The Air Quality Positive Approach: Key Takeaways for Developers

With the expansion of the Ultra-Low Emission Zone and decreasing emissions from the average vehicle, air quality across London is generally improving. As such, an ever-increasing area is becoming compliant with the UK’s National Air Quality Standards (AQSs) and other local targets. However, it is widely acknowledged that there are no safe levels for some pollutants and as such, exposure to air pollution should be minimised. The Air Quality Positive approach provides a means by which development can support the Greater London Authority’s target of going beyond mere compliance, by providing a framework to minimise emissions and reduce exposure from new development.

This represents a major shift in the way air quality is assessed for major development in London. The Air Quality Positive approach outlines that there are no set targets to achieve, which differs from the Air Quality Neutral approach, with the only requirements being that:

  • There must be evidence that air quality has informed design.
  • Design decisions which influence air quality can be justified.
  • The benefits of any measures are estimated using reasonable evidence.
  • There must be a plan setting out how measures are secured (e.g. by design, by condition).
  • Details must be provided about how long-term targets will be monitored.

The lack of set targets and criteria presents challenges to Developers and project teams who can find certainty and comfort in the achievement of set thresholds. As such air quality consultants will need to take a far more prominent role in the design, including at the earliest stages, to maximise the chances of successful outcomes.

What should Air Quality Positive Statement include?

Air Quality Positive statements should not only include details of the air quality mitigation measures proposed, but it should also act as a guide to identify how air quality influenced the design, as well as a reference document demonstrating where information relating to air quality can be found in the wider application. Air Quality Positive statements suggest that some form of air quality assessment (e.g. air quality modelling) should be undertaken at the very start of the project to identify the areas of highest risk to poor air quality, with this information feeding into design.

Major development as defined by The Town and Country Planning (Mayor of London) Order 2008 are required to provide an Air Quality Positive Statement that identifies how:

  • The proposal was designed to minimise exposure to pollution, including through the siting of particular uses, the building aspect and design, the incorporation of green vegetation and connectivity to existing sustainable travel networks.
  • The energy strategy is designed to minimise emissions through low emission or zero emissions technology.
  • Transport emissions were reduced from users of the proposal, through influencing travel behaviour.
  • The proposal considers new and emerging technologies in the design, which might provide additional emissions reductions options in the future.

The development included in the table below will require an Air Quality Positive statement. The Table below was taken from the latest Air Quality Positive guidance.

Category 1ADevelopment which comprises or includes the provision of more than 150 houses, flats, or houses and flats.
Category 1BDevelopment (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings: (a) in the City of London and with a total floorspace of more than 100,000 m2
(b) in Central London4 (other than the City of London) and with a total floorspace of more than 20,000 square metres; or outside Central London and with a total floorspace of more than 15,000 m2.
Category 2C:
Paragraph 1,
parts (a) to (f)
Development to provide:
(a) an aircraft runway (b) a heliport (including a floating heliport or a helipad on a building)
(c) an air passenger terminal at an airport
(d) a railway station or a tram station
(e) a tramway, an underground, surface or elevated railway, or a cable car
(f) a bus or coach station.
Category 2C:
Paragraph 2
Development to alter an air passenger terminal to increase its capacity by more than 500,000 passengers per year.
Category 2C:
Paragraph 3
Development for a use which includes the keeping or storage of buses or coaches where:
(a) it is proposed to store 70 or more buses or coaches or buses and coaches; or
(b) the part of the development that is to be used for keeping or
storing buses or coaches or buses and coaches occupies more than 0.7 hectares.
Category 2DWaste development which does not accord with one or more
provisions of the development plan in force in the area in which the application site is situated and which falls into one or more of these sub-categories:
(a) it occupies more than 0.5 hectares;
(b) it is development to provide an installation with a capacity for
a throughput of more than:
(i) 2,000 tonnes per annum of hazardous waste; or
(ii) 20,000 tonnes per annum of waste.
Table: Development type requiring an Air Quality Positive Statement

Greenavon and Air Quality Positive Statements

The Air Quality Positive approach represents a fundamental change in the way air quality is assessed for Major development in London, altering the focus from mere compliance to the AQSs to a holistic exploration of ways air quality can be improved considering energy, green infrastructure and transport. This holistic approach will present challengers to architects and developers, as they will need to balance the often-competing demands of various disciplines.

If you are proposing a ‘Major’ development in London, it is essential that you engage an air quality consultant at the earliest opportunity to identify opportunities to reduce exposure and improve air quality. The lack of set criteria will also mean that it will be essential to engage local authorities and their officers, in structured discussions, to ensure that a robust framework is produced to avoid a shifting of expectations and requirements from the local authority.

Air Quality Positive Statements will form another document in the application pack for Major Developments across London. They are a means of ensuring that air quality is considered at the earliest stages of a development’s design. As experts in air quality assessment and management, we are well placed to support you deliver the Air Quality Positive approach for your proposal. For a free consultation on how the air quality positive might impact your project, please do not hesitate to get in touch.  

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