RTPI Scotland's Response to Cleaner Air For Scotland 2 Consultation

1 Do you agree with the package of actions put forward in the health chapter?

Yes

Additional comments in support of your answer:

RTPI Scotland acknowledges that there is scientific consensus that exposure to air pollution is harmful to people’s health in terms of premature mortality and morbidity, mainly related to respiratory and cardiovascular disease. It is also widely accepted that outdoor air pollution causes damage to human health across a wide range of conditions, from pre-birth to old age. Air pollution is also harmful to the environment generally, in particular to sensitive habitats and the wildlife depending on these, across Scotland, from local emission sources and more widely through dispersion and long-range transport of air pollutants. We feel that despite research being limited it needs to evolve further and be expanded to match or exceed international standards.

Multiple areas need to be tackled on a joined-up basis, and the inter-relationships need to be recognised, such as improving air quality promoting active travel, reducing air pollution from road transport, reducing people’s exposure, especially to transport related pollution to combat health and well-being issues.

It is encouraging to note that in 2016 Scotland became the first country in Europe to adopt into domestic legislation the World Health Organisation (WHO) guideline value for PM2.5of 10g m3 as an annual mean, whilst appreciating that the relationship between air pollution and mortality is complex.

RTPI Scotland notes the uncertainty from international studies about the scale of health effects associated with low pollutant concentrations typical of those found in much of Scotland today but importantly the research has repeatedly demonstrated impacts of pollutants on respiratory illness that are consistent with international evidence and associations of air pollution with other important health conditions in communities including cardiovascular disease, dementia, diabetes, and adverse pregnancy outcomes (low birth weight and prematurity).

We agree that to achieve these aims will require concerted action to make health focused policy development more of a joint priority across all relevant central and local government departments. RTPI Scotland is particularly keen to see the Scottish Index of Multiple Deprivation (SIMD) used to explore evidence of links between socially deprived communities and air quality noting that low access to economic opportunity often combines with poor health and poor activity levels, poor access to affordable mobility and likely exposure to air pollution.

We note the intention to take further action, both in order to achieve legal compliance with domestic and international standards and this requires integrated health focused policies which deliver lower air pollution and better health outcomes.

The proposed Actions seem to be appropriate and proportionate and the need for further research in all areas is a critical factor.

2 Do you agree with the package of actions put forward in the integrated policy chapter?

Yes

Additional comments in support of your answer:

RTPI Scotland agrees that there is a vital need to integrate policy and mainstream strategies such as the United Nations Sustainable Development Goals and the Scottish Government’s National Outcomes. We are particularly keen to support further progress in embedding placemaking principles across all policy areas to deliver benefits for both physical and mental health through creating better urban spaces that are more attractive to spend time and easier to move around in. Improving design quality and investing in more blue and green infrastructure in local communities. We note that there are clear synergies between many of the high-level strategies and they must all work collectively to be successful. E.g., the National Transport Strategy 2, Climate Change Plan, National Planning Framework 4 and the Infrastructure Investment Plan.

We are particularly keen to see transport, infrastructure, spatial and placemaking agendas integrated and able to interact with each other to maximise the benefits for local people and places.

Transport is Scotland's largest greenhouse gas (GHG) emitting sector and the NTS climate action and health/wellbeing priorities highlight the crucial role of transport in delivering improvements to both climate and air quality emissions. Again, we see the need for policy interlinkages e.g., there is strong evidence of synergies between tackling climate change and improving air quality simultaneously.

We note that the Climate Change Plan update has been published setting out plans for a green recovery from COVID-19, alongside a strategy to meet future emissions reduction targets.

RTPI Scotland fully supports the work of the Just Transition Commission which advises Ministers on how to maximise the economic and social opportunities of meeting climate change targets, while managing the challenges. It is disappointing to note that there are no fixed noise level targets in Scotland or the rest of the UK and in Scotland’s four biggest cities, it has been estimated that over one million people are exposed to noise levels in excess of the WHO guidelines. As with urban air pollution, the major source of ambient noise is road traffic and the adverse impacts of air pollution are closely correlated with those of noise, making it difficult to assess the impact of traffic noise on health separately. RTPI Scotland considers that the many interventions aimed at reducing traffic sourced air pollution are also likely to help reduce excess traffic sourced noise and these interventions range from traffic reduction in urban areas to physical solutions such as green barriers along roads. There is a key role for planners and planning to play here to ensure that new development areas do not exacerbate the position and attention is paid to separation of housing from main traffic arteries and motorways by screen planting, physical distancing, appropriate noise reduction/elimination barriers. A clear link between noise action plans, air quality actions plans and Local Development Plans needs to be established. Standards should be published in Local Development Plans and related guidance as a part of the Actions set out.

