Air Quality Neutral and Air Quality Positive Assessments

What is an air quality neutral assessment?

All development across London must be air quality neutral, in line with Policy SI1 of the London Plan. The air quality neutral policy was created to tackle incremental increases in pollution that were caused by successive development, which might of individually had insignificant impacts. The air quality neutral policy seeks to encourage the transition to more sustainable forms of transport, and to zero-emission heating. It has effectively banned the use of woodburners in new and refurbished buildings across the Capital.

Each proposal has an allowable pollutant (NO2 or PM2.5) generation rate, dependent on the proposed land-use and scale of development. If the air quality neutral assessment identifies that the amount of pollution exceeds the benchmarked values, changes to the design, additional mitigation or financial offsetting will then be required. Planning applications for all development in Greater London must include details of whether it meets the air quality neutral criteria for both building and transport emissions, or risk refusal.

The Greater London Authority provides guidance on how air quality neutrality should be assessed for different development types. Major developments are required to provide a full air quality neutral assessment, regardless of its location. However, minor development which meet certain conditions may be able to follow a simplified procedure. A specialist air quality consultant may not be required to support an application which only requires the simplified procedure; however, we strongly recommend that you engage a professional air quality consultancy such as Greenavon Air Quality Consultants, to support an application that requires a full air quality neutral assessment.

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What is the simple procedure for Air Quality Neutral?

Proposed minor development in London (outside of Air Quality Focus Areas) can judged to be air quality neutral for building emissions, if it can be demonstrated that they meet the criteria below:

  • the new heating system is a heat pump or other zero-emission heat source.
  • the new heating system includes one or more individual gas boilers with NOx emissions rated at less than 40 mg/kWh
  • the development is connecting to an existing heat network.

Proposed minor development in London (outside of Air Quality Focus Areas) can judged to be air quality neutral for transport emissions where parking provision does not exceed the maximum parking standards set out in policies T6 and T6.1 to T6.5 of the London Plan.

What if my proposal is not air quality neutral?

If the air quality neutral assessment demonstrates that the building or transport benchmarks are not met, then the project will not be considered air quality neutral. Consequently, the design must then be adjusted to meet the criteria. As an example, If the transport emission benchmarks were exceeded, the design could be altered to incorporate fewer car parking spaces. If the proposed adjustments cannot be accommodated or still do not result in meeting the standards, the next step would be to consult with the local planning authority to agree an approach to reduce on-site emissions.

As a final option, and at the discretion of the local authority, an offsetting payment may be negotiated with the local authority. This approach requires calculating the annual monetary value of emissions above the benchmark and then offsetting the impacts, using Defra’s latest damage costs for NO2 and PM2.5. The offsetting payment’s total amount is calculated over a 30-year period and can result in a significant payment to the local authority. The guidelines emphasize that modifying the development to meet the benchmarks is the preferred solution, and offsetting is the last resort. As such, we recommend engaging an air quality professional at the earliest stage of design to ensure that your proposal can be made to be air quality neutral.

What is an air quality positive statement?

An air quality positive approach seeks to incorporate consideration of air quality at the earliest stage of project design and represents a fundamental change in the way air quality is assessed for major development in London. To maximise the benefits of the air quality positive approach, and minimise any planning risk, it is essential that you get an air quality consultant on board at the project’s inception, or as soon as practicably possible.

The approach has the duel-goal of minimising a development’s exposure to existing poor air quality and actively seeking to improve air quality through incorporating the know-how of architects, transport consultants, sustainability specialists and of course, air quality consultants.

Air Quality Positive statements demonstrate how air quality has been considered throughout the design of the proposal and should signpost where a design decision was made, in part, due to air quality. Themes that contribute towards the delivery of an Air Quality Positive Scheme include:

  • Better Design and Reducing Exposure, including evaluating whether sensitive uses can be set back away from pollution sources, or whether the built form, or green infrastructure, can encourage the effective dispersion of pollutants.
  • Building Emissions and seeking opportunities to provide low or zero emissions energy systems
  • Transport Emissions, including assessing whether the scheme can be car free and whether the design can support cargo cycles or micro-consolidation services to minimise last-mile emissions.
  • Innovation and Futureproofing. For example, evaluating whether the scheme is capable of accommodating zero-emission fuels (e.g. hydrogen), and new technologies when they become available.

The Greater London Authority have provided an in depth video on the purpose of air quality neutral assessments and air quality positive assessments, which has been reproduced below.

Air Quality Positive and Air Quality Neutral Guidance – 7 December 2021 – Overview for All – credit:
London Plan and London Plan Guidance

How Greenavon can help?

Greenavon has significant expertise in preparing air quality neutral assessments and air quality positive statements. For a free consultation, please do not hesitate to get in touch.

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