Local air quality management: policy guidance

11. Placemaking and air quality action planning

Placemaking is about collaborative working across professions and with communities to identify place-based solutions for the issues we face. Placemaking done well helps address air pollution, and creates better quality, more sustainable places that contribute to improving our mental and physical health.

This guidance should be read alongside National Planning Framework 4 (NPF4) ^[22] and the Local Development Plan (LDP)^[23] for the area. The Place Principle^[24], the Place Standard Tool^[25] and the Local Living Framework^[26] are also referenced and are all applicable to thinking about our existing and future places in relation to air quality.

11.1 Background

The planning system will impact on improving air quality mainly in the longer term through local development plans that seek to tackle health inequalities. Day-to-day decision making on individual planning applications can help improve air quality or avoid or mitigate air quality impacts that could be caused or be exacerbated.

The Place Standard Tool can support individuals, communities and organisations think in a structured way about physical and social aspects of place that are important to health and wellbeing. It helps to identify strengths and weaknesses as a means of prioritising action for improvements.

National Planning Framework 4 (NPF4) is the Scottish Government’s national spatial strategy for Scotland’s long-term development. Local development plans are prepared by planning authorities across Scotland. These are the 32 Councils in Scotland and the National Park Authorities.

11.2 National Planning Framework 4 (NPF4)

NPF4 is part of the statutory development plan for the area along with the LDP. The NPF4 spatial strategy supports the planning and delivery of sustainable places, liveable places and productive places. It was informed by CAFS2.

The approach of Policy 23 ‘Health and Safety’ is crucial for considering air quality impacts. The policy does not support new developments with significant adverse impacts for air quality. It is clear that development proposals will consider opportunities to improve air quality and reduce exposure to poor air quality. The policy also enables air quality impact assessments to be undertaken for proposals for new development where the proposal or the air quality in the location suggest significant effects are likely.

AQMAs are not directly addressed in the NPF4 policy. However, a proposal for new development within an AQMA can indicate to applicants and the planning authority that particular attention to the air quality aspects of NPF4 policy and spatial strategy should be considered in the design of and decision making on development proposals.

Where an air quality impact is likely from proposed development, Environmental Health Officers should discuss the issues raised and potential options with the relevant planning officers.

Other NPF4 policies relating to air quality include:

• Policy 2 Climate mitigation and adaptation: The policy aims to promote and facilitate development that minimises greenhouse gas emissions, some of which also have air quality impacts.
• Policy 11 Energy: The policy aims to promote and facilitate all forms of renewable energy including those associated with negative emissions technologies, carbon capture and the co-location of such technologies.
• Policy 12 Zero waste: The policy is clear that proposals for waste infrastructure and facilities (excluding landfill and energy from waste) will only be supported where a range of matters are addressed including part (d)(ii), environmental impacts including pollution of air. Part (g) does not support proposals for energy from waste facilities except under limited circumstances set out in the policy.
• Policy 13 Sustainable Transport: The policy supports the sustainable transport hierarchy and a place-based approach to consider how to reduce car dominance and supports active forms of movement.
• Policy 14 Design, Quality and Place: The policy supports well designed development leading to successful places through the application of the six qualities of successful places. The ‘Pleasant’ quality includes mitigating against air pollution. The ‘Connected’ quality supports well connected networks to make moving around by active and sustainable means easy to support reduced car dependency.
• Policy 15 Local Living and 20 Minute Neighbourhoods: The policy supports the creation of compact neighbourhoods where people can meet the majority of their daily needs by active or sustainable transport options.
• Policy 33 Minerals: The policy supports sustainable management of resources and minimisation of extraction impacts on communities and the environment. Part (d)(iv) is clear that proposals should demonstrate acceptable levels of potential pollution including for air.

11.3 Development management

The Town and Country Planning (Scotland) Act 1997^[27] provides that planning permission is required to carry out works which constitute ‘development’ for the purposes of the Act. Applications for planning permission are determined on the basis of policies in the development plan (NPF4 and the LDP) and material considerations.

