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Draft Action Plan for Stratford St. Andrew 2017 and Annual Status Report 2016 Results

Consultation results

Stratford St Andrew Air Quality Management Area (AQMA) draft Action Plan 2017

Annual Status Report 2016 – annual air quality report for the Suffolk Coastal district

During August and September 2017 we undertook a Public Consultation asking for views and comments on 2 air quality reports that had been produced;

  • The draft Action Plan for the Stratford St Andrew AQMA – following declaration of an AQMA the Council is required to produce and consult upon a draft Action Plan.  The Action Plan provides additional information regarding sources of nitrogen dioxide (NO2) impacting on this AQMA and proposes measures to be put in place in order to reduce the NO2 concentrations.
  • The Annual Status Report 2016 – this provides an annual summary of the district’s air quality for 2015/2016 and includes updates on each of our AQMAs.

The Consultation ran for 6 weeks and ended on 8th September 2017.

Key findings:

  • The Council received a total of 7 responses to the Consultation which are detailed in the table below.
  • 1 response was specific to the draft Action Plan for Stratford St. Andrew, 3 responses were specific to the AQMA declared in Woodbridge, 1 response was specific to a development site in Trimley St. Martin, and 2 responses were happy with regard to both reports. 

Farnham with Stratford St. Andrew Parish Council

Parish Council 

The Farnham with Stratford St Andrew Parish Council agrees with the action to move the 30 mph sign further south at least 200 metres out of the village at a cost of £20,00 to be completed Autumn 2017. The PC has concerns over the effective re-locating of the 30mph sign. The PC notes that a location has already been decided on and would welcome information as to where the proposed site is – at least 200 metres from the village boundary or at least 200 metres from where the sign is now?

The PC agrees that potential Planning applications within the AQMA are not likely to have a large impact on air quality except for the SZC planning application. The PC is concerned that the impact on the air quality in AQMA and Stratford and Farnham as a whole from the SZC planning application will prove to be far greater than current studies indicate. The PC is not convinced that Mitigation measures could be sufficient to maintain the annual mean objective for air quality.

Out of the long term and aspirational measures included in the AQAP, the Parish Council considers that the Average speed camera system throughout Stratford St Andrew and Farnham, is the most effective option. 

This needs to move from aspirational to actioned asap if monitoring after the sign has been moved continues to indicate that the annual mean objective is not being consistently achieved.

The PC requests that it is included amongst the bodies that receive the results of regular annual monitoring and hopes that the first monitoring will be scheduled as soon as possible after the repositioning of the sign.

The other long term and aspirational measure which would mitigate the entire problem is the four village by pass.

Resident of Woodbridge

Member of Public

In Woodbridge the council want to bring in a 20mph zone including the main road through it. This will of course increase the amount of exhaust fumes with very little return on safety issues, and who knows what they were up to the other week where they introduced temporary ‘trial’ traffic lights at the junction with its monitoring station. I guess what they were trying to do was to move the 'pollution' away from the monitoring station and locate it further down the street, where the residential buildings are.

This of course would massage the figures downward at the monitoring station, but would increase the pollution levels for all the home owners. Not what I would think as being very ethical or considerate towards their constituents. It must be noted as well that during this trial period the queues going through that junction were at least twice as long and at the same time blocking the other junctions along the street, hence doubling the amount of fumes. A big FAIL

Resident of Suffolk Coastal district

Member of Public

Having read the article in the East Anglian Daily Times about the air quality in Woodbridge, I'd like to ask whether this is based on the recently conducted "air quality trial".

If yes, as someone who sat for minutes on end waiting to move, I am not surprised as the timings on the lights were ridiculous and did not reflect the normal usage. It seems to me as if someone had a hidden agenda in the way the experiment was set up. The lights took 2-3 times longer to change, which will inevitably increase pollution.

Resident of Woodbridge

Member of Public 

Thanks for your general letter dated 27/7, ref AQMCON, regarding the Action Plan Update for the AQMA in Woodbridge.

I have read through the reports but am struggling to locate this Action Plan Update. Please can you send me the specific reference and date. I was expecting to find a recent Update i.e. commenting on the 1 week's trial in June/ July 17 but all I can find is older information.

District Councillor

Local authority

Most interesting report – and I am pleased that the Felixstowe AQMA has been revoked and that the proposed action for Stratford St. Mary by simply moving the 30 mph sign will be successful.

Felixstowe Town Council

Town Council

Thank you for providing Felixstowe Town Council the opportunity to comment on Suffolk Coastal’s new air quality reports.

The reports were presented to the Council’s Planning & Environment Committee yesterday. Members noted and welcomed the 5th October 2016 Revocation Order for the AQMA at The Dooley Inn, Ferry Lane, Felixstowe. Members had no further comments to make.

Kirton and Falkenham Parish Council

Parish Council

Kirton and Falkenham Parish Council (the “PC”) would like to respond to this consultation, specifically addressing the request to “To report on significant new developments that might affect local air quality.”

