Air Quality SPD

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Comment

Air Quality SPD

Purpose of the document

Representation ID: 71213

Received: 12/10/2018

Respondent: Cycleways

Representation Summary:

The WDC Proposal sets out the desirable conditions to achieve sustainable development, but the guidance would benefit by being more prescriptive and measurable.

Full text:


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

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