Campaign Meeting on Monday 30th November 2020 at 8pm - Keith Prince AM is our speaker

 Agenda

1 Apologies 

2 Keith Prince will speak to us with his views on the campaign

3 Minutes and matters arising

4 Anglia Development Decision

I cut and paste the key passages from the Secretary of State's DECISION re air quality at end of agenda.

5 Any other business

5 Date of next meeting

Key Extracts form Norwich Decision

This is para 2 at page 2

A list of representations which have been received since the inquiry is at Annex A. Copies of these letters may be obtained on request to the email address at the foot of the first page of this letter. In the representation dated 14 September, points were made which sought to draw the Secretary of State’s attention to emerging medical evidence with regard to air quality and the incidence and severity of Covid-19, and also to a PreAction Protocol letter seeking an early review of the Government’s Clean Air Strategy. Given that the outcome of any challenge to the Clean Air Strategy is not yet known, and given his decision is to refuse this application, the Secretary of State is satisfied that the issues raised do not affect his decision, and no other new issues were raised in this correspondence to warrant further investigation or necessitate referral back to parties.

This is from pages 10 and 11

Air quality

 60.In 2012 the Council declared an Air Quality Management Area (AQMA) covering the whole of the city centre, including the application site, due to exceedances of the annual mean objective for NO2 (IR548). For the reasons given in IR549-559, the Secretary of 11 State agrees with the Inspector that the information before him is sufficient for air quality to be properly taken into account in this decision (IR559).

 61.For the reasons given in IR560-567, the Secretary of State agrees with the Inspector that the proposal would be appropriate for its location taking account of likely effects on health and living conditions, and that no conflicts with the Council’s Air Quality Action Plan have been identified. He further agrees that opportunities to mitigate impacts have been identified, that the proposal would contribute towards compliance with relevant national objectives, and that the air quality benefits of providing housing in this accessible site should be given limited weight (IR566). The Secretary of State agrees with the Inspector that the proposal would accord with the Framework and with DM11 (IR610), and that air quality is not a matter that weighs against the grant of planning permission (IR567).

&

Air Quality pages 31-35 

This was not one of the matters which the Secretary of State indicated that he particularly wished to be informed about, notwithstanding his consideration of the representations made by CYC. This is relevant because Professor Peckham, one of the authors of the written evidence for CYC, has argued in the Court of Appeal that the Secretary of State is obliged to call in all planning cases where there is potential for exceedances of the nitrogen dioxide (NO2) limits identified in the relevant Air Quality Directive. The Courts did not accept Professor Peckham’s case. 

114. The case made against this proposal was based on 3 main propositions. As the potential for these arguments to fail became clear, new and different arguments took their place during the Inquiry. These submissions deal first with the case as originally advanced and then as it evolved, before setting out the applicants’ positive case. The air quality case for CYC as originally advanced 115. First, it was argued that the Secretary of State is under a duty to ensure compliance with the national air quality limit values “within the shortest possible time” and as a result “any development [in the UK] which does not reduce air pollutants to legal compliance levels….will be found unlawful”. However: • This proposition is hopelessly incorrect and has already been dismissed by the Court of Appeal. • Thus in the case of Shirley

47, Professor Peckham argued that, because the national air quality targets for NO2 had not been met, there was a duty on the Secretary of State to call in (and to refuse) any application where there was an issue about compliance with air quality standards. • The court was clear that this proposition was incorrect. It is a shame that there is no reference to Shirley in the evidence for CYC. • The Court held that, where there was a breach of the Directive, the “single prescribed means of addressing the breach is the preparation of an air quality plan”. It went on to say that there was nothing in case law that supported Professor Peckham’s assertion that “land use planning powers and duties have to be exercised in any particular way - such as by imposing a moratorium on grants of planning permission for particular forms of development or for development of a particular scale whose effect might be to perpetuate or increase exceedances of limit values.” • The Court went on to explain that, where air quality was an issue, the appropriate approach was to take it “into account alongside other material considerations weighing for or against the proposal” in the ordinary way. 

116. The failure of this first limb was recognised in the opening statement for CYC when Dr Boswell (one of CYC’s witnesses on air quality) stated that it was not 47 CD10.24, see in particular paragraph 33 Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate 

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his case that permission could not be granted where there were exceedances but, rather, that such exceedances ought to be reduced as soon as possible. 