The PC’s specific concern is DC/17/0010/SCO   “Proposed Scoping Opinion for proposed logistics facility at Innocence Farm”. The PC supports SCDC’s requirement that alternative sites are investigated.  Further, the PC has seen no evidence for the need for expansion, especially given existing planning permissions for other expansions which have not been implemented.

The PC would expect rigorous assessment of any Environmental Analysis or Statement, especially given that the proposed site is very close to a rural village and directly adjacent to a primary school serving two villages.  The proposal is for 3,200 HGVs and 600 car movements per day.  By the nature of a logistics site these will be slow moving and carrying out manoeuvres such as reversing, which will cause significant pollution from the diesel engines. 

The impact of diesel fumes has received a great deal of attention recently.  What is becoming crystal clear is that living in areas affected by diesel pollution will have a major impact on human health, particularly in the case of children. Five studies are listed below by way of example.  The PC would suggest that the consultation must address each of the issues raised in these studies. 

a. Cancer risk. Cancer UK has estimated that pollution accounts for 3,500 cases of lung cancer each year (The Times, 12 August 2017).

b. Heart disease.  A study by Queen Mary University of London and Oxford University has shown that particles emitted by diesel engines have been linked with unusual cardiac growth (The Times, 27 April 2017 and 29 May 2017).

c.  Dementia Risk.  “The evidence from experimental work suggests that ultra-fine particles from engines do get taken up through the lungs, circulate in the body and produce inflammation,” “That has been implicated in a variety of diseases and it now appears we have evidence that would suggest a similar link for dementia.”   (The Times, “Busy roads put millions at higher risk of dementia”, 5 January 2017  citing Calderón-Garcidueñas, Lilian et al., “Living close to heavy traffic roads, air pollution, and dementia”, The Lancet,  January 2017).

d.  Coughing and wheezing.  Diesel fumes contain chemicals that directly stimulate the nerves responsible for the coughing and wheezing reflex according to a study by Imperial College, London (The Times, 1 May 2017).

e.  Sleep.  High levels of air pollution significantly affect the ability to sleep (The Times, 22 May 2017) 

The proposed logistics facility reaches the edge of Trimley St. Martin and is very close to its school. The enormous quantity of traffic, in particular of slow moving vehicles within the facility, would emit considerable quantities of carbon monoxide, nitrogen dioxide, PM10 and other pollutants into the ambient air of the school and nearby.  SCDC and SCC’s responsibilities are recognised in the website, but their responsibilities for pollution go far beyond what is stated.  

The DEFRA report (“Draft plans to improve air quality in the UK, Tackling nitrogen dioxide in our towns and cities, UK overview document”, DEFRA, September 2015 ) addressing EC Directive 2008/50/EC and the 2010 Air Quality Standard Regulations (2010/1001) require the drawing up of plans which limit the levels of such pollutants.  A new plan was published by DEFRA in July 2017 which emphasised the responsibilities of local authorities in reducing exposure to pollutants.

To permit development which led to an increase in pollutant levels in close proximity to rural villages and a primary school would be both irresponsible and contrary to central government policy.  It might also invite legal challenge from those concerned with limiting vehicle exhaust emissions and potentially expose the District and County Councils to damages actions by those whose health is adversely affected by the development.

Actions to be taken following the Consultation:

  • Confirmation of the site for the new speed limit change has been sent to Farnham with Stratford St. Andrew Parish Council – the speed limit signs on the A12 at the southern end of the village are to be moved 450m south of their current location to approximately 23 metres north of the centreline of the junction with Chapel Road.
  • This Consultation did not produce any significant changes to the Stratford St. Andrew Action Plan.  The Action Plan is now with Suffolk County Council for final sign off, it will then be sent to the Department for Environment, Food and Rural Affairs (Defra) for final approval and, following that, will then be published on the Council’s website.
  • The speed limit is due to be moved in Stratford St. Andrew in December 2017 (weather permitting).  Following the move, air quality monitoring results collected will be used to determine its effectiveness and whether any of the additional measures within the Action Plan need to be investigated for implementation.
  • Consultation responses with comments relevant to Planning have been forwarded to the appropriate officer within the Planning department.
  • We are working to further embed Air Quality within Planning Policy.  Future planning permissions throughout the district will be assessed for air quality impacts by the Environmental Protection team and responses submitted to Planning.
  • The 1 week trial to move the stop lines back at the traffic lit junction of Lime Kiln Quay Road, Thoroughfare and St John’s Street in Woodbridge was undertaken in July 2017.  This trial was undertaken in order to determine whether it was feasible to run for a longer period in order to determine air quality impacts within the Air Quality Management Area (AQMA) and at other locations on the junction.  Officers from Suffolk County Council are in the process of producing a report on their conclusions and the viability for the trial to be run for a longer period.  When investigating the results of the 1 week trial, impacts on other residential properties along the junction and its approach that are not within the AQMA will be considered.