0.25 £59,300

Fleet Depot

(50 HGVs, Edge)Edge of town 24 1.7 £608,000

Reference Sites

Year: 2016; Speed: 48 kph; Road type: Urban (not London); PM10 costs: Transport Average

Source: Low Emission Planning: Policy Appraisal Note & Annex (LEP, 2015-16)

Calculations using COMEAP ‘interim’ damage costs (Sep 2015)

and emission factors and fleet composition data from EFT (v6.0.1)

Bradford Planning Applications

Categorised into Land Uses

for modelling purposesSite details

Total Size for

Land Use

Assumed

Location

Residential (Mixed housing)18 sites (from 58 to 600 units)

Mixed housing selected as mid value3,619 dwellings Suburban

Retail (Food Retail) 3 sites (one incl. a petrol station) 6,738 sqm GFA Suburban

Retail (Non-food retail)2 sites, incl. 1 multi-use (coffee shop,

newspaper shop, hair salon)4,466 sqm GFA Suburban

Employment (Industrial)

3 sites modelled: (i) general industrial use;

(ii) industrial B1/B2; (iii) car servicing

(NB 2 EfW plants listed, but not modelled)

5,552 sqm GFA Suburban

Health (Care Home)2 sites: (i) care home; (ii) building incl. extra

care apartments, nursery, day centre5,746 sqm GFA Suburban

Leisure (Restaurant)

4 sites, incl. 3 restaurants and one multi-use

application (A1-A5 = non-food retail, office,

restaurant, pub, takeaway)

3,156 sqm GFA Suburban

Source: Low Emission Planning: Policy Appraisal Note & Annex (LEP, 2015-16)

Bradford H-A-B Assessment

Land Use Base Harm £AQ/5yrDamage Avoided

£AQ/5yrResidual £AQ/5yr

Residential £2,610,000 £275,000 £2,373,000

Food Retail £1,470,000 £213,000 £1,276,000

Non-food retail £366,000 £41,300 £330,400

Industrial £256,000 £56,900 £201,000

Care Home £35,900 £7,070 £29,210

Restaurant £538,000 £65,800 £479,800

TOTAL

(all land uses)£5,280,000 £659,000 £4,620,000

Overall reductions: 13% NOX 10% PM10 (majority of emission reductions from the travel plan)

Which translates to an 12% reduction in combined damage cost

Travel Plan, EV fleets

and HGV measures

Source: Low Emission Planning: Policy Appraisal Note & Annex (LEP, 2015-16) Recalculated using COMEAP

‘interim’ damage costs (Sep 2015) and emission factors and fleet composition data from EFT (v6.0.1)

(2) Regional Working

Draft Guidance Aug-Sep 2016

Regional Event Nov 2016

Policy Drafting Dec 2016

Lancaster Guidance

Development

Available: http://www.lowemissionhub.org/case-study/378/Lancaster-Guidance-and-Templates-(AQ-Planning-Guidance)

Local Pathways

Taking Stock

Current Position?

Aims and Intentions?

Pathway?

Potential Barriers

Commitment and Support?

Time and Resource?

Chicken and Egg – Guidance / Policy?

Lead Times?

Local Guidance Templates=> Choice of templates, design questionaire and tuning guidelines

to establish help establish best approach for local needs

Template 1

Template 2

Template 3

Standard

mitigation only

Standard mitigation for all sites

plus additional on-site

measures for larger sites

Standard mitigation for all sites

plus additional on-site measures for larger sites

potentially supplemented by a financial contribution

Low Emission & Air Quality Policy

Worked Examples

- Site Classification

- Emissions and Mitigation Assessment

- Applying Tests and Forming Opinions

Emissions Assessment Training

Workshop materials which take

participants step by step through the

emissions assessment process

Further Supporting Materials

(3) Local Policy

1. Traditional Air Quality Management

Primary emphasis to assessing concentrations

2. Traditional Air Quality Management

with greater emphasis on mitigation

3. Traditional Air Quality Management

with greater emphasis on mitigation

underpinned by single point damage calc

4. Integrated Air Quality/Emissions Management

including assessment of mitigation benefits

EPUK

Bradford

W. Yorks

Sussex

Lancaster

Evolution of Air Quality Planning Approaches

K&M

?