3 What in your opinion and/or experience are the barriers to cross departmental working within local authorities or other organisations on air quality and how can these barriers be overcome?

Please provide any comments here:

The key to successful mitigation and implementation of actions is to work collectively in partnership and not to have a departmental “silo” mentality. The Paper makes clear the inter-relationships, synergies and cross-working required and this needs to be articulated in structures and focussed Teams on a wider corporate basis. It is recognised that there are specific regulatory and legislative duties based primarily on professional disciplines but beyond that there has to be collective responsibility at Council, Government and Agency levels.

4 Do you agree with the package of actions put forward in the placemaking chapter?

Yes

Additional comments in support of your answer:

RTPI Scotland strongly endorses and supports the notion that placemaking has a critical and central role to play and this means working collaboratively across professions and communities to identify the best place-based solutions for the issues that we face. This all needs a new approach to integrated spatial thinking and concepts to embed and normalise this across central and local government and the private sector.

The planning toolkit has all the necessary components to lead on such initiatives E.g., the way we plan, design and manage our urban landscapes - as resources, as buffers and spaces for recreation, active mobility and nature, the new open space and green network strategies, blue and green infrastructure, Local Development Plans and the emerging Regional Spatial Strategies and Local Place Plans.

It is recognised that the role that nature-based solutions can address a variety of environmental, social and economic challenges in sustainable ways. Sensitive and sustainable placemaking lies at the heart of this solution and must be seen as an essential, integrated approach. RTPI Scotland has strong ambitions for the new National Planning Framework 4 and the Planning (Scotland) Act 2019 and related reforms which requires that the revised National Planning Framework has regard to any national strategy in respect of the improvement of air quality prepared by Scottish Ministers. Importantly NPF4 will look towards 2050, guiding spatial development, setting out our national policies, designating national developments and reflecting regional spatial priorities. As the paper states, “The Planning (Scotland) Act 2019 set out six outcomes that the National Planning framework should contribute towards, including improving the health and wellbeing of the people of Scotland, improving equality and meeting greenhouse gas emission reduction targets, that relate directly to the aims of CAFS 2”

RTPI Scotland also supports the related actions of the Principal Policy on Sustainability, Town Centre Health Checks and Strategies which should identify how green infrastructure can enhance air quality as well as a range of other impacts. The Planning for Zero Waste policy is also clear that consideration should be given to buffer zones between sensitive receptors and dwellings and some waste management facilities.

We note that although air quality impacts may be considered in Environmental Impact Assessment and Strategic Environmental Assessment, the former does not apply to all developments and the latter applies only to plans, programmes and strategies. This again emphasises the need for a holistic and integrated programme of measures which is multi -sector and multi-professional.

The Place Principle

When the Place Principle was agreed in 2019 it was to help overcome organisational and sectoral boundaries, encourage better collaboration and community involvement, and improve the impact of combined energy, resources and investment in Scotland's regions, cities, towns, and neighbourhoods. We share its ambitions to promote a shared understanding of place, to support inclusive and sustainable outcome improvement and the need to take a more collaborative approach to a place’s services and assets to achieve better outcomes for people and communities.

In particular the Place Principle brings ideas about investments, resources and assets under one roof and is based on an understanding that decision making and delivery that is informed by the people who live and work locally is key to the economic, social, cultural and environmental success of places. All of these elements are essential mechanisms for improving health characteristics. However, if the Place Principle is to be effective there is a need to ‘give it teeth’ and operationalise its work so it influences policy, practice and investment on the ground.

The Place Standard

The Place Standard tool supports individuals, communities and public, private and third sector organisations to think about both the physical elements and the social aspects of a place together in a structured way by asking a series of questions based on the evidence about which aspects of place are important to health and wellbeing, We fully support and endorse the Place Standard as an additional tool to support “a place-based approach and the delivery of high quality, sustainable places that promote community wellbeing and more positive environmental impacts, maximising the potential of the physical and social environment to support health, wellbeing and a high quality of life and reduce health inequalities”

The Actions set out for this area of activity are fully supported by RTPI Scotland NPF4 having regard to CAFS 2 in its preparation, further promotion of the use and role of the Place Standard tool(s) in place-based approaches, enabling delivery of air quality improvement as a co-benefit of delivering high quality sustainable places that support health and wellbeing and reduce health inequalities.

