Low Emissions SPD - Practical Guidance for Applicants and Agents

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The Low Emissions SPD (adopted November 2021) aims to improve air quality across Ipswich through new development. This will be achieved, where possible, through preventing new emission sources, encouraging emission reductions, and encouraging active travel choices. The adoption of the SPD means changes for how applications will be assessed and introduces additional local validation requirements. This webpage helps to clarify applicants’ and agents’ responsibilities in respect of the Low Emissions SPD.

Why is Action Needed?

  • Poor air quality has a significant impact on health and quality of life.
  • The Council has a legal responsibility to act to achieve air quality standards and objectives in accordance with the Ipswich Air Quality Action Plan, under Part IV of the Environment Act 1995.
  • Part 1 of the Environment Act 2021 establishes a legally binding target to reduce emissions of fine particulate matter (PM2.5) – expected to be published by the government through secondary legislation later this year. Although the Low Emissions SPD is primarily focused on reducing concentrations of Nitrogen Dioxide (NO2), it should also lead to improvements  in concentrations of particulate matter . 
  • The National Planning Policy Framework requires planning decisions to contribute to and enhance the natural and local environment, by preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of air pollution.
  • Adopted Local Plan Policies DM5 Design and Character and DM17 Transport and Access in New Developments set out adopted planning policy requirements regarding air quality.
  • Emerging Local Plan Policies DM3 Air Quality and DM21 Transport and Access in New Developments set out emerging planning policy requirements regarding air quality (check the Latest News for the Plan’s progress).

The Low Emissions SPD adds further detail to the policies in the Ipswich Local Plan. Householder applications are exempt from the requirements of the Low Emissions SPD.

How to use the SPD – Step by step guide to addressing air quality in your planning application

Step 1 – Employ good design practice from the outset 

Make sure the development considers all of the relevant policies and other supplementary planning documents, including those on Space and Design and Public Open Space.

Applicants and agents are strongly advised to enter into pre-application discussions with the Local Planning Authority together with the Council’s Public Protection Team prior to submitting a planning application. These discussions should include the Highway Authority if air quality mitigation / compensation measures are linked to transport matters.

Step 2 - Identify the scale of development 

The Low Emissions SPD defines three levels of development scale (small, medium and large), see Appendix 1 of the Low Emissions SPD for the thresholds/sizes and additional trigger criteria used in the SPD.

Step 3a - Small and medium developments

Applicants for all small or medium developments (excluding householder developments) will need to submit an Air Quality Exposure Assessment alongside a planning application. The Low Emissions SPD provides a simple Exposure Assessment template at Appendix 3 of the SPD for completion. Link to a downloadable version:

To print and complete by hand (PDF), or

To complete and return electronically (word version)

The Exposure Assessment is a screening exercise. It looks at whether the development could potentially expose future occupants to unacceptable levels of poor air quality and helps to determine the appropriate level of mitigation / compensation required.

Where exposure criteria are triggered, applicants will also need to conduct an Air Quality Assessment to be submitted alongside a planning application. Further details of the steps necessary to undertake an Air Quality Assessment are shown in ‘Appendix 4 – Air Quality Assessment Protocol’ of the SPD.

Step 3b - Large developments

A detailed Air Quality Assessment will be required for all large developments and will need to be submitted as part of the planning application process. The Low Emissions SPD provides an Air Quality Assessment Protocol at Appendices 4.

As the need for an Air Quality Assessment will usually only apply to the largest major developments, it is anticipated that these will require input from specialists (see ‘Who Should Carry Out an Air Quality Assessment’ below).

Developers are strongly advised to confirm the scope of any assessment with the Local Planning Authority before undertaking the assessment. Failure to agree the scope of an assessment may result in delay and unnecessary expense.

As part of the assessment procedure, a simple calculation is proposed to allow the quantification of any emission changes – the pollution impact of a scheme can then be monetised using the pollutant damage costs (per tonne) specified by the Defra Interdepartmental Group on Costs and Benefits (IGCB) 33. Information about the ‘Damage Cost Calculator’ can be found in Appendix 5 of the SPD.

Step 4 - All development applications to identify appropriate mitigation

All developments (excluding householder developments) require a Mitigation Statement which outlines the mitigation measures proposed depending on development scale.

In the case of large developments, the statement should include an assessment of impacts and mitigation measures associated with the demolition/construction phase, assessed as part of the wider development’s detailed Air Quality Assessment.

The information provided in the Mitigation Statement will be reviewed alongside the exposure assessment and, if applicable, the Air Quality Assessment for the proposal. We will then use this information to determine whether the mitigation proposed is adequate; there is not a significant increase in the likelihood of an air quality objective exceedance at an on or off-site location; and there is no conflict with the Council’s Air Quality Action Plan.

Link to a downloadable version of the Mitigation Statement templates:

To print and complete by hand (PDF), or

To complete and return electronically (word version)

Who Should Carry Out an Air Quality Assessment?

An Air Quality Assessment should be carried out by a technically competent person. Applicants are advised to check the professional qualifications of any consultant they may choose to conduct assessments. Typically, registration with a relevant professional body such as the Institute of Air Quality Management or Institute of Environmental Management and Assessment helps to show competence.

Example Template Scheme Mitigation Statements

The Council has prepared the following example Template Scheme Mitigation Statements: