Purpose of the document

Thank you for forwarding me details of the above Draft Air Quality Supplementary Planning Document received on 5th September 2018.
Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth.
We have reviewed the consultation document provided. Given the distance of the SRN to the locations that it specifies, we can confirm that the plans and policies set out within the Draft Air Quality Supplementary Planning Document are unlikely to have implications for the continued safe operation and functionality of the SRN.
We welcome the opportunity to provide comments to this consultation, and support the sustainable development principles contained within the Air Quality SPD, but have no comments to make on its contents.
Please do not hesitate to contact me if you require any more information or clarification.

Thank you for your consultation on the above dated 5 September 2018, which was received by Natural England on 5 September 2018.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Our remit includes protected sites and landscapes, biodiversity, geodiversity, soils, protected species, landscape character, green infrastructure and access to and enjoyment of nature.
Whilst we welcome this opportunity to give our views, the topic of the Supplementary Planning Document does not appear to relate to our interests to any significant extent. We therefore do not wish to comment.
Should the plan be amended in a way which significantly affects its impact on the natural environment, then, please consult Natural England again.
Strategic Environmental Assessment/Habitats Regulations Assessment
A SPD requires a Strategic Environmental Assessment only in exceptional circumstances as set out in the Planning Practice Guidance here. While SPDs are unlikely to give rise to likely significant effects on European Sites, they should be considered as a plan under the Habitats Regulations in the same way as any other plan or project. If your SPD requires a Strategic Environmental Assessment or Habitats Regulation Assessment, you are required to consult us at certain stages as set out in the Planning Practice Guidance.
Please send all planning consultations electronically to the consultation hub at consultations@naturalengland.org.uk.

I have looked through the supplementary planning document & the Annual Status Report. I am encouraged to see the council is working to address the high pollution levels in our area. I should like to know if an evaluation has been undertaken on the A4177 Birmingham Road by Hatton Park? As I am sure you are aware during the peak travel hours traffic is often stationary or slow moving. I can see the report mentions site W68 Birmingham Road but I couldn't see it in the street maps & I wondered if it was a monitor by the A46?

Summary:
The WDC Proposal sets out the desirable conditions to achieve sustainable development, but the guidance would benefit by being more prescriptive and measurable.
Assessment
P8, para2 - The guidance establishes the principle of Warwick District as an emission reduction area and requires developers to use reasonable endeavours to minimise emissions and, where necessary, offset the impact of development on the environment. This statement would benefit by being specific and measurable.
P8 - Sets out the WDC's objectives, however, objectives need to be measurable, incorporating terms such as: Define, List, Measure, State, etc.
P6 - Sustainable Development, (SD), needs to be defined, it is used in line 3 of para1, p8
P15 - reference to particulates: The underlying feature of vehicle particulates is that they are toxic. As a DEFRA study noted,
There is no known safe level for exposure to particulate matter, it is not appropriate to rely solely on the use of air quality objectives .
The hazard of particulates is of particular relevance to children, hence high levels of traffic adjacent to schools are of significant concern.
P17, 181, AQMAs and Clean Air Zones. Within this context it is worth noting the experience from London. Evidence that Low emission zones, LEZs, work is mixed......Three years after the introduction of the London scheme, there was no evidence of improvement in air quality.
P17, 102 It would be more prescriptive to state, Transport issues must be considered. Likewise, it would be helpful to define what the transport issues are.
P18, 103 Within the context of sustainable development, it would be useful to state the transport modes.
Delivering the policies, specifically:
TR1, p21, Access and choice, p28, Table 4 - Type 2 Mitigation, and p29 Table 5 - Type 3 Mitigation
* Policies to support and deliver walking and cycling need to include measure that will bring about behaviour change, as well as the high standard of physical infrastructure required.