RTPI Scotland considers that the key to overall success will be the joined up work of local authorities developing a targeted approach where appropriate for utilising the Place Standard tool with an emphasis on how effectively air quality is embedded into plans, policies, City Deals and other spatial initiatives, and more generally in cross departmental working, identifying and addressing evidence, skills, awareness and operational gaps.

5 Do you have any suggestions on the role of place-based approaches in delivering targeted air quality improvements?

Please provide any comments here:

RTPI Scotland notes the absence of reference to the 20 minute neighbourhood in CAFS 2. Covid-19 has highlighted the importance of having well-designed, attractive, healthy and sustainable communities where people have local access to the services, shops and facilities they need on a daily basis. Through supporting modal shift to active travel and reducing the need to travel, supporting the creation of 20 minute neighbourhoods could be key place-based approach to improving air quality.

6 Do you agree with the package of actions put forward in the data chapter?

Yes

Additional comments in support of your answer:

Whilst we recognise that there is a comprehensive body of air quality data for Scotland it is important that it is regularly reviewed and that the potential of new technologies, such as low-cost sensors, remote sensors, and the advancement of digital planning interfaces link effectively to related datasets that can provide added value in supporting joined up policy delivery. Data has to be transparent, accurate and be able to be manipulated and presented consistently across different spatial geographies.

RTPI Scotland particularly welcomes the Actions to commission a review of air quality data collection and reporting in Scotland and the commissioning of research to explore the potential of utilising satellite data to complement air quality monitoring. The data sharing, compatibility and transferability of data relating to transport, health, air quality and places needs to be an urgent action to be suitable for inputting into all spatial planning strategies and policies. The intention to create a shared data platform for planning and place data is one of the key actions for the Scottish’s Governments Digital Strategy for Planning

7 Do you have any suggestions on the approach for annual collection of traffic data for air quality management purposes?

Please provide any comments here:

No comment.

8 Do you agree with the package of measures put forward in the public engagement and behaviour change chapter?

Yes

Additional comments in support of your answer:

It is vitally important that there is a new focus on the 3 strands of public information provision, awareness and behavioural change to make them clearer as fundamental requirements integral to the delivery of long term sustained change in environmental quality generally and air pollution specifically.

We note that there is limited evidence available on public perceptions specifically of air quality in Scotland and equally limited research on public engagement around air quality issues has been undertaken in Scotland. RTPI Scotland supports the development of a public engagement strategy on air quality in Scotland.

9 Do you agree with the package of actions put forward in the Emissions Regulation chapter?

Yes

Additional comments in support of your answer:

RTPI Scotland recognises the Sector Plan Approach used by SEPA to help drive improvement across environmental media as well as influencing circular economy choices.

Whilst the current regulatory frameworks are recognised as robust it is vital that we aim for a “beyond compliance” culture and approach and encourage and support progressive business solutions which have clear environmental advantages. It will also be vital in a post-Brexit world to ensure that current EU requirements are still retained as the minimum standard but the focus should be on achieving further emissions reductions with additional benefits for air quality. The proposed Actions are considered to be balanced and proportionate and fit for purpose.

10 Should currently unregulated sectors such as non-waste anaerobic digestion and non-road mobile machinery be brought into existing legal frameworks?

Yes

Additional comments in support of your answer:

RTPI Scotland considers that unregulated sectors must be included if we are to achieve overall improvements in air quality and genuinely adopt a holistic approach.

11 Do you agree with the package of actions put forward to reduce the impact of domestic (household) combustion?

Yes

Additional comments in support of your answer:

RTPI Scotland feels that this an area to tackle as a matter of urgency, both in new and existing housing development and we agree that “Actions to tackle domestic sources of air pollution need to be coordinated with related policies and actions, especially those included in the updated Climate Change Plan and those targeted at building standards and energy efficiency” The current consultation on “New Build Heat Standard” will be an integral part of that package of measures and will include the upcoming Heat Decarbonisation Policy Statement and updated Energy Efficient Scotland Routemap.

RTPI Scotland agrees that the current legislation e.g., Clean Air Act is out of date and requires a radical overhaul to include recent and emerging technologies such as, woodburning stoves, biomass systems, etc. There has to be an integrated approach taken to ensure the transition to low carbon heating solutions for homes and businesses can be achieved.

12 What potential impacts might the package of actions put forward have on households and businesses?

Please provide any comments here:

There will be cost implications and there may a need for a specific set of financial assistance packages including favourable incentives, grants and loans. Planning legislation can be of assistance here and the ongoing review of Permitted Development Rights (PDR) offers another opportunity to specify development which does not require planning permission.

