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RTPI response to the draft UK Air Quality Plan

The RTPI welcomes the opportunity to provide evidence to the Joint Air Quality Unit consultation on the draft UK Air Quality Plan for tackling nitrogen dioxide. The draft plan is clear on the serious public health impacts from poor and often illegal levels of air pollution in towns and cities. The 2016 High Court ruling requires the government to produce an Air Quality Plan to achieve legal compliance ‘by the soonest date possible’. This response considers both short-term measures to achieve compliance and the long-term role of planning in creating the conditions for improved air quality.

The high levels vehicle-based air pollution experienced in many urban areas results in part from a legacy of low density, car-dependent urban expansion on the fringes of towns and cities over previous decades. The plan says little on the critical relationship between urban form, infrastructure and air quality, or the contribution of planning to improving air quality. This is despite considerable evidence on the impact that decisions on urban form has on public health, social inclusion and air quality. The planning system in each UK Nation contains key levers to improve air quality.

In England, this includes the development management (DM) process, which helps to mitigate air pollution in the short-term, and the Local Plan-making process, which helps ensure that new development does not create negative impacts over the long term. The National Planning Policy Framework (NPPF) also contains a number of policies related to air quality; however, its increased focus on the speed of delivery and returns to land owners/developers can favour dispersed patterns of development in unsustainable locations.

The 2015 “Cleaner Air for Scotland Strategy” is much clearer on the role that planning should play in shaping sustainable settlement patterns, reducing car dependency and promoting travel by public and active modes. The draft UK Air Quality Plan should contain a similar emphasis on the role of effective Local Plan policies.

The Air Quality plan should promote a more integrated approach to transport and land use planning in order to tackle air pollution over the long-term. It should ensure that local authorities and Combined Authorities have the resources and technical capacity to develop integrated spatial maps of land use, transport infrastructure and air quality. Central government should provide policies for clean air (including Clean Air Zones) and strong and targeted investment in sustainable public and active transport infrastructure.

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