Permitted Development Rights (PDR) grant planning permission through legislation, thereby removing the need to apply for such permission where development complies with specified conditions and limitations. This includes domestic flues, including those related to biomass heating systems which can impact air quality. There are also PDR for extensions to industrial, forestry and agricultural buildings for the purposes of biomass burning. Further guidance on domestic and non-domestic PDR can be found in relevant planning circulars^[28].

The full policy wording contained in NPF4 should be referred to in the preparation of development proposals, commentary and decision making on them. Some LDPs may have particular arrangements in their spatial strategy and policies in relation to air quality. These approaches should be understood and applied to development proposals.

11.4 Place Standard Tool

The integrated approach offered by the Place Standard^[29] tool to understanding the physical, social, and economic aspects of a place provides a holistic means of assessing and taking action on issues such as travel and transport, green infrastructure, place design and layout, that can deliver co-benefits such as air quality improvements.

The Place Standard tool with Air Quality Lens^[30] is specifically designed to be used in areas to engage with local communities to find out how local people feel about air quality, and their ideas to improve air quality. These additional specific prompts can support a stronger focus on air quality within a holistic assessment of a place. This can support actions to address air quality concerns, as well as help to raise awareness and engagement with the issue.

More recently, the Place Standard with Climate Lens^[31] provides step-by-step support on how to develop productive conversations focussed on the important relationship between place and climate change and environmental sustainability. It too integrates air-quality related issues, with a range of practical resources to support users.

Another complementary addition to inform the emerging design or development of a place is the ‘Design’^[32] version. It is aimed at designers (architects, planners), developers and clients to directly inform and support the design and development process to deliver healthier places, including the delivery of air quality improvement co-benefits.

All the Place Standard tool resources are free and easy to use and a range of guidance, resources and additional materials available online will guide you to plan and carry out your assessment^[33].

11.5 Air quality as a material consideration

Air quality is capable of being a material planning consideration, in so far as it

affects land use. Whether it actually is will depend upon the facts of the case. Wherever a proposed development is likely to have significant air quality impacts,

close co-operation will be essential between planning authorities and those with

responsibility for air quality and pollution control. The impact on ambient air quality is

likely to be particularly important where:

• the proposed development is inside or adjacent to an AQMA;
• the development could result in designation of a new AQMA; and
• the granting of planning permission would conflict with, or render unworkable, elements of a local authority's air quality action plan.

This does not mean that all planning applications for developments inside or

adjacent to AQMAs should automatically be refused if the development is likely to

affect local air quality. Such an approach could sterilise development, particularly

where authorities have designated large areas as AQMAs. All such applications will

continue to be considered according to their individual merits on the basis of all

available information. It may mean, however, that consideration of planning

conditions could be required in some circumstances.

In considering whether a site inside an AQMA is an appropriate location for

new housing, planning authorities should consider where within the AQMA likely

exeedences have been identified, how great these exceedences are and when it is

forecast that the objectives will be met. It should also consider the potential effect on

air quality of the new housing development.

11.6 Air Pollution Assessment Service (APAS)

The Air Pollution Assessment Service (APAS)^[34] is a novel tool developed by the Joint Nature Conservation Committee (JNCC) and partners including SEPA to enable planning authorities to carry out air quality and human health assessments during the planning process. APAS will support the CAFS strategies by incorporating the National Modelling Framework (NMF) Regional Air Quality Model in its work to allow planning authorities to screen and assess potential impacts on air quality arising from changes in traffic-related emissions associated with large-scale development proposals.

The Improvement Services (IS) and Transport Scotland are working on the development of common standards to guide future traffic data collection. The IS established a central facility to store traffic data which is now live on the Spatial Hub. Local authorities are encouraged to upload their existing and new traffic data to these pages with the aim of providing a “one stop shop” for traffic data. This will enable local authority planners to retrieve and utilise the most recent data more easily and add it into development planning scenarios in APAS.

Bringing together both ecosystem and human health assessments into one platform will support the local air quality management and NPF4 objectives in delivering sustainable places that protect human health and the wider environment.