Traditional

Traditional

+ Mitigation

Low

Emission

York

Specific measures,

interventions and

contributions

Additional emissions

calculations & assessmentsConsideration of locations

beyond AQMA

Trad AQ Policy

AQMA = AQIA

Fully

Revised

Policy

Low Emission

& Air Quality

Policy

Fully

Revised

Approach

Low Emission

Planning

Guidance

All development proposals must seek to minimise the associated emission of harmful air pollutants

during both the construction and operational phases. They must also avoid causing or worsening a

breach of an air quality objective level or limit value, or exposing those who use and occupy the

site to unacceptable adverse exposure.

The developer must take these aims into account with regards choice of location and general

site/building design and transport arrangements. They are also likely to need to apply additional

on-site mitigation and where the latter is not sufficient to meet the policy aim, a further financial

contribution towards local air quality management off-site emission reduction measures may then

be required and considered as part of mitigation/offsetting proposals. This contribution will be

based on the calculated associated air pollutant damage costs.

Accompanying guidance provides details on site classification with reference to impact on existing

Air Quality Management Areas, standard mitigation requirements and assessment requirements

to demonstrate impact and mitigation performance levels. The latter includes the appropriate use

of both mass emission and pollutant concentration assessment methods.

Air Quality Assessments (AQA) must be submitted for any development proposal within or

adjacent to an Air Quality Management Area (AQMA). New development located within or

adjacent to an AQMA must ensure that users are not significantly adversely affected by the air

quality within that AQMA and include mitigation measures where appropriate. For development

proposals in urban areas the inclusion of solid fuel combustion appliances is discouraged.

Lancaster Policy (draft)

Policy Check List

Geographical Scope All sites

Air Quality Concerns Emissions Concentrations Exposure

Performance Expectations Minimise No worsening or breach No unacceptable impact

Compliance Domains Location / Design / Mitigation

Contributions Explicit Mention

Assessment Methods Emissions, Concentration and Exposure Assessment

Guidance Identified

(4) The Low Emission Partnership

1. Traditional Air Quality Management

Primary emphasis to assessing concentrations

2. Traditional Air Quality Management

with greater emphasis on mitigation

3. Traditional Air Quality Management

with greater emphasis on mitigation

underpinned by single point damage calc

4. Integrated Air Quality/Emissions Management

including assessment of mitigation benefits

EPUK

Bradford

W. Yorks

Sussex

Lancaster

Evolution of Air Quality Planning Approaches

K&M

?

Traditional

Traditional

+ Mitigation

Low

Emission

York

Low Emission Partnership (2008-2017). Direct project participants have included: Greenwich, Hillingdon,

Sefton, Mid Devon, Wigan, Oxford, Leeds, Sheffield, Maidstone, Tunbridge Wells, Sussex, York, Lancaster,

Birmingham, Salford and others... Plus wider networking and collaborations…

Original Guidance developed by the Beacons working group (2008). It was then consulted on, revised and re-published jointly with Defra (2010)=> Approach part of national guidance

Additional Guidance on Supplementary Planning Guidance (2011)=> First full LES policies adopted

(incl. MD, S, WM, B)

Further development work (2011-13)- LET development (method/data/tool)- standardisation and assurance study - integration with Hub data structures=> Gaps opening up between LEP

developments and local practice

Progress review, method development leading to substantial revisions (2014)- Local policy guidance (& York Doc)- Emissions Assessment Guidelines- Reporting template & checklists- LET Methods and Data- Local Policy Appraisal Method => Revised documents (2015)=> Further Updates (2016)=> Piloting and proving (2016+)

Low Emission Development

- York materials (2015)

- Lancaster materials (2016)

Plus:

Guidance Templates for Local adoption

Design Guide and Tailoring Questionnaire

Suite of Worked Examples

www.lowemissionhub.org

www.lowemissionstrategies.org