Air Quality Management Areas: Implications for planning applications

What is an Air Quality Management Area?

In the UK, there are Air Quality Standards which set the legal limits for outdoor levels of certain pollutants, including nitrogen dioxide (NO₂), particulate matter (PM10 and PM2.5) and sulphur dioxide (SO₂), at certain locations where members of the public would be regularly exposed. Air Quality Standards are based on extensive scientific research and the latest understanding of the relationship between a pollutant concentration and the potential health effects. An Air Quality Management Area, often called an AQMA, is an area where one or more of the UK Air Quality Standards are not likely to be met.

The Air Quality Standards for the UK are summarised in Table 1, below.

Pollutant	Objective	Averaging Period
Particulate Matter (PM10)	50 µg/m³ not to be exceeded more than 35 times a year (7 times a year in Scotland)	24 hours
	40 µg/m³ 18 µg/m³ (Scotland)	1 year
Particulate Matter (PM2.5)	20 µg/m³ 10 µg/m³	1 year
Nitrogen Dioxide (NO2)	200 µg/m³ (not to be exceeded more than 18 times a year)	1 hour
	40 µg/m³	1 year
Sulphur Dioxide (SO2)	266 µg/m³ not to be exceeded more than 35 times a year	15 minutes
	350 µg/m³ not to be exceeded more than 24 times a year	1 hour
	125 µg/m³ not to be exceeded more than 3 times a year	24 hours

If a local authority identifies an area where one or more of the Air Quality Standards are not likely to be achieved, it must declare an Air Quality Management Area there. This area can consist of just one or two streets, or it could be much bigger. For example, many of the London boroughs have declared the AQMA which cover the entirety of the administrative area, whilst in Epping Forest District, there is an AQMA which covers just one house.

AQMAs are established to address and manage air quality issues. Once an area has been designated as an AQMA, the local authority must develop and implement an Air Quality Action Plan (AQAP), within 12 months, to outline strategies and measures aimed at improving air quality. These plans may include industrial regulations, public awareness campaigns, and the promotion of cleaner technologies.

In the UK, most Air Quality Management Areas (AQMA) are declared due to exceedances of the annual mean Air Quality Standard for NO₂. NO₂ is a significant air pollutant associated with the combustion of fossil fuels, particularly in vehicles powered by internal combustion engines. In the UK, transport, and specifically road transport, is a major contributor to NO₂ emissions and the principal reason for non-compliance with the UK Air Quality Standards.

AQMAs are often found in urban areas with high levels of traffic, close to sensitive uses such as houses, hospitals and schools. Some of the cities with notable air quality challenges and a higher likelihood of having AQMAs include London, Birmingham, Manchester, and other metropolitan areas.

A summary of the number and type of AQMAs can be found on the UK AIR information resource website.

How do AQMAs influence planning applications?

The National Planning Policy Framework (NPPF) is a comprehensive set of planning policies that guides local authorities, developers, and decision-makers in land use planning. It emphasizes sustainable development, addressing various aspects such as environmental considerations, economic growth, and social well-being. The NPPF contains policy which relates to air quality and AQMAs. Paragraph 186 of the NPPF is reproduced below:

“Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement. So far as possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.”

To adhere to national and local planning policy, proposed development must ensure that it does not significantly worsen air quality or introduce members of the public into an area of unacceptable air quality.  

A planning application could cause the declaration of an AQMA in two principal ways:

• By building a sensitive development in an area where Air Quality Standards are exceeded, resulting in the declaration, or expansion of, an AQMA; or
• By increasing pollution concentrations in the local area, which contributes to an exceedance of an Air Quality Standard and the declaration of a new AQMA.

Within AQMAs, planning authorities often require air quality mitigation, such as enhanced ventilation strategies, that protects proposed users of development from the detrimental effects of poor air quality.  Developers seeking approval within AQMAs are also often required to adopt stringent emission limits. In London, for example, all new gas boilers are required to meet a NO_X emission limit of 40mg/kWh, and all development are required to be air quality neutral for transport and building emissions. The very largest development in London are also required to adopt an air quality positive approach, which means that a proposal must actively take measures to improve air quality. These controls ensure that new projects contribute to improving air quality, as opposed to exacerbating existing issues.  

Not all development is considered sensitive to air pollution and subject to the same controls, and it should be noted that the national Air Quality Standards do not apply at all locations. For example, a local authority would not likely require pollution concentrations across an industrial unit to comply with any Air Quality Standards. However, if a hospital, school, dwelling, or any other location where vulnerable members of the community might spend significant periods, was proposed in an AQMA, the local authority would rigorously scrutinise any application and likely require significant mitigation if exceedances of the Air Quality Standards were identified.

Air Quality Assessments represent a crucial element in the planning process within AQMAs. Developers, and their consultants, are required to conduct comprehensive assessments that evaluate a project’s compliance to the Air Quality Standards, as well as assess and mitigate the potential effects of emissions from their projects.

Moreover, AQMAs influence planning applications by ensuring the integration of air quality considerations into master planning. This holistic approach involves careful consideration of the layout of developments, transportation infrastructure, and green spaces. The aim is to minimize exposure to air pollutants and promote sustainable urban design that prioritizes environmental health and more sustainable forms of transport.

Frequently Asked Questions

Can I build in an AQMA?

• Yes, it is possible to build within an AQMA. However, the design of the development must be conscious of local air quality issues, ensuring future users of the development will not be subject to poor air quality, and ensuring that the development itself will not exacerbate existing issues.  Planning applications within AQMAs are scrutinized more closely to ensure that the proposed development aligns with the AQAP and does not exacerbate existing pollution levels. A planning application which does not consider air quality, through a comprehensive Air Quality Assessment, in an AQMA is likely to be refused permission.

What are the design considerations of building in an Air Quality Management Area?

• Designing a development within an AQMA requires careful consideration of several factors to minimize the impact on air quality and contribute positively to the local environment. The number of car parking spaces in an AQMA may be restricted, or there may be a requirement to install additional electric vehicle charge points. In addition, certain ways of heating a development (e.g. biomass boilers) may be restricted, with zero-emission sources, such as air source heat pumps, preferred.

What sort of planning material should I supply for a development in an AQMA?

• When submitting a planning application for a development within an AQMA, providing a comprehensive and accurate Air quality assessment, written by a competent professional,  is crucial to ensure that the proposal aligns with local planning policy and does not significantly worsen air quality in the area.  

How can I ensure that my development proposal meets air quality standards in an AQMA?

• To ensure compliance, it is essential to conduct a thorough Air Quality Impact Assessment (AQIA) as part of the planning application. This assessment evaluates potential emissions from the proposed development and recommends appropriate mitigation measures. Collaboration with air quality professionals and engagement with local environmental agencies can provide valuable insights to alight your project with air quality standards.

Should I speak to the local authority when proposing a development in AQMAs?

• It is always recommended to speak to the local authority, or take advantage of their formal pre-application service, to discuss air quality and understand their priorities.  Seeking their expertise and guidance can contribute to informed decision-making and maximise the chances of planning permission being granted.