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West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies Ltd LES Ltd Low Emission Strategies

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Page 1: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

West Yorkshire / West Midlands Low Emission Strategy Planning

Guidance

IAQM, September 25th 2013Andrew Whittles

Managing DirectorLow Emission Strategies Ltd

LES LtdLow Emission Strategies

Page 2: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

Contents

• Evolution• Guidance• National Planning Policy Framework• West Yorkshire / West Midlands LES Guidance• Conclusions

LES LtdLow Emission Strategies

Page 3: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Exposure

Blackheath Road, Greenwich

Page 4: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

“Greenwich hope to improve air quality by piping clean air in from Bexley”

AQB, 2001

LES LtdLow Emission Strategies

Page 5: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Greenwich Peninsula LEZ

Page 6: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Greenwich Millenium Village

Page 7: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Greenwich Peninsula

Page 9: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Page 10: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Applicable RangeNitrogen DioxideAnnual Mean

Applicable Range PM10

Recommendation

APEC – A > 5% below national objective Annual Mean:> 5% below national objective24 hr:> 1-day less thannational objective

No air quality grounds for refusal; however mitigation of any emissions should be considered.

APEC – B Between 5% below or above national objective

Annual Mean:Between 5% above or below national objective24 hr:Between 1-day above or below national objective.

May not be sufficient air quality grounds for refusal, however appropriate mitigation must be considered e.g., Maximise distance from pollutant source, proven ventilation systems, parking considerations, winter gardens, internal layout considered and internal pollutant emissions minimised.

APEC – C > 5% above national objective Annual Mean:> 5% above national objective24 hr:> 1-day more than national objective.

Refusal on air quality grounds should be anticipated, unless the Local Authority has a specific policy enabling such land use and ensure best endeavours to reduce exposure are incorporated. Worker exposure in commercial/industrial land uses should be considered further. Mitigation measures must be presented with air quality assessment, detailing anticipated outcomes of mitigation measures.

London Councils, 2007

London Guidance

Page 14: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

Low Emission Strategies

LES LtdLow Emission Strategies

Page 15: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Development Type Applicability Mitigation Measures Residential Commercial Industrial Notes Construction Phase Low Emission Strategy / Scheme Elements:

- On-road vehicle specification1 - Recharge/refuel infrastructure - NRMM22Specification3 - Sustainable delivery strategy

Operational Phase Low Emission Strategy / Scheme Elements:

- Differential parking levy4 - Priority parking5 - Emission specified parking5 - EV dedicated parking5 - Low Emission Taxi Rank5,6,7 - Alternative fuel infrastructure6,7 - Fleet emission specification1 - Fleet emission strategy1 - Procurement strategy1,8 - Bicycle/E- bike rental scheme6,7 - Car club6,7 - Low Emission car club6,7 - Resident incentives9 - Employee incentives9 - Visitor incentives9 - Information networks6,10 - Waste to fuel segregation,

collection/process6,7,11,12

Yes Yes Yes Yes Yes Yes Yes Yes -

Yes - - - Yes Yes Yes Yes - - Yes Yes

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes - Yes Yes Yes Yes

Yes Yes Yes Yes - - Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes - Yes - Yes Yes

1See Table – Low Emission Technologies: Applicability and Availability 2 Denotes Non-Road Mobile Machinery 3See London Code: Reducing Emissions from Construction & Demolition Sites (Greater London Authority) 4 Where charge is levied on off-street parking 5 Off-street parking provision 6 Option for provision by scheme off-set 7 Consideration may be required of adoption of Community Infrastructure Levy (CIL). CIL allows for capital (non-revenue) costs 8 Recommended/required via contract/restrictive covenant 9 Incentives may include store/club card /leisure facility discounts etc 10 Information internet/other media concerning low emission strategy options,/impact of options 11 Consideration to segregation of waste, capable of providing renewable fuel, and disposal/processing into low emission fuels 12 Local authorities may consider upgrade of vehicle technologies concerning RCVs/vans and community transport provision

Page 16: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Page 17: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Page 18: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Planning policies should sustain compliance with and contribute towards EU limit values ornational objectives for pollutants, taking into account the presence of Air QualityManagement Areas and the cumulative impacts on air quality from individual sites in localareas. Planning decisions should ensure that any new development in Air QualityManagement Areas is consistent with the local air quality action plan

(Paragraph 124)

National Planning Policy Framework

Page 19: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Planning policies should sustain compliance with and contribute towards EU limit values ornational objectives for pollutants, taking into account the presence of Air QualityManagement Areas and the cumulative impacts on air quality from individual sites in localareas. Planning decisions should ensure that any new development in Air QualityManagement Areas is consistent with the local air quality action plan or low emission strategy

(Paragraph 124) (DCLG website 2013)

NPPF....

Page 20: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Plans should protect and exploit opportunities for the use of sustainable transport modes forthe movement of goods or people. Therefore, developments should be located and designedwhere practical to:- incorporate facilities for charging plug-in and other ultra-low emission vehicles; andconsider the needs of people with disabilities by all modes of transport

(Paragraph 35)

NPPF...

