LAANC's Response
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In LAANC’s view the consultation has failed to clearly set
out the conclusions of its own air quality assessment within the current UK
planning policy framework. For example the assessment does not address the
potential policy conflicts of opting for either of the two Heathrow proposals.
The conflicts arise as the NPPF states that the planning system should perform
an environmental role to minimise pollution.
One of the twelve core planning principles notes that planning should
“contribute to reducing pollution”. Specifically in relation to air quality
impacts, the NPPF states that: “Planning policies should sustain compliance
with and contribute towards EU limit values or national objectives for
pollutants, taking into account the presence of Air Quality Management Areas
and the cumulative impacts on air quality from individual sites in local areas.
Planning decisions should ensure that any new development in Air Quality
Management Areas is consistent with the local air quality action plan”.
The Commission’s assessment shows that there is a significant risk that any expansion of Heathrow would have material negative impacts on local air quality. It is therefore difficult to see how either shortlisted Heathrow option can comply with current national planning policy guidance as neither option will contribute to pollution reduction or contribute towards meeting national or EU Air Quality Limit Values.
The Commission’s assessment shows that there is a significant risk that any expansion of Heathrow would have material negative impacts on local air quality. It is therefore difficult to see how either shortlisted Heathrow option can comply with current national planning policy guidance as neither option will contribute to pollution reduction or contribute towards meeting national or EU Air Quality Limit Values.