117. Second, it was suggested in the statement of case and the original proofs that the Secretary of State is obliged to ignore potential enhancements in air quality as a result of regulations and policy during the lifetime of the project. However: • This second proposition relies on a misunderstanding of the Gladman48 case and is patently incorrect. Again, Professor Peckham was involved. • The Court of Appeal found that, in the absence of any evidence on the potential quantum of improvements, the Inspector was entitled to place little reliance on them. In particular, “He was entitled to rely on the evidence before him rather than the evidence that might have been produced but was not”. • The Court also referred to the fact that there was no evidence before the Inspector regarding the possible consequences of government policy in relation to NO2 concentrations. • The position here is very different. The Government has now issued vehicle emission regulations and specific evidence-based guidance on fleet emission factors and likely background concentrations. This guidance is designed to enable the assessment of the relevant levels in future years. • The Planning Inspectorate has recently given clear guidance that a failure to take into account anticipated improvements in air quality when establishing a future baseline for emissions would now be legally unsound49. • This Inquiry has evidence-based guidance on how to approach likely future background concentrations of NO2 and particulate matter (PM10). It must use this evidence, which establishes that the proposal can proceed consistent with the relevant air quality policy. • This Inquiry also has the CURED v3A50 sensitivity test for NO2, which was recently described by the Wealden Inspector and Natural England as appropriately precautionary. • The use of either of these scientifically credible tools establishes that there is no air quality reason for withholding permission at this sustainable site.

 118. Third, it was argued that planning permission should be refused on air quality grounds because the existing and predicted levels of NO2 and other pollutants are such that the site is not appropriate for housing at all51. Dr Mills confirmed in his evidence in chief that this was his position. He suggested that new 48 CD15.118 49 Inspector’s interim findings on Wealden Local Plan examination (CD10.23) 50 Calculator Using Realistic Emissions for Diesels – an emissions factor calculator issued by Air Quality Consultants (CD15.27) 51 Paragraph 4 of the proof of Professor Peckham/Dr Mills (the proof was written jointly and Dr Mills attended the Inquiry to give evidence) (CYC3/1) Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate 

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 housing would be “best placed out in the fields” where it would have a reduced air quality impact and that the application site could become a park.

 119. However, the application site affords a high degree of accessibility to all modes of travel. It is likely to be the best available brownfield site in the Norwich urban area in transport and overall sustainability terms. It would be ironic if such a site were lost to housing development due to an air quality objection driven by existing vehicle emissions, particularly when one of the key benefits of the scheme is that it would improve the ability for new residents to make sustainable transport choices. 

120. CYC’s alternative suggestion was that the quantum of development should be reduced and a 13m grass and woodland border should be provided around the entire proposal. The status of this suggestion is now unknown52. For the reasons identified above, such a suggestion would make redevelopment undeliverable. Use of CURED 3A is reasonable and precautionary 

121. Turning to the new points that emerged during the Inquiry, there was an extraordinary volte face in CYC’s case regarding the use of CURED v3A. The applicants’ air quality evidence followed guidance from the Department for Environment, Food and Rural Affairs (DEFRA) that decision makers should have regard to Emissions Factor Toolkit (EFT) v9 when identifying the impact of policy changes on vehicle emissions of NO2. CYC accepted that it was right to have regard to such policy changes and argued that, in addition to EFT, it would be reasonable and precautionary to use CURED v3A as a sensitivity test in this case. This was the unambiguous position of this Rule 6 Party in its rebuttal proof of evidence53.

 122. The applicants then re-ran the assessment using the CURED v3A toolkit to provide a sensitivity test, as suggested by CYC. This exercise showed that, when considered with the most up-to-date measured baseline figures and in line with policy, the proposal gives rise to no air quality issues54. When this outcome became known to CYC its previously unambiguous position on the use of CURED v3A was jettisoned. In closing, CYC now says that the CURED v3A dataset should not be used at all55. This inability to accept that which was uncomfortable for its case characterised the air quality element of CYC’s case. Use of bias factors 

123. At the start of the Inquiry CYC was arguing that the Council had inappropriately used local bias factors when carrying out its duties under the Environment Act. CYC suggested that the Council should have used the national bias factors. When it became apparent that using the most up-to-date national figures would have made no difference to the results, the suggestion was advanced that an 52 Inspector’s note – this suggestion is contained in the summary of the proof. When asked about it in cross examination by Mr Harris, Dr Mills said that it could be disregarded 53 Inspector’s note – row 36 of the Air Quality Statement of Common Ground (ID11) records that CYC considered that CURED v3A is a “valuable tool for sensitivity testing” in an AQA. CYC disagreed that it should be regarded as precautionary. 54 The results are set out in WH20 and WH24 55 Paragraph 73 of the closing submissions (CYC14) Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate Page 34

 adjusted national figure ought to be used. This adjustment was made unilaterally by Dr Boswell, without reference to DEFRA or the Council. This is a hopeless approach. The Council is required to use either local or national figures (and to explain why) as part of its submission to DEFRA. The Council’s Air Quality Management Area (AQMA) Report was undertaken in accordance with the regulations and guidance, it has been approved by DEFRA and there has been no challenge to that approval. 

