PM2.5 Targets: Interim Planning Guidance
Interim Planning Guidance on the consideration of the Environment Act PM2.5 targets in planning decisions
The Environmental Targets (Fine Particulate Matter) (England) Regulations 2023 set two new targets for fine particulate matter (PM2.5):
- A maximum annual mean concentration target of 10µg/m3 to be achieved by 2040 (the AMCT); and
- A population exposure reduction target of 35% compared to 2018 to be achieved by 2040 (the PERT).
Defra is developing guidance for applicants and Planning Authorities in England to demonstrate that they have appropriately considered the PM2.5 targets when making planning applications and planning decisions.
The purpose of the targets is to improve air quality by reducing levels of PM2.5 across the country, therefore improving public health. While achievement of the targets will be assessed at relevant monitoring sites, the targets apply to ambient (outdoor) air throughout England. Applicants and Local Planning Authorities should therefore consider the impact of developments on air quality in all ambient air, whether a monitor is present or not.
These targets require a different approach to that used by applicants and Local Authorities in response to existing air quality legislation.
The new approach moves away from a requirement to assess solely whether a scheme is likely to lead to an exceedance of a legal limit and instead ensures that appropriate mitigation measures are implemented from the design stage, streamlining the process for planning and ensuring the minimum amount of pollution is emitted and that exposure is minimised.
Pending publication of the new guidance, applicants are advised to provide evidence in their planning applications that they have identified key sources of air pollution within their schemes and taken appropriate action to minimise emissions of PM2.5 and its precursors as far as is reasonably practicable. If quantitative evidence is not available, a qualitative approach can be taken. This applies to all developments which would normally require an air quality assessment. More detailed assessments are expected for developments which are closer to populations, and those which are likely to have higher emissions. This guidance is separate to how PM2.5 should be considered within environmental permitting.
The following questions are designed to be used as prompts to support the interim process, but applicants are welcome to consider measures in addition to those listed below:
1. How has exposure to PM2.5 been considered when selecting the development site?
Applicants are advised to consider the following in their application:
- Site proximity to people (particularly large populations and/or vulnerable groups, e.g. schools, hospitals, care homes, areas of deprivation) and the impact of the development on these,
- Site proximity to pollution sources and the impact of these on users of the development,
- Exposure and emissions during both construction and in-use.
2. What actions and/or mitigations have been considered to reduce PM2.5 exposure for development users and nearby receptors (houses, hospitals, schools etc.) and to reduce emissions of PM2.5 and its precursors?
Applicants are advised to explain (with evidence where possible) why each measure was implemented. Or, if no mitigation measures have been implemented, why this was not proposed. Actions can refer to, but are not limited to, the following:
- Site layout,
- The development’s design,
- Technology used in the construction or installed for use in the development,
- Construction and future use of the development.
Planning Authorities are encouraged to consider the cumulative impact of development both in developing their Local Plan and when making decisions on a case-by-case basis. Whilst contributions from individual developments may be small, cumulatively they can lead to an increase in regional exposure, and so will have public health impacts and affect progress towards the targets.