Page 21: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

If setting local parking standards for residential and non-residential development, localplanning authorities should take into account:-an overall need to reduce the use of high-emission vehicles

(Paragraph 39)

NPPF...

Page 22: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Bradford Low Emission Strategy - Foreword

“The existence of a black pall of smoke over the town is quite unnecessary to thetrade of Bradford…the existence of the unnatural and unhealthy condition of theatmosphere is highly prejudicial.....” said Dr. Thomas W Hime, Medical Officer ofHealth for Bradford, in his annual report to the Council in 1884.

At Bradford Council we have long recognised that clean air is fundamental for thedistrict to prosper, and be an attractive place to live, work and invest. The adoptionof our Air Quality Strategy in April 2011 continued the council’s commitment toprotect the health of its residents.

Transport is now the major contributor to our air quality problems. This Low EmissionStrategy outlines how the council will work with the public and the private sector, andwith other stakeholders, to implement measures which reduce the impact ofemissions from traffic on public health and air quality, whilst simultaneouslycontributing to the regeneration of our economy.

Cllr Andrew Thornton: Portfolio holder for Environment, Sport & Sustainability

Page 23: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Page 24: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

West Yorkshire Low Emission Strategy

Page 25: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Public Health

Page 26: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Percentage of Deaths Attributable to PM2.5 (Defra 2012)

Page 27: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Scheme Type Minor Medium Major Threshold Below DfT threshold criteria for

Transport Assessment and Travel Plan (TA/TP)

Meets DfT threshold criteria for Transport Assessment and Travel Plan (TA/TP)

Or where the development is for any B2 or B8 use falling below the major classification .

Medium type developments which also trigger any of the following criteria:

i) Where development requires an EIA

ii) Where development is likely to increase traffic flows by more than 5% on roads with >10,000 AADT or change average vehicle speeds by > 10 kph/likely to cause increased congestion

iii) Where a development requires a Transport Assessment and HGV movements are =/> 10% of total trips

Assessment None (other than for exposure) None (other than for exposure) Air Quality Assessment required including an evaluation of changes in vehicle related emissions

Mitigation Type 1 Types 1 and 2 (Mitigation should be included within Travel Plan)

Types 1,2 and 3

(Mitigation should be included within Travel Plan

Development Classification Table

Page 28: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Where the proposed development falls within the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999.

Where the proposed development falls within the Pollution Prevention and Control (England and Wales) Regulations 2000.

Proposals that could increase the existing traffic flow on roads of > 10,000 AADT by 5% or more or change average speeds by more than 10kph

Proposals that include additional HGV movements more than 10% of total trips.

Proposals that introduce biomass energy/heating plant into the urban environment.

Where significant demolition and construction works are proposed.

Page 29: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Development Type

Assessment Required

Mitigation Compensation

Minor None (other than for exposure)

Type 1 -

Medium None (other than for exposure)

Type 1 and 2 -

Major Full AQ Assessment in line with Council Guidance, including evaluation of emission and concentration changes

Type 1 and 2 Type 3

Mitigation and Compensation

Page 30: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Residential Commercial/Retail Industrial

Provision Rate 1 charging point per unit (house with dedicated parking)

10% of parking spaces (this may be phased with 5% provision initially and a further 5% trigger)

10% of parking spaces (this may be phased with 5% provision initially and a further 5% trigger)

1 charging point per 10 spaces (unallocated parking)

To prepare for increased demand in future years, appropriate cable provision for increased provision should be included in scheme design and development in agreement with the local authority

Where Travel Plans are required, recommended EV re-charging provision should be detailed within them, including future proofing through the provision of cabling ...

Type 1 – EV Recharging Standards

Page 31: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Minor Small Scale Major

Large Scale Major

Appropriate Code of Construction Practice

Best Practice Guidance

Best Practice Guidance

Best Practice Guidance

Diesel exhaust emission controls on Non-Road Mobile Machinery (NRMM - 37 kwh power rating or above) should be required on sensitive sites at the discretion of the local authority

Type 1 – Construction Standards

Page 32: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Mitigation Travel Plan (where required), including mechanisms for discouraging high emission vehicle use and encouraging the uptake of low emission fuels and technologies

Designation of parking spaces for low emission vehicles Differential parking charges depending on vehicle

emissions All commercial vehicles should comply with either

current or previous European Emission Standards from store opening, to be progressively maintained for the lifetime of the development

Fleet operations should provide a strategy for considering and reducing emissions, including possibilities for the take up of low emission fuels and technologies

Use of ultra low emission service vehicles

Type 2 – Standard Mitigation for Scheme Sustainability

Page 33: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Road Transport Emission Increase = ∑ [Estimated trip rate for 5 years X Emission rate per 10 km per vehicle type X Damage costs]

Damage Cost Calculation

Page 34: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Mitigation / Compensation

