The Planning Policy Manager introduced the report.  She explained that the air quality modelling for the Swale Local Plan Review had been carried out by Sweco’s Air Quality Technical Team.  The Planning Policy Manager explained that air quality was a key element of evidence required for the Local Plan Review and was also a significant concern to local communities and the Council.  She advised that the evidence had been prepared in close working with Swale Council environmental health colleagues and the full draft was set-out at Appendix I to the report. 

The Planning Policy Manager explained that the study had looked at two main scenarios of growth to 2037: 776 dwellings per annum plus employment sites to 2037; and 1054 dwellings per annum plus employment sites to 2037.  She reported that levels of NO₂ were forecast to reduce between 2017 (base year for the study) and 2027 and again by 2037.  This was based on the assumption that emissions would fall as newer vehicles were introduced.  The two scenarios tested did show that emissions would increase slightly, but overall would remain well below exceedance levels.   The modelling also showed that there were no exceedances of PM₁₀.

The Planning Policy Manager stated that Jen Simpson (Sweco) was also in attendance to respond to any questions.

Members were invited to ask questions and make comments.

Some Members were concerned that there was no reference to PM_2.5 levels within the report.   Ms Simpson explained that the Council’s Air Quality specialist had advised that PM_2.5 was not an issue in Swale, and therefore it was considered PM_2.5 levels should not be included within the report. Ms Simpson added that PM_2.5 was difficult to measure and PM₁₀ was used as a surrogate to gauge whether PM_2.5 was likely to be an issue.

A Member asked for clarification in respect of how the employment square footage had been agreed with regard to the two growth scenarios and was unsure how, given the proposed increases in housing that traffic flows would reduce?  Ms Simpson agreed to liaise with Sweco’s Transport section about the figures.  The Planning Policy Manager also agreed to forward employment density figures for the various B class uses. 

A Member queried whether the modelling was over- or under-predicting?  Ms Simpson explained that there was some under-prediction within the modelling.

A Member considered that more information was needed within the report regarding other pollutant sources, and raised concern about the increased number of windfall sites and that the impact they had on air quality had not been considered.  The Member also queried how the Council could assess air quality where it was not known where development would be.  He felt that the proposed housing would have a big impact on air quality and asked whether industry had been included in the modelling?  

Ms Simpson stated that background air quality data had been provided by DEFRA and this data included all other emission sources, including industry.  The Head of Planning Services stated that the modelling had taken into account windfall figures through background levels.  Planning applicants needed to undertake furthermore detailed modelling to demonstrate that the proposals combined with other developments would not give rise to any exceedances.  

The Planning Policy Manager stated that the evidence needed to be carried out at a high level to assist with the broad development strategy. Ms Simpson explained that the modelling was based on the transport model and the zonal assumptions of what sites were included for the high-level assessment.  The options assessed were very much the worse case scenario and no significant impact on air quality had been identified. 

The Head of Planning Services stated that the Sweco modelling was strategic based for Local Plan forecasting and was based on DEFRA guidelines.  The Council’s Air Quality Action Areas and Air Quality Action Plan would require more detail and possible mitigations for consideration at the planning application stage. 

A Member asked whether road closures had been considered as part of the assessment as this would have had an impact on the figures. 

The Head of Planning Services reported that traffic counts were based on traffic modelling and the consultants would have considered any road closures that might have taken place and the counts would have been tested and validated. 

A Member, who was also the Cabinet Member for Environment, stated that some areas of the Borough which had the worst emission rates were not included, whilst other areas which did not have high emission rates were.  He also raised concern that within Appendix D of the modelling report only 4 or 5 receptor areas were listed, but he was aware that there were more.  He asked whether a modal shift was expected, and what assumptions had been made and what if those assumptions could not be met?   He also asked how much had the air quality team been involved  and whether the World Health Organisation (WHO) air pollution levels could be included? 

Ms Simpson explained that traffic modelling had not been carried out for 2019 so there were limitations, the modelling for that year was based on growth from 2017. The approach assumed the national growth factor between 2017 and 2019, and that all roads grew by the same amount.  Ms Simpson further explained that this method did not take account of new developments which might have taken place between 2017 and 2019 and might have resulted in a redistribution of traffic flows.  Ms Simpson stated that the Council’s Air Quality Project Officer had been heavily involved in the scope of the assessment and the content of the report.  With regard to the WHO guidance, Ms Simpson stated that legally they were required to use the UK air quality regulations. 

The Head of Planning Services reported that transport modelling did include assumptions based on mitigations and included trip rate calculations.  The Local Transport Plan would need to ensure that any mitigations proposed would support the assumed trip rates.  He confirmed that the Council’s environmental health team had been leading on the report with the consultants. 

The Planning Policy Manager stated that the evidence had to be proportionate and that for this stage the evidence needed to be high level, with opportunities later in the process for when more detailed proposals were identified, to seek additional information where required.   

A Member asked why the report was being rushed through?  He did not consider the WHO data could be included as it would just be thrown out by developers as it was not evidence based.

The Planning Policy Manager explained that the Local Plan Review timetable had been agreed as set out in the Local Development Scheme which the Local Plan Panel had agreed at their meeting in March 2020.  She added that she had been looking to extend it, before the Government published proposed changes to the current planning system.  The Planning Policy Manager further explained that those changes to the planning system and new standard method for calculating housing need would result in significant consequences for the Borough in terms of housing number uplift.  She stated that for those reasons, it was important to continue with the reports as scheduled. 

The Vice-Chairman in-the-Chair said that the report was clearly high level and that members of the Panel needed to be pragmatic and realistic on timeframes.  She asked officers to forward responses to questions raised to Panel Members. 

Councillor Benjamin A Martin moved the following amendment to recommendation (2):  Subject to clarification over the potential employment positions.  This was seconded by Councillor James Hunt.  On being put to the vote the amendment was agreed.

The Vice-Chairman in-the-Chair thanked officers and Ms Simpson for attending the meeting.

Recommended:

(1)      That the content of the draft Air Quality Modelling Report and Technical Note be noted.

(2)       That the draft Air Quality Modelling Report be finalised and published and used as part of the evidence base for the Local Plan Review subject to clarification over the potential employment positions.