England’s Chief Medical Officer, Professor Chris Whitty, in his annual report published on 8th December 2022, set out that more must be done, and can be done, to improve air quality across the UK.
The report’s executive summary begins by explaining that “air pollution affects us all” and that the mortality burden associated with air pollution in England is estimated to be between 26,000 to 38,000 people a year. The report describes the long and short-term trends in air pollution, how major UK cities have improved air quality, the importance of urban planning in minimising emissions and reducing exposure and, importantly, where further research is needed.
The report does not constitute planning policy. It does, however, give some indications as to what the Government might do next in terms of policy and legislation, which will impact developers.
The Chief Medical Officer’s report has a whole section on the role that urban planning can play in reducing emissions and minimising people’s exposure to air pollution. The report highlights that active travel should be encouraged, and that additional focus should be placed at improving air quality near sensitive uses such as schools and healthcare facilities. It also supports the electrification of the domestic, road transport, aviation and shipping sectors.
Whilst the report recognises that there have been significant improvements in air quality since the 1970s, it outlines that improvements in PM2.5 (amongst the most dangerous of air pollutants) have stalled in the past decade. It discusses how burning wood for domestic heating (a major source of PM2.5) has risen in popularity in recent years due to a combination of aesthetic, practical, ecological, and economic reasons.
The Government has already proposed a non-binding annual mean PM2.5 target of 10μg.m-3 (a target which is half the legally binding standard of 20μg.m-3) and it is strongly mooted that the national air quality standard for PM2.5 will be changed to 10μg.m-3 when Defra stops dragging its feet (it has already missed its legally binding target for setting a new air quality standard for PM2.5 as part of the Environment Bill 2021). When selecting a new Air Quality Standard for PM2.5 The Environment Act 2021 requires that the Secretary of State is satisfied that the targets are achievable and Chris Whitty’s language suggests that further improvements are “technically possible”. This could be construed as tacit support for tighter Air Quality Standards for PM2.5.
In the event the annual mean Air Quality Standard for PM2.5 is tightened there would be a significant growth in the number of non-compliant areas across England and Wales. Air quality would, therefore, likely become more of a material consideration in planning applications. Where sensitive development is proposed in an area where the Air Quality objective for PM2.5 is breached, it would likely need to consider incorporating air purification technology, including filters, to supply the development with clean air.
The report also focuses on the topic of indoor air pollution, highlighting that as outdoor air quality improves, the relative importance of indoor air quality increases. The Chief Medical Officer also discusses the role that indoor air quality should have in future planning decisions, with the report challenging the engineering sector to find a solution that maximises ventilation (to improve air quality) but minimises energy losses associated with additional heating and cooling. This will be an essential challenge to ensure that development promotes both net-zero and the health of its occupants.
There is a lack of legislation surrounding indoor air quality and the promotion of good indoor air quality in development is currently being guided by certification schemes such as WELL, BREEAM and LEED. It is considered prudent for developers to think more about indoor air quality and to perhaps consider future proofing developments by targeting credits such as BREEAM’s Indoor Air Quality BREEAM HEA 02 credit.
The Chief Medical Officer’s Report on Air Pollution: Key takeaways for developers:
Whilst the Chief Medical Officer’s report on air pollution report is not planning policy, it does provide insight into the Government’s thought process and does provide indications of where additional legislation to tackle air pollution is being investigated. A summary of the key takeaways from this document are:
- The Government, as part of its obligations under the Environmental Act, are required to set a new legal standard for PM2.5. It is expected to that the existing annual mean standard will decrease from 20μg.m-3 to 10μg.m-3. This would increase the area of the UK which is non-complaint with the National Air Quality Standards. The number of developments which would need to consider air quality as part of the ventilation strategy, through the incorporation of filtration and air purification systems, would therefore increase.
- There will likely be increased emphasis on the air quality effects of development around schools and healthcare facilities, during both the construction and operational phases.
- There will be no let up in the promotion of active travel and the drive for electrification of the transport and domestic heating sectors.
- It is inevitable that greater emphasis will be placed on indoor air quality in the future, meaning that developers will need to think more about ventilation, the choice of materials, building layout and potentially, air quality monitoring in developments. The targeting of BREEAM indoor Air Quality credits (HEA 02) is considered a good place to start in promoting good air quality in development. In London, the Air Quality Positive Assessment framework would achieve the same goal.
- There will need to be enhanced collaboration between indoor air quality specialists and ventilation specialists to ensure that good indoor air quality is maintained, without jeopardising energy efficiency and net zero.
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