Air Quality Assessments – London

Air pollution levels across London regularly exceed the national air quality objectives and most of Greater London has been declared an Air Quality Management Area (AQMA). The Greater London Authority and Mayor of London are implementing a range of measures across the Capital to reduce pollution concentrations and improve the health of Londoners. These measures include the rollout of the Ultra-Low Emission Zone (ULEZ) which expanded on the 29th August 2023, to cover almost the entirety of Greater London, as well as the promotion of Clean Air Neighbourhoods and School Streets schemes.

Due its size, population and density and very high levels of pollution, air quality in London is managed differently to the rest of England. It has its own air quality strategy, as well as guidance for the management of air quality (LLAQM.TG.19). Furthermore, the London Plan includes a series of air quality policy which is seen nowhere else in the country. These include the need for all development to be “air quality neutral” and for major/ strategic development to be “air quality positive”. Furthermore, generators and non-road mobile machinery (NRMM) on construction sites must meet stringent emission standards.

For more information about current levels of air quality in London, visit the London Air website.

Why are air quality assessments needed in London?

All development must be air quality neutral in London for both building and transport emissions, for minor development air quality neutrality with respect to transport emissions can be demonstrated if they do not exceed maximum parking standards set out in policies T6 and T6.1 to T6.5 of the London Plan. Air Quality neutrality with respect to building emissions can be demonstrated if heating strategy is zero-emission (e.g. heat pumps), it is connected to an existing heat network, or where the new heating system is powered by a low NO_X boiler.

Air quality assessments in London are required to ensure that proposals do not significantly impact neighbours during construction (e.g., from the release of dusts and odorous gases from construction and demolition), during operation (due to the release of emissions from central heating systems, or from associated road vehicles) and to make sure the design is sensitive to existing areas of poor air quality. As London is such a densely populated space, consideration of air quality during operation and construction is important to protect Londoners health and amenity. Air Quality Assessments in London are undertaken in line with best practice Greater London Authority on the Control of Dust and Emissions and the Institute of Air Quality Management Guidance (IAQM).

Air quality impact assessments are generally required in London if a proposal includes more than 10 houses, includes more than 1000m² of commercial floorspace, or introduces highly sensitive uses next to a main road, or other pollution source. The London Plan provides further guidance of when air quality assessments may be required, stating that “for major developments, a preliminary Air Quality Assessment should be carried out before designing the development to inform the design process” and that “further assessments should then be carried out as the design evolves to ensure that impacts from emissions are prevented or minimised as far as possible“. All major development should therefore adopt an air quality positive approach, and identify opportunities to improve, and not just maintain, local air quality.

With regard to minor development, the London Plan states that “for most minor developments, achieving Air Quality Neutral will be enough” and therefore, only an air quality statement would be required to accompany most minor applications. It, however, notes that “where characteristics of the development or local features raise concerns about air quality, or where there are additional requirements for assessment in local policy, a full Air Quality Assessment may be required.” Examples of characteristics that might lead to a requirement for a full air quality assessment include:

• if the application site is located in an Air Quality Focus Area.
• if the proposed development is a school, nursery or a care home.
• If the proposal includes a significant emission source, or is located near a major road.
  

Borough Specific Air Quality Guidance

Each London Borough manages air quality in its own adminstrative area and many councils have their own unique requirements. The London Boroughs with special requirements are as follows:

When might you need an odour assessment in London?

Several London boroughs including Bexley and Brent also require that all new kitchen extract systems are designed in line with best practice guidance to minimise the potential for any odour impacts (Control of Odour and Noise from Commercial Kitchen Exhaust Systems). Westminster, for example, has its own odour/ kitchen extract guidance detailing exactly what is needed in the City of Westminster to gain planning permission for new extract systems.

How Greenavon can help?

Greenavon have developed close working relationships with several local authority officers across Greater London. We routinely consult with local authority officers to discuss a project and, where possible, agree the assessment approach in advance of planning submission. This is done to maximise the project’s chances of gaining planning permission and minimising the need for any additional work which might be required via planning condition.

In London, Greenavon can assist with the following types of assessment:

• Air Quality Assessments and Air Quality Statements
• Odour Assessments
• BREEAM Indoor Air Quality Plans
• Air Quality Neutral Assessments
• Air Quality Positive Statements
• EMAQ+ Kitchen Odour Risk Assessments
• Dust Management Plans, and Construction Dust Risk Assessments
• Dust Monitoring

Where we work in London

City of London│ Camden│ Hackney│ Hammersmith and Fulham│ Haringey│ Islington│ Kensington and Chelsea│ Lambeth│ Lewisham│ Newham│ Southwark│ Tower Hamlets│ Wandsworth│ City of Westminster│ Barking and Dagenham│ Barnet│ Bexley│ Brent│ Bromley│ Croydon│ Ealing│ Enfield│ Greenwich│ Harrow│ Havering│ Hillingdon│ Hounslow│ Kingston upon Thames│ Merton│ Redbridge│ Richmond upon Thames│ Sutton│ Waltham Forest│