13 Do you agree with the package of actions put forward in the agricultural section?

Yes

Additional comments in support of your answer:

We note that agricultural emissions related to air quality are dominated by ammonia (NH3) and as such agriculture accounts for around 90% of total ammonia emissions in Scotland. It is also pleasing to note that these emissions have declined significantly over the last 30 years.

Agricultural activities such as intensive pig and poultry breeding units, slurries, manures and nitrogen fertilisers care the main components and it is vital that effective mitigations are implemented and the regulations are updated to the latest standards. Codes of Practice, funding schemes, best practice, and policy revisions, planning guidelines, will all be important factors in continuing to reduce ammonia emissions in agriculture. We recognise that mitigation practices will require investment in infrastructure and new equipment, such as low-emission slurry spreading equipment or covers for slurry storage and we support current funding packages such as the pilot Sustainable Agriculture Capital Grant Scheme. All of this improvement work needs to be seen in the wider context as part of the work of the Climate Change Plan and its update in light of Scotland’s new net zero greenhouse gas emissions targets.

14 We will work together with SEPA and the agricultural industry to develop a voluntary code of good agricultural practice for improving air quality in Scotland. Do you agree with this approach to tackling ammonia emissions from farming?

Yes

Additional comments in support of your answer:

Voluntary codes are helpful and assist in joint working and partnership working but the approach may need to be further strengthened with legislative powers as suggested below.

15 Any voluntary code of good agricultural practice could be subject to an early review process to assess its effectiveness and compliance. If the review indicates that insufficient progress is being made, the need for direct regulatory intervention will be considered.

Do you agree with this approach?

Yes

Additional comments in support of your answer:

As we stated above legislation and enforcement is a more powerful tool to use if the voluntary approach is not as successful as envisaged.

16 Do you agree with the package of actions put forward in the nitrogen deposition and environmental impacts section?

Yes

Additional comments in support of your answer:

RTPI Scotland considers this to be a crucial area for intervention and mitigation. Equally we appreciate the damage caused by air pollution on ecosystems is often less obvious and it is more difficult to identify on the ground. Poor air quality and direct deposition of pollutants can however cause damage to plants and animals, and to aquatic and terrestrial ecosystems, impacting adversely on biodiversity. We support the introduction of proactive measures and actions such as low emission ‘buffer zones’ for agricultural emissions around protected nature conservation sites, the planting of trees to recapture airborne nitrogen, and targeting pollution from transport and combustion sources.

17 Do you agree with the actions put forward in the transport chapter?

Yes

Additional comments in support of your answer:

The paper summarises the overarching objectives of the Scottish Government’s transport policy as, “A Scotland that is connected by a sustainable, inclusive, safe and accessible transport system, helping deliver a healthier, fairer and more prosperous Scotland for communities, businesses and visitors. A sustainable travel hierarchy that promotes both a reduction in the need to travel, a modal shift to minimise transport emissions and effectively manage demand to reduce the number of road-based vehicle movements”

RTPI Scotland recognises the crucial role that sustainable travel plans and options are also critical factors in reducing air and noise pollution as transportation is a major contributor to poor air quality across Scotland.

RTPI Scotland advocates a sustainable and integrated approach to move away from car and lorry dependencies and encourages a wider range of travel options for all. We are well placed to implement interventions through the National Transport Strategy and its component paper ‘Take Climate Action’ , given that ‘our current transport system is a significant contributor to poor air quality. Active walking, cycling, public and shared transport, increased freight routes, and electric vehicles for example need to be promoted and communicated to the public to change cultures and practices. As mentioned in response to Q5. RTPI Scotland sees an opportunity for the delivery of 20 minute neighbourhoods to promote modal shift to active transport methods and reduce reliance on cars and lorries. We support the Sustainable Investment Hierarchy which is embedded within the Strategic Transport Projects Review which emphasises a reduction in the need to travel unsustainably, making the most of our existing transport strategic system and supporting strategic investments in sustainable, smart and cleaner transport options.

We also support and encourage the designation of Low Emission Zones (LEZs) in Glasgow, Edinburgh, Dundee and Aberdeen and would like to see this approach adopted on a wider spatial basis. During Covid-19 there has been a dramatic shift to homeworking options for employees and we feel that this should be supported and extended by employers where appropriate for at least part of the normal working week.

