LES Ltd
Low Emission Strategies
West Yorkshire / West Midlands
Low Emission Strategy Planning
Guidance
IAQM, September 25th 2013
Andrew Whittles
Managing Director
Low Emission Strategies Ltd
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Low Emission Strategies
Contents
• Evolution
• Guidance
• National Planning Policy Framework
• West Yorkshire / West Midlands LES Guidance
• Conclusions
Exposure
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Blackheath Road, Greenwich
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“Greenwich hope to improve air quality
by piping clean air in from Bexley”
AQB, 2001
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Greenwich Peninsula LEZ
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Greenwich Millenium Village
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Greenwich Peninsula
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Lower Lea Valley Olympic Site
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London Guidance
Low Emission Strategies
Applicable Range
Nitrogen Dioxide
Annual Mean
> 5% below national objective
Applicable Range
PM10
Recommendation
Annual Mean:
> 5% below national objective
24 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
objective
24 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 objective
24 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.
APEC – A
London Councils, 2007
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Thames Gateway Bridge Design
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Emirates Cable Car
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Tesco, Woolwich 2013
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Low Emission Strategies
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Mitigation Measures
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
Development Type Applicability
Residential Commercial Industrial
Notes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
1
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
4
See Table – Low Emission Technologies: Applicability and Availability
Denotes Non-Road Mobile Machinery
3
See London Code: Reducing Emissions from Construction &
Demolition Sites (Greater London Authority)
2
Where charge is levied on off-street parking
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
5
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National Planning Policy Framework
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Planning policies should sustain compliance with and
contribute towards EU limit values or
national objectives for pollutants, taking into account the
presence of Air Quality
Management Areas and the cumulative impacts on air
quality from individual sites in local
areas. Planning decisions should ensure that any new
development in Air Quality
Management Areas is consistent with the local air quality
action plan
(Paragraph 124)
NPPF....
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Planning policies should sustain compliance with and
contribute towards EU limit values or
national objectives for pollutants, taking into account the
presence of Air Quality
Management Areas and the cumulative impacts on air
quality from individual sites in local
areas. Planning decisions should ensure that any new
development in Air Quality
Management Areas is consistent with the local air quality
action plan or low emission strategy
(Paragraph 124) (DCLG website 2013)
NPPF...
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Plans should protect and exploit opportunities for the
use of sustainable transport modes for
the movement of goods or people. Therefore,
developments should be located and designed
where practical to:
- incorporate facilities for charging plug-in and other
ultra-low emission vehicles; and
consider the needs of people with disabilities by all
modes of transport
(Paragraph 35)
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NPPF...
If setting local parking standards for residential and nonresidential development, local
planning authorities should take into account:
-an overall need to reduce the use of high-emission
vehicles
(Paragraph 39)
Bradford Low Emission Strategy - Foreword
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“The existence of a black pall of smoke over the town is quite unnecessary to the
trade of Bradford…the existence of the unnatural and unhealthy condition of the
atmosphere is highly prejudicial.....” said Dr. Thomas W Hime, Medical Officer of
Health for Bradford, in his annual report to the Council in 1884.
At Bradford Council we have long recognised that clean air is fundamental for the
district to prosper, and be an attractive place to live, work and invest. The adoption
of our Air Quality Strategy in April 2011 continued the council’s commitment to
protect the health of its residents.
Transport is now the major contributor to our air quality problems. This Low Emission
Strategy outlines how the council will work with the public and the private sector, and
with other stakeholders, to implement measures which reduce the impact of
emissions from traffic on public health and air quality, whilst simultaneously
contributing to the regeneration of our economy.
Cllr Andrew Thornton: Portfolio holder for Environment, Sport &
Sustainability
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West Yorkshire Low Emission Strategy
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Public Health
Low Emission Strategies
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Percentage of Deaths Attributable to PM2.5 (Defra 2012)
Development Classification Table
Scheme Type
Threshold
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Minor
Medium
Major
Below DfT threshold criteria for Meets DfT threshold criteria for Medium type developments
Transport Assessment and
Transport Assessment and
which also trigger any of the
Travel Plan (TA/TP)
Travel Plan (TA/TP)
following criteria:
Or where the development is
for any B2 or B8 use falling
below the major classification .
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
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 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.
Mitigation and Compensation
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Development
Type
Assessment
Required
Compensation
Minor
None (other than Type 1
for exposure)
-
Medium
None (other than Type 1 and 2
for exposure)
-
Major
Full AQ
Assessment in
line with Council
Guidance,
including
evaluation of
emission and
concentration
changes
Type 3
Mitigation
Type 1 and 2
Low Emission Strategies
Type 1 – EV Recharging Standards
Provision Rate
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Residential
Commercial/Retail
Industrial
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 ...
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Type 1 – Construction Standards
Minor
Appropriate
Code of
Construction
Practice
Best Practice
Guidance
Small Scale
Major
Best Practice
Guidance
Low Emission Strategies
Large Scale
Major
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
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Type 2 – Standard Mitigation for Scheme Sustainability
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
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Damage Cost Calculation
Road Transport Emission Increase =
∑ [Estimated trip rate for 5 years X Emission rate per
10 km per vehicle type X Damage costs]
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Type 3 – Additional Mitigation/Compensation for Scheme Acceptability
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
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Low Emission Travel Plans
Avoid
vehicle use
Shift
Improve
to sustainable
transport modes
emissions of
vehicle parc
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Damage Cost Calculation
Road Transport Emission Increase =
∑ [Estimated trip rate for 5 years X Emission rate
per 10 km per vehicle type X Damage costs]
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Low Emission Strategies
Damage Cost Calculation
Road Transport Emission Increase =
∑ [Estimated trip rate for 5 years X Emission rate
per 10 km per vehicle type X Damage costs]
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Low Emission Strategies
Damage Cost Calculation
Road Transport Emission Increase =
∑ [Estimated trip rate for 5 years X Emission rate per
10 km per vehicle type X Damage costs]
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IGCB Damage Costs – Defra (2010)
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
£28,140
£22,033
£31,978
£9,703
£7,598
£11,027
PM Waste
£20,862
£16,335
£23,708
PM Industry
£25,229
£19,753
£28,669
£2,426
£1,900
£2,757
PM Transport Average
£48,517
£37,987
£55,133
PM Transport Central
London
PM Transport Inner
£221,726
£173,601
£251,961
£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
PM Domestic
PM Agriculture
PM ESI
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Emission Factor Toolkit (Defra)
http://laqm.defra.gov.uk/review-and-assessment/tools/emissions.html#eft
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Ltd
Bradford Waste PFI – Planning Condition
Low Emission Strategies
A Low Emission Strategy for the operations at the site and its associated road transport shall be submitted
for 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.
Low Emission Strategies:
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• Bradford
• York
• West Midlands
• West Yorkshire
• Sussex / Horsham
• Merseyside
• Leicester
• Northampton
• Southampton
• Sheffield
• Exeter
• Colchester
• Scotland
Conclusions
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• 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
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Thank you!
andrew@whittles.demon.co.uk
sally.jones@bradford.gov.uk
popplewellv@walsall.gov.uk
sdouglas@wakefield.gov.uk
nigel.jenkins@lewes.gov.uk