NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.

Air quality

Proposed key objective of NPF4: To ensure that the planning system helps tackle poor air quality and promote good air quality through the promotion of sustainable placemaking and transport links and ensuring that new developments are guided towards appropriate locations

Comments in relation to air quality were often brief and focused on the importance of good air quality and/or improving air quality from a public health perspective. They included that vulnerable and disadvantaged people are disproportionately affected by the impacts of poor air quality.

The improvement in air quality during the COVID-19 crisis was noted, and it was reported that levels of nitrogen dioxide and PM2.5[21] emissions have seen dramatic falls. The connection was made to reductions in private car use in particular, and it was reported that there are currently 38 Air Quality Management Areas throughout Scotland, with the majority of them declared as a consequence of road traffic pollution.

Going forward it was suggested that consideration should be given to improving public transport and increasing opportunities to work closer to home. The role that land use planning can play in improving local air quality was noted, including as the pattern of land use determines the need for travel, which is in turn is a major influence on transport-related emissions. It was also reported that green infrastructure in and around streets and buildings has a major part to play in reducing urban temperatures and reducing demand for air conditioning, and also has the potential to reduce air pollution including particulates.

It was suggested that air quality should be given greater emphasis in the planning process, with specific NPF4-related comments or suggestions including that greater emphasis should be placed on planning authorities undertaking the necessary action to improve air quality, and that this should be supported by effective resourcing. Other suggestions included that:

  • The Good Design Principles set out in the Environmental Protection UK and Institute of Air Quality document Land-Use Planning and Development Control: Planning for Air Quality[22] should be employed during the planning process.
  • NPF4 Impact Assessments should be thoroughly tested in terms of managing harmful air quality-related impacts but also emphasising opportunities to manage health impact.
  • There should be a requirement to prepare low emissions strategies.
  • There should be full integration of the inputs of the planning, transport, housing, education and environment services to ensure that environmental considerations, including those related to air quality, are considered at the earliest stages of the strategic planning processes.
  • Careful consideration should be given to the location of developments where particularly sensitive members of the population are likely to be present, such as in the case of schools.
  • Although air quality is already a material consideration when determining planning applications, policy should be more focused on ensuring all development makes a contribution towards improving air quality. Incentives as well as restrictive measures will be needed to make this happen.
  • Additional measures to offset emissions should be encouraged at an early stage in the design process. It is important that obligations to include offsetting are proportional to the nature and scale of development proposed and the level of concern about air quality; such offsetting can be based on a quantification of the emissions associated with the development.
  • More air quality monitoring would help characterise where poor air quality is predicted to become an issue in the future, perhaps due to development being consented now.

It was also noted that there is an ongoing review of the Cleaner Air for Scotland Strategy. It was suggested that NPF4 should provide support for the implementation of the new Cleaner Air Strategy which must be enshrined within the new SPP.

Other themes raised included the need to develop sustainable and active travel options, reduce energy use, manage waste and the circular economy and improve building standards. All these issues are explored further under the relevant themes.



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