RTPI Scotland also supports Active travel the Active Travel Framework 2019, which sets out the key policies for improving the uptake of walking and cycling in Scotland. It is supported by the National Walking Strategy (NWS) and the Cycling Action Plan for Scotland (CAPS). This shift in travel patterns will significantly contribute to cleaner air and less pollution, with the added health, finance and well- being benefits.

We note that 75% of all public transport trips are taken by bus but bus patronage has been dropping over a number of years. We feel that this must be reversed as a matter of urgency. Increased use, better accessibility, ultra- low and zero emission vehicles, modern electric and other energy sources such as LPG must be prioritised as key tools in addressing air pollution from transport. The Rail Safety and Standards Board Air Quality Strategic Framework 2020 sets out a vision for the rail industry which is “a rail network with a minimal impact on local air quality.' This needs a collective approach by the operators and regulators.

RTPI Scotland supports the development of a low carbon economy and the roll out of public electric vehicle chargers across all parts of the country. This will require changes in attitude, financial incentives to encourage customer buy in, and partnership work between local councils and the private sector.

18 Do you agree with the package of actions put forward in the Local Air Quality Management section?

Yes

Additional comments in support of your answer:

RTPI Scotland supports the proposed assessment into the advantages and disadvantages of extending LAQM assessment to all areas with public access. With the potential opportunity of increasing the level of human health and future land use protection delivered by LAQM, the formation of an evidence base to support decision making as to whether such extension would deliver overall benefits will be important.

19 Do you agree with the proposed Governance of CAFS 2?

Yes

Additional comments in support of your answer:

Improving air quality is a cross-cutting issue which has intricate connections with many other policy areas as set out in this Paper. RTPI Scotland believes that the biggest challenge lies in the areas of governance, coordination and responsibility to ensure that we tackle the problems in a joined up and integrated manner particularly as it is directed by many policy and strategy areas. A national overview and management approach is considered essential to ensure legislation, enforcement, monitoring and data collection are all synchronised effectively. The Paper amply demonstrates a plethora of actions, innovations and approaches but the key to reducing air pollution and improving air quality will require substantial co-working and co-production across multiple agencies and different levels of government.

20 Do you agree with the proposed review timeframe?

Yes

Additional comments in support of your answer:

The 5-year review cycle appears to be appropriate.

Impact Assessments

21 Are you aware of any additional equalities impacts of the proposals in this strategy?

Please provide any comments here:

No

22 Do you think introducing legislation to control the supply of the most polluting domestic fuels, as described in chapter 7 of this consultation, will have disproportionate impacts on remote/rural or island communities? Please provide evidence where possible in support of your answer.

Please provide any comments here:

Yes. We have no specific evidence but it seems obvious and self-evident that there is likely to be an urban/rural/islands split on these matters and it is likely that the main targets and solutions are inevitably urban based.

23 Do you think this strategy will disproportionately impact low income households? Please provide evidence where possible in support of your answer.

Please provide any comments here:

We do not consider that this is a straightforward question to respond to. Some of the proposed actions, such as changing to low emission vehicles and replacement heating systems may have a disproportionate impact. Conversely, initiatives such as better integrated and subsided public transport networks may provide substantial benefits to lower income households.

24 Are you aware of any additional business or regulatory impacts of the proposals in this strategy? Please provide any supporting evidence that you are aware of.

Please provide any comments here:

No

25 Do you anticipate that the proposals in this strategy will have differing impacts for large/small scale businesses? Please provide any supporting evidence that you are aware of.

Please provide any comments here:

Yes. It is likely that there will be differing impacts on businesses depending on their scale, number of employees and also the nature of their business. Also, the usage of freight transport methods will be crucial.

26 Would there be different impacts for those that operate in Scotland only and those that operate across different parts of the UK? Please provide any supporting evidence that you are aware of.

Please provide any comments here:

Yes. Travel by different transportation methods and the distances travelled will be factors in such a situation.

27 Would there be different impacts for those that operate in Scotland only and those that operate across different parts of the UK? Please provide any supporting evidence that you are aware of.

Please provide any comments here:

Yes. Again, this seems to be an obvious and self-evident conclusion to make. Different geographies, population levels and patterns of distribution and different environments will all have different impacts in terms of usage, applicability, relevance and there will inevitably be diseconomies of scale.

28 What are your views on the accuracy and scope of information used to describe the environmental baseline set out in the Environmental Report?

Please provide any comments here:

No comment.

29 What are your views on the predicted environmental effects as set out in the Environmental Report?

Please provide any comments here:

No comment.

30 What are your views on the findings of the SEA and the proposals for mitigation and monitoring the environmental effects set out in the Environmental Report?

Please provide any comments here:

No comment.