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

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The dispersion software used to model future concentrations assume large<br />

reductions in emissions in future years associated with cleaner vehicles – so even<br />

with a large increase in vehicle numbers developers can still report an improvement<br />

in air quality.<br />

Developers do not take into account <strong>the</strong> cumulative impacts of o<strong>the</strong>r proposed (or<br />

already permitted) developments <strong>for</strong> <strong>the</strong> area.<br />

As <strong>the</strong>re is no official national guidance on determining <strong>the</strong> significance of air quality<br />

impacts, describing significance remains an issue of contention. For instance,<br />

developers can interpret increases in concentrations of up to 0.4 µg/m 3 as<br />

imperceptible or negligible following Development Control: <strong>Plan</strong>ning For Air Quality<br />

(2010 Update).<br />

9.107 As it is assumed that every development will add to overall air emissions, be it emissions from<br />

buildings or additional traffic, it is proposed that every new development meeting <strong>the</strong> CIL’s<br />

definition of a dwelling is required to contribute towards <strong>the</strong> cost of tackling poor air quality.<br />

These financial contributions secured through Community Infrastructure Levy (CIL) would be<br />

<strong>the</strong>n spent on offsetting measures (as listed in Appendix 15).<br />

9.108 In addition, to minimise site‐specific direct emissions from new developments and reduce<br />

exposure of new residents to poor air quality, developers will be required to implement<br />

redesign and mitigation measures according to <strong>the</strong> magnitude of impacts and existing<br />

pollutant concentrations at <strong>the</strong> development site. The assumed scale of impact was related to<br />

<strong>the</strong> predicted increase in car numbers and based on <strong>the</strong> study of available guidance<br />

documents – listed in Table 2 of Appendix 15.<br />

9.109 Small development of up to 10 units to be located at sites where air pollutant levels are close<br />

to or exceeding objectives can be required to make improvements to <strong>the</strong> development design<br />

and layout (redesign measures in Appendix 15), <strong>for</strong> example, ensure that at busy roads<br />

appropriate distance is maintained between <strong>the</strong> building and <strong>the</strong> road; place sensitive uses<br />

(bedrooms, children play areas) in <strong>the</strong> least polluted parts of <strong>the</strong> site; limit car parking spaces;<br />

provide cycling facilities (e.g. shelters) and look into improving building insulation (above<br />

current regulations) and/or increasing <strong>the</strong> proportion of energy generated from renewable<br />

sources (above current regulations). Small developments in background locations where<br />

current air pollution levels remain well below objectives can still be required to look into<br />

design improvements and, <strong>for</strong> example, provide shelters <strong>for</strong> bicycles and improve building<br />

<strong>the</strong>rmo efficiency. These design improvements will be secured through planning conditions.<br />

9.110 The direct impact of slightly larger developments of 11‐50 units is also considered to be low;<br />

however, if located at sites of relatively poor air quality, <strong>the</strong>y may be required to make<br />

changes to design and layout (similar to small developments). They could also use some of<br />

<strong>the</strong> mitigation measures in Appendix 15 to encourage sustainable modes of transport, <strong>for</strong><br />

example, by providing new residents with in<strong>for</strong>mation of public transport, routes/times and<br />

walking and cycling routes. Mitigation measures will be secured through planning obligations.<br />

9.111 It is assumed that developments of 50‐100 units will have <strong>the</strong> potential <strong>for</strong> a low to medium<br />

impact on air quality, depending on <strong>the</strong> existing pollutant concentrations in <strong>the</strong> area. It is<br />

suggested that higher adverse impact of <strong>the</strong>se development is managed by a broader range<br />

of redesign and mitigation measures. In addition to <strong>the</strong> measures described above <strong>for</strong> smaller<br />

developments, <strong>the</strong> measures to be applied by larger developments could, <strong>for</strong> example,<br />

include reduced parking provision and /or preference given to low emission / car club<br />

vehicles and improvements to traffic management or road layout at <strong>the</strong> development site.<br />

9.112 Unless proven o<strong>the</strong>rwise, potentially significant adverse air quality impacts of developments<br />

of a size above 100 units will be presumed. Developers will be required to use a broad range<br />

of redesign and mitigation measures. Redesign measures to be considered by large<br />

developments include walking and cycling routes/facilities; provision of facilities <strong>for</strong> public<br />

transport, such as bus stops and lay‐bys, communal combined heat and power and improved<br />

building insulation (above current regulations). Part L of <strong>the</strong> Building Regulations identifies<br />

<strong>the</strong> legal minimum a development needs to meet in terms of energy efficiency in <strong>the</strong> UK. The<br />

Council could introduce more stringent demands <strong>for</strong> larger developments. In addition, a<br />

Page | 137 Runnymede BC FINAL <strong>Sustainability</strong> <strong>Appraisal</strong> <strong>Report</strong> – Feb 2013

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