On-street EV recharging Contribution to low emission vehicle refuelling

infrastructure Car clubs Low emission bus service provision Low emission waste collection services Bike/e-bike hire schemes Contribution to renewable fuel and energy

generation projects Incentives for the take-up of low emission vehicle

technologies and fuels Air Quality Monitoring programmes

Type 3 – Additional Mitigation/Compensation for Scheme Acceptability

Page 35: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Avoidvehicle use

Shiftto sustainable

transport modes

Improveemissions of vehicle parc

Low Emission Travel Plans

Page 36: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Road Transport Emission Increase = ∑ [Estimated trip rate for 5 years X Emission rate per 10 km per vehicle type X Damage costs]

Damage Cost Calculation

Page 37: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Road Transport Emission Increase = ∑ [Estimated trip rate for 5 years X Emission rate per 10 km per vehicle type X Damage costs]

Damage Cost Calculation

Page 38: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Road Transport Emission Increase = ∑ [Estimated trip rate for 5 years X Emission rate per 10 km per vehicle type X Damage costs]

Damage Cost Calculation

Page 39: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

Sensitivities

Central Estimate (1) (2) (2)

NOX £955 £744 £1,085

SOX £1,633 £1,320 £1,856

Ammonia £1,972 £1,538 £2,241

PM Domestic £28,140 £22,033 £31,978

PM Agriculture £9,703 £7,598 £11,027

PM Waste £20,862 £16,335 £23,708

PM Industry £25,229 £19,753 £28,669

PM ESI £2,426 £1,900 £2,757

PM Transport Average £48,517 £37,987 £55,133

PM Transport Central London

£221,726 £173,601 £251,961

PM Transport Inner £228,033 £178,540 £259,129

PM Transport Outer £148,949 £116,621 £169,261

PM Transport Inner Conurbation £117,899 £92,309 £133,975

PM Transport Outer Conurbation £73,261 £57,362 £83,252

PM Transport Urban Big £87,332 £68,377 £99,241

PM Transport Urban Large £70,351 £55,081 £79,944

PM Transport Urban Medium £55,310 £43,305 £62,853

PM Transport Urban Small £34,932 £27,351 £39,696

PM Rural £15,041 £11,776 £17,091

IGCB Damage Costs – Defra (2010)

Page 40: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

http://laqm.defra.gov.uk/review-and-assessment/tools/emissions.html#eft

Emission Factor Toolkit (Defra)

Page 41: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

LES LtdLow Emission Strategies

A Low Emission Strategy for the operations at the site and its associated road transport shall be submittedfor approval in writing by the Local Planning Authority 12 months from implementation of this planning decision notice. The Low Emission Strategy shall include, amongst other matters; i) Assessment of Low Emission Vehicle technology and infrastructure (e.g. Electric Vehicle dedicated parking and charging,

gas refuelling station etc) ii) Assessment of fleet emission specification (e.g. current best practice - this may be current Euro standard vehicles). This should include all vehicles forming part of the operation and accessing the site, such as refuse collection vehicles, bulk transfer vehicles, forklifts, heavy goods vehicles, staff vehicles etc iii) Assessment of Procurement policy (including planned vehicle replacement and suppliers of other goods and services) iv) Measures such as eco-driving (driver training and technological aids to eco-driving), and policies regarding vehicle idling. The Low Emission Strategy shall have targets for emission reduction and timescales, with pollution savings quantified. At the end of each calendar year an implementation plan shall be submitted for approval in writing by the Local Planning Authority, which on approval shall be fully implemented in accordance with the details and measures so approved. The Low Emission Strategy shall take into account future changing standards and available technologies and be updated accordingly in agreement with the Local Planning Authority. Reason: In the interests of improving air quality, reducing green house gases and ensuring that the effects on the environment and occupants of adjoining land is minimised, in accordance with policies UR3, P1, P8 and P11 of the Replacement Unitary Development Plan and paragraphs 30 and 120 of the National Planning Policy Framework.

Bradford Waste PFI – Planning Condition

Page 42: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

Low Emission Strategies:

• Bradford• York• West Midlands• West Yorkshire• Sussex / Horsham• Merseyside • Leicester• Northampton• Southampton• Sheffield• Exeter• Colchester• Scotland

LES LtdLow Emission Strategies

Page 43: West Yorkshire / West Midlands Low Emission Strategy Planning Guidance IAQM, September 25 th 2013 Andrew Whittles Managing Director Low Emission Strategies

Conclusions

• Clarity / certainty – define ‘sustainability’ in AQ terms• Level playing field• Acknowledges cumulative impact / seeks incremental benefit• Core Strategies / AQAP / Low Emission Strategies• Workloads• Damage costs / HMRC Green Book – AQ Supplement• Travel Plans• Section 106 / CIL• Euro Standards / diesel / low emission technology readiness• Public Health / HIA • Innovation / opportunity /precedent• Communication

LES LtdLow Emission Strategies