Developers, planners and local authorities should prepare for a potential shift in how air quality is considered within planning, with meeting existing limits increasingly unlikely to be viewed as the end of the conversation, according to environmental specialist Lucion Group.
The advice follows the latest evidence session of the House of Commons Environmental Audit Committee’s inquiry into Air Pollution in England, held on 14th September, as the Government begins work towards its next Air Quality Strategy, due in 2028.
During the session, DEFRA Minister Emma Hardy MP said she wanted the forthcoming strategy to explore a culture of “continuous improvement”, rather than an approach where reaching compliance effectively means the issue is considered complete.
Lucion believes the direction of the discussion could have important implications for future planning applications and air quality assessments, particularly for developments in areas where pollution levels, population exposure or vulnerable communities are already a concern.
Dan Clampin, Associate Director at Lucion Group, said: “The significant point for developers and planners is the direction of travel. At present, much of the focus within an air quality assessment is understandably on whether a proposed development will comply with the relevant limits.”
“What we are now hearing is a desire to look beyond that minimum position and consider what more can be done to continually reduce exposure and improve air quality.”
“That does not mean the planning requirements have suddenly changed, but it does give us an indication of how expectations could develop. For those bringing forward projects over the next few years, it makes sense to start thinking about air quality, mitigation and improvement as early as possible rather than waiting for new policy to arrive.”
The Committee heard that 65 new PM2.5 monitors have been installed since 2024, with the network expected to increase to approximately 197 monitors by the end of 2027. DEFRA is also working with the UK Health Security Agency on vulnerability mapping to help identify communities disproportionately exposed to pollution.
According to Lucion, a more detailed evidence base could give local authorities greater insight into pollution and population exposure at a local level, potentially increasing the level of information expected from developments proposed in sensitive locations.
The evidence session also highlighted possible changes beyond traditional road and development-related emissions.
DEFRA officials confirmed that the Government is considering extending environmental permitting to beef and dairy operations as it looks to reduce ammonia emissions from agriculture. Bill Parish, Deputy Director for Noise, Agricultural and Industrial Pollution at DEFRA, told the Committee that the cattle sector is responsible for 46% of national ammonia emissions and is currently outside environmental permitting requirements.
Dan added: “For developments close to sensitive habitats, agricultural operations or areas already experiencing air quality pressures, these discussions are particularly relevant.”
“We are not suggesting that every proposal will suddenly face a completely different assessment process. The important thing is recognising that policy is moving and that the evidence available to regulators and local authorities is becoming increasingly detailed.”
“Understanding the potential issues early gives project teams more opportunity to build appropriate mitigation into a scheme and reduce the risk of air quality becoming a source of delay later in the planning process.”
Transport emissions are also continuing to evolve. The Department for Transport has consulted on adopting the Euro 7 vehicle emissions standard in Great Britain, including new requirements relating to particulate emissions from brakes as attention increasingly turns to non-exhaust emissions.
Meanwhile, the Government confirmed during the Committee session that decisions on Clean Air Zones and ULEZ-style schemes will continue to sit principally with local areas, rather than being mandated nationally.
Lucion advises developers, local authorities and other organisations to consider the emerging policy direction now, particularly where projects are likely to progress through planning as the 2028 Air Quality Strategy is developed.
Dan concluded: “The regulations and guidance that apply today remain the starting point, but major developments often take years to move from concept through planning and delivery.”
“Looking at where policy is heading as well as where it stands today can help organisations make better-informed decisions, avoid unnecessary surprises and build more resilient projects from the outset.”
