Comment

Representation ID: 19871

Received: 01/04/2021

Respondent: Natural England

We welcome the approach set out within Policy EN8 to tackling air pollution and improving air quality throughout the District, particularly the recognition of the important part which can be played be green infrastructure in absorbing pollutants.

The Draft Local Plan should acknowledge that new agricultural development (e.g. intensive pig and poultry) may also pose risk to air quality.

Please see Annex 1 extract below for further guidance regarding how the Draft Local Plan could address the impacts of air quality on the natural environment.

Air pollution
We would expect the plan to address the impacts of air quality on the natural environment. It should address the traffic impacts associated with new development, particularly where this impacts on European sites and SSSIs. The environmental assessment of the plan (SA and HRA) should also consider any detrimental impacts on the natural environment, and suggest appropriate avoidance or mitigation measures where applicable.

Natural England advises that one of the main issues which should be considered in the plan and the SA/HRA are proposals which are likely to generate additional nitrogen emissions as a result of increased traffic generation, which can be damaging to the natural environment.

The effects on local roads in the vicinity of any proposed development on nearby designated nature conservation sites (including increased traffic, construction of new roads, and upgrading of existing roads), and the impacts on vulnerable sites from air quality effects on the wider road network in the area (a greater distance away from the development) can be assessed using traffic projections and the 200m distance criterion followed by local Air Quality modelling where required. We consider that the designated sites at risk from local impacts are those within 200m of a road with increased traffic, which feature habitats that are vulnerable to nitrogen deposition/acidification. APIS provides a searchable database and information on pollutants and their impacts on habitats and species.