We have submitted our concerns about air quality in the consultation “Improving air quality: national plan for tackling nitrogen dioxide in our towns and cities”.
We are very dissatisfied with DEFRA’s (Department of the Environment, Farming and Rural Affairs) proposed measures to address the problem:
- We do not accept that devolution of responsibility for air quality to local planning authorities is an appropriate way forward. Local authorities lack the resources, capacity and expertise to shoulder the responsibility.
- We are concerned that each local planning authority will act in isolation with regard to air quality. The government is committed to delivering 1 million new homes by 2020, and it is clear that the adverse air quality impacts of increased traffic, increased congestion and air pollution in pinch-points, will be experienced across more than one planning authority area and we are aware of no overarching strategy that can address this.
- Within Kent, we are particularly concerned at the conflict between the requirement for air quality improvement and policies and decisions on transport. Kent’s channel corridors provide for the movement of some 60% of freight between the UK and mainland Europe. Kent County Council’s Freight Action Plan seeks to facilitate increased traffic, rather than engage in sustainable freight movement strategies which reduce the nation’s reliance on this route. The Port of Dover’s expansion plans will have concomitant impact on the highways network further afield, not least at the existing Dartford Crossings. It is because of the congestion, delays and exceedance of air quality limit values that already exist at Dartford that DfT recently announced a third Thames Crossing to be sited east of Gravesend. However, Highways England have acknowledged that the construction of this crossing would be expected to divert only 14% of the traffic using Dartford to the new crossing at Gravesend; it will not resolve the existing problems at Dartford, but it will create new problems at Gravesend.