* Behaviour change needs to start at the front door when designing for the provision of attractive options for walking and cycling. Thus, streets within housing developments should be safe and attractive places to walk or cycle, to encourage a shift away from car based travel.
* Car parking should be located away from the house.
* For cycling, secure and accessible undercover cycle storage should be provided close to the house.
* The workplace destination should provide similar storage, plus changing and wash/shower facilities, along with clothes lockers. Such arrangements should be part of a planning condition on new employment centres.
* Residential areas should be connected to places of work, leisure, shopping etc, with a network of good quality cycle routes.
Other information and guidance,
The Copenhagen Reverse Traffic Pyramid
Lynn Sloman - A nationally recognised expert in design and evaluation of sustainable transport investment programmes .
London Cycling Design Standards ,

Rodney King
On behalf of Cycleways

The Town Council has recently considered the above document which is subject to public consultation.

The Council has asked me to respond as follows:-

1) The SPD is welcomed and represents an important document to be used in conjunction with other Planning Policies to achieve an acceptable balance between the need for development and environmental protection.
2) Measures to seek financial compensation through the use of Section 106 Agreements, where mitigation measures cannot be integrated into a planning proposal, are welcomed.
3) The SPD does not indicate a time span or date for review. Given the pace of technological change in terms of both vehicles and societal attitudes, it is suggested that a review is conducted no later than on the fifth anniversary of the SPD adoption.
4) It is pleasing to see a Section (5.56) devoted to "green infrastructure". Whilst there remains some conflicting evidence on the benefits of the green environment to managing air quality, the Town Council firmly endorses the principles within the District Council Green Spaces Strategy and advocates the retention of trees within the sites of future developments wherever possible. Where trees need to be removed there should be compensatory planting elsewhere within the same site.

The air quality in the County of Warwickshire has been documented as having one of the highest levels of
pollution in the country.

Our county is surrounded by M40/M42/M6/M5/M45 and with recent press coverage that there has been an
increase of 2.5 million additional cars on the roads in the last five years, it clearly shows that WDC are truly out of
touch in monitoring the sever high levels of pollution being added to this county, which is totally unsustainable.

Warwickshire has also the highest rate of Asthma diagnosis amongst youngsters in the country.

As a sufferer myself of bronchiectasis which has been the result of living near to the M40 since it was built , clearly shows
that there are many other suffers with respiratory conditions caused by heavy pollution being dispersed in now rural surroundings as well as towns and villages.

Also we would question any information that states pollution levels meet current standards in this district. The current rate of houses being built
Adds further pollution to residents lifestyle. Construction traffic dominates the projects for a year. Residents have to deal with dust and additional
Pollutants in the atmosphere, from cement mixers, running engines and the list is endless.

We would like to ask about the monitors placed on the A4177 and Ugly Bridge road back in July 2017. Which were logged
for just 36 hours?

We would question the ability of getting a true reading when this exercise was conducted in the school holidays and the
Levels of traffic were lower than they would be in normal term time.

Transport quite regularly comes to a grinding halt within the vicinity of Hatton Park, which was the case two weeks ago when traffic was gridlock from Hockley Heath
To Leamington following a major fire on North and southbound of the M40 near Henley in Arden.

Morning traffic from 7.30 - 9 am is at a standstill most days while queuing down the A4177 into Warwick. Residents all around are breathing in obnoxious air pollution from the exhaust fumes.

More houses means more cars means higher pollution, as it will take another two decades to address all cars becoming electric .

The only way to reduce pollution is stop desimating the green belt area.
Trees are being cut down when there should be more Planted to help keep the air cleaner.

I feel very sorry for the next generation who will not thank us for the way in which we have left this planet, by over populating small areas with thousands of houses which equate to more cars on the road.

2.5 million more cars on the road in just 5 years sends out a clear message to WDC in the way they address air pollution for the next 40 years.

For and on Behalf of
TidCom Group
Hatton Park Residents

Thank you for consulting the County Council on this SPD.

The County Council has been engaged and contributed to the development of this SPD. Therefore, we support the SPD.

