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DRAFT Sustainability Appraisal Report for the Emerging Local Plan ...

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equirement <strong>for</strong> 10% of energy <strong>for</strong> all new developments to come from renewable sources,<br />

however <strong>the</strong> Note has not been <strong>the</strong> subject of public consultation) and <strong>the</strong> measures<br />

proposed in <strong>the</strong> draft 2012 Air Quality <strong>Plan</strong> (AQAP) cannot be implemented without<br />

substantial funds. It is <strong>the</strong>re<strong>for</strong>e recommended that <strong>the</strong> mitigation strategy proposed in this<br />

section is introduced as a Supplementary <strong>Plan</strong>ning Document (SPD) addressing both air<br />

pollution and greenhouse gas emissions. The aim of <strong>the</strong> SPD would be to provide guidance on<br />

air quality and climate changes mitigation measures required to ensure <strong>the</strong> sustainability of<br />

<strong>the</strong> new development as proposed in <strong>the</strong> policies of <strong>the</strong> emerging <strong>Local</strong> <strong>Plan</strong>. The air quality<br />

measures that <strong>the</strong> Council intends to take are already set out in <strong>the</strong> draft 2012 AQAP. The<br />

SPD would take account of <strong>the</strong> issue of cumulative effects and interactions and possible<br />

trade‐offs between climate change and air pollution mitigation measures.<br />

Air Pollution / Carbon Reduction Strategy<br />

9.103 Appropriate mitigation can ensure<br />

that adverse impacts of<br />

developments are avoided,<br />

minimised or offset, in line with <strong>the</strong><br />

National <strong>Plan</strong>ning Policy Framework:<br />

“<strong>Local</strong> planning authorities should<br />

seek opportunities to achieve each of<br />

<strong>the</strong> economic, social and<br />

environmental dimensions of<br />

sustainable development, and net<br />

gains across all three. Significant<br />

adverse impacts on any of <strong>the</strong>se<br />

dimensions should be avoided and,<br />

wherever possible, alternative<br />

options which reduce or eliminate<br />

such impacts should be pursued.<br />

Where adverse impacts are<br />

Figure 12 ‐ Hierarchy of methods <strong>for</strong> addressing air<br />

pollution<br />

unavoidable, measures to mitigate <strong>the</strong> impact should be considered. Where adequate<br />

mitigation measures are not possible, compensatory measures may be appropriate” (s. 152 of<br />

<strong>the</strong> NPPF).<br />

9.104 The hierarchy of methods <strong>for</strong> addressing air quality and greenhouse gas emission issues is<br />

shown in Figure 12. Any adverse impacts should be avoided in <strong>the</strong> first place. This means that,<br />

<strong>for</strong> instance, locations where current air pollution levels are high should be avoided. If<br />

alternative sites cannot be identified, <strong>the</strong> development design, layout and location should be<br />

looked at in terms of potential reductions in air quality impacts and greenhouse gas<br />

emissions. If redesign measures are not sufficient to fully reduce <strong>the</strong> impacts to an acceptable<br />

level <strong>the</strong>n mitigation can be used to ei<strong>the</strong>r protect sensitive receptors (from existing or future<br />

pollutant concentrations) or reduce total air pollutant / greenhouse gas emissions from <strong>the</strong><br />

proposed development. As it is assumed that every development will add to overall air<br />

emissions and, in some cases, introduce new exposure to an area of poor air quality,<br />

offsetting measures will provide money <strong>for</strong> schemes that improve overall air quality.<br />

9.105 Specific measures should be suited to development’s scale, predicted magnitude of air quality<br />

impacts and existing pollutant concentrations. A generic (non‐exhaustive) list of mitigation<br />

and offsetting measures, grouped into categories, has been compiled from available guidance<br />

documents (Appendix 15). This list should be read alongside its Table 1 where <strong>the</strong> type of<br />

measures was assigned to developments according to <strong>the</strong>ir size/predicted impact and existing<br />

pollutant concentrations.<br />

9.106 Under <strong>the</strong> current system only <strong>the</strong> largest developments or developments within or adjacent<br />

to an AQMA are required to go through an Air Quality Assessment. However, even in <strong>the</strong> case<br />

of large developments located in areas poor air quality, <strong>the</strong> predicted changes in nitrogen<br />

dioxide / particulate matter concentrations modelled by <strong>the</strong> developer continue to show<br />

negligible or insignificant impacts. The following are possible reasons <strong>for</strong> this.<br />

Page | 136 Runnymede BC FINAL <strong>Sustainability</strong> <strong>Appraisal</strong> <strong>Report</strong> – Feb 2013

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