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Environment Act Particulate Matter targets: Interim planning guidance
The Department for Environment, Food and Rural Affairs (Defra) has recently published interim planning guidance related to the Environment Act Particle Matter (PM2.5) targets.
Overview
The Department for Environment, Food and Rural Affairs (Defra) has recently published interim planning guidance related to the Environment Act Particle Matter (PM2.5 ) targets.
While this guidance is distinct from how PM2.5 emissions should be considered in environmental permitting, it is important for the planning regime across England. Dr. Steven Lees outlines how developers can ensure that new projects align with the requirements of this latest air quality planning guidance.
About Steven
Dr. Steven Lees
Associate Air Quality Consultant
Steven recently joined the RPS Environment Management team as an Associate Air Quality Consultant based in Manchester. With over 14 years of experience in air quality, he earned a PhD researching the effects of air pollution on designated habitat sites at the University of Sheffield before embarking on a career in environmental consultancy.
He has worked on projects from inception to completion across various sectors, including residential, commercial, agricultural, industrial, and power. His project experience includes sensitive inner-city developments (such as residential buildings and schools), large-scale manufacturing and production facilities, peaking plants, data centres, and offshore wind farms.
Throughout his career, Steven has collaborated with regulators, developers, legal specialists, and other consultants (including transport, planning, and ecology specialists). He is a member of the Institute of Air Quality Management and the Institution of Environmental Sciences.
What is Particulate Matter?
PM2.5 consists of fine particulate matter, including construction dust, combustion particles, organic compounds, and metal fragments, with a diameter of 2.5 µm or less. Common sources of PM2.5 include vehicle emissions, industrial processes, combustion sources, and construction sites. Exposure to PM2.5 can lead to or exacerbate respiratory issues and cardiovascular diseases.
What are the targets?
The Air Quality Standards Regulations (2010) set a limit value of 20 µg/m³, expressed as an annual average, for PM2.5.
However, the Environmental Targets (Fine Particulate Matter) (England) Regulations 2023 establish two new targets for PM2.5 to be achieved by 2040:
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A maximum annual mean concentration target of 10 µg/m³; and
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A population exposure reduction target of 35% compared to 2018.
What is the purpose of the updated guidance?
The purpose of these targets is to improve air quality by reducing PM2.5 levels nationwide, thereby helping to safeguard public health. While the achievement of these targets will be assessed at relevant monitoring sites, they apply to ambient (outdoor) air throughout England. Applicants and Local Planning Authorities must consider the impact of developments on air quality in all ambient air, regardless of whether a monitor is present.
These targets necessitate a shift in approach for applicants and Local Authorities, moving away from merely assessing whether a scheme might exceed a legal limit. Instead, they emphasise the implementation of appropriate mitigation measures from the design stage, streamlining the planning process and minimising pollution emissions while reducing exposure.
When does the new guidance apply and what needs to be considered?
The interim guidance applies to future developments that have the potential to emit or are sensitive to PM2.5. It does not apply to planning decisions for applications submitted before 4 October 2024.
The guidance emphasises the importance of implementing appropriate mitigation measures during the design stage of new developments to minimise both PM2.5 emissions and exposure, rather than solely assessing the likelihood of exceeding the limit value.
Applicants must provide evidence in their planning applications that they have identified key sources of PM 2.5 within their schemes and taken reasonable actions to minimise emissions of PM 2.5 and its precursors.
How can a new development consider Particulate Matter at the design stage?
Exposure to PM2.5 is particularly critical for highly sensitive uses, such as residential, educational, childcare, and healthcare facilities. Developers should consider the location of polluting development sites in relation to existing sensitive receptors, as well as the placement of sensitive uses within the new development site concerning nearby PM2.5 sources.
Questions for consideration:
Is the new development a potential source of PM2.5 during construction and/or operation?
If so:
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Can the new development site be located away from existing sensitive receptors, such as large residential communities, schools, hospitals, and care homes?
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Can potential new sources of PM2.5 within the new development site be positioned as far away as possible from neighbouring sensitive receptors?
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Can mitigation measures be implemented within the new development to reduce or eliminate PM2.5 emissions?
Is the new development sensitive to exposure to PM2.5?
If so:
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Can the new development site be situated away from local sources of PM2.5?
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Can the proposed sensitive uses be located as far away as possible from neighbouring sources of PM2.5?
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Can mitigation measures be implemented within the new development to reduce or eliminate exposure to PM2.5?
How can we help?
This article serves as a starting point for developers to consider Defra’s new interim planning guidance regarding the Environment Act PM2.5 targets. The key to identifying ways to reduce exposure to and emissions of PM2.5 lies in collaboration with essential project team members, such as air quality consultants, transport consultants, architects, and energy and sustainability experts.
Our experts have conducted Air Quality Assessments for numerous new developments over the past few years, covering various use classes and routinely addressing PM2.5 emissions and exposure. We also have extensive experience collaborating with project teams to provide site-specific air quality measures and advice to mitigate emissions and exposure.
For more information on Defra’s interim guidance or to speak with an RPS expert, please contact Dr. Steven Lees or Kathryn Barker.
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