Pg 8 One of the objectives is: * to provide guidance on the use of planning conditions and Section 106 obligations to improve air quality;
Pg 32 para 5.57 says that our list does not include infrastructure to improve air quality.
This statement needs updating - as there are specific items on the list for 2018/19 eg Bath St Gyratory, Emscote road works, Warwick Town Centre improvement works. There must be other works that are related to air quality also on the list

also on pg 8 Air Quality to be considered as a material planning consideration.
Could I clarify that all future developments within the AQMAs will be required to submit a statement of Air Quality mitigation?

Pg 10 Identifying the AQMA - are there plans for more detailed work to take place in these areas to actively reduce the high level of dangerous particulates?

pg 21 Low Emission Strategy Guidance for Developers (2014). 5 years out of date - will that be updated?


General comments:
How can this SPD be used to protect mature trees in developments? E.g pg 32. 5.56 What about a statement to encourage retention of mature trees? These can also assist with general air quality.
Car share should be promoted more and encouraged
Cycling infrastructure such as covered cycle racks should be essential in commercial /employment land as well as housing developments.
Are bike share schemes to be considered also?
Yesterday (16th Oct 2018) WCC announced a commitment to connectivity between towns as part of cycle networks. Given this is a County wide SPD - how can we strengthen this to ensure we meet those aims?

Introduction
The FSB is the UK's leading business organisation and across Warwickshire, Coventry and Solihull 96.6% of the 50,000 private sector businesses are small - employing less than 50 employees. The FSB in Warwickshire and Coventry is grateful for the opportunity to comment on Warwick District Council Air Quality and Planning Supplementary Planning Document
The FSB understands air quality has become a much high priority area for UK Government and the consultation document aims to assist in reducing air quality impacts of development.
Our response focuses on a number of key principles that should be considered by Local Authorities in relation to small businesses when developing measures to tackle air pollution.
Supporting small businesses in tackling air pollution
* The FSB understands that improving our air quality in urban areas, is a complex issue and requires the joint action of Government and local authorities. One of the most significant challenges is the build-up of nitrogen dioxide concentrations around some local roads.
In response to this policy development the FSB released its report 'Clearing the Air: Supporting small businesses in tackling air quality in England (November 2017). The report is designed to help Government and local authorities to understand the diverse small business audience in relation to development of policies designed to tackle air pollution. The report is available here and we have highlighted some of the main recommendations in our response.
* Engagement with the small business community is key when developing guidance and we are therefore grateful for the opportunity to respond to this consultation on planning guidance and the designation of five air quality management areas.

* Despite widespread concern about the issue, it is important to note that air quality is improving nationally. By 2022 only 10 local authorities in England are forecast to still be in breach of air quality limits, even without the addition of new remedies. In the consultation guidance it states that air quality management areas established do not breach Air Quality Objectives.

However it is acknowledged that fine particulate matter levels have a significant impact on health across the district and reductions will still bring health benefits to the local population. As a result we would welcome regular assessment of measures to determine whether proposed mitigation measures are proportion or whether additional measures need to be included.

* The document proposes a number of mitigation measures for minor, medium and high new developments against the threshold criteria. These must be fair and transparent allowing those in the areas affected to adapt to and take advantage of any new requirements. The impact on small businesses operating in the designated areas and those travelling into the areas and impacted by any new developments should be considered when determining mitigation measures. The FSB believes that WDC in planning requirements should ensure that important and small business trades and services are not being deterred from the designated areas and town centres.

* The mitigation measures for major new developments include the establishment of Clean Air Zones. Where these are proposed as part of the planning requirements the FSB believe there should be further engagement and to ensure that small businesses are fully account for as part of the development process. Businesses must be given further fair opportunity to input and comment on proposals.

* Any supplementary planning documents and guidance resulting from this consultation should be implemented and followed fairly and transparently by planning officers so that a consistent and proportionate approach is taken to any new development.