124. If the approach suggested by Dr Boswell in closing were to be adopted, it is difficult to see how any local air quality authority could make any realistic assessment of air quality under the present regime. Dr Boswell was asked by the Inspector how he thought the analysis should be done, given his criticisms of both local and national data sets. No realistic answer was forthcoming. If Dr Boswell is right then every single AQMA report submitted to DEFRA in accordance with the Environment Act would be incorrect and unreliable. 

125. In any event, the most up-to-date measured levels of pollutants fall so far below the limit levels that there is no realistic prospect (having regard either to CURED v3A or to EFT v9) of even CYC’s typical range of bias factors making any difference to the conclusions to be reached in the circumstances of this case. The applicants’ case on air quality

126. Air quality is to be considered on its merits alongside all of the other benefits and harms of the proposal. That has been confirmed by the Shirley case. The limit values applicable for NO2 and PM10 for planning purposes are clear and well understood. CYC may prefer alternative levels but that is not a matter for this Inquiry. At the time of the officers’ report, it was accepted that there was likely to be an increase in concentrations of relevant pollutants as a result of the proposals. In a ‘no policy world’ this would have included modelled exceedances for NO2 in some locations, including at Edward Street. At all locations the modelled concentrations of PM10 fell way below the relevant limit values.

127. However, these results were not seen as justifying a refusal of planning permission when considered in the overall planning balance. Moreover, the Council’s air quality officer considered that the results at Edward Street were anomalous. This was because the concentrations modelled there were higher than some of the highest readings at the city centre bus interchange. An air quality condition requiring further modelling and mitigation was therefore put in place. 

128. Following the resolution to grant planning permission the application was called in. Air quality was not identified as a reason for the call in and no further specific air quality measurements were taken. However, during the course of the Inquiry, the Council’s latest readings for the AQMA as a whole became available. These are the fullest and most up-to-date readings before the Inquiry and should therefore be used. The measured figures for Edward Street are well below the previously modelled figures and also well below the relevant limits for NO2, confirming that the modelled figures were (as suspected) anomalous. Given that these were measured figures, Dr Boswell’s detailed criticisms of the model are irrelevant. Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate Page 35 

129. Having regard to the EFT guidance and the Wealden Inspector’s interim findings, the Council now accepts that the impact of policy on vehicle emissions must be taken into account. When the up-to-date baseline readings are used and either the EFT v9 toolkit or the CURED 3A dataset are used, then the concentrations of both NO2 and PM10 fall well below the relevant limit levels at all relevant receptors56. Taken together with the fact that development in this location has the potential to reduce significantly overall vehicle mileage in the AQMA, then the conclusion that it should be developed as proposed and not left fallow becomes compelling.

 130. The redevelopment of this sustainable urban site should not be halted by air condition concerns. All air quality matters have been minimised as far as practical and/or can be dealt with by way of conditions. Rather than being an air quality problem, this site forms an essential part of the solution to the challenge of accommodating significant and sustainable growth in housing and jobs in the city centre. Overall conclusion

 131. The proposal before the Inquiry represents an opportunity for the planning system to address the dilemma that is Anglia Square and to unlock the potential of a site which lies at the heart of the spatial strategy for Norwich. That opportunity must now be taken.ENDS

A key passage in the above appears to be

"However, during the course of the Inquiry, the Council’s latest readings for the AQMA as a whole became available. These are the fullest and most up-to-date readings before the Inquiry and should therefore be used. The measured figures for Edward Street are well below the previously modelled figures and also well below the relevant limits for NO2, confirming that the modelled figures were (as suspected) anomalous."

This suggests we need the latest Redbridge Council figures which should have been published months ago. I have also purchased a pollution monitor to measure the NO2 and PM quantities at bus stops at child height close to primary schools. If the readings are high we can make the argument that the Council should take further readings.

The Secretary of State appears to rely on the September 2018 Shirley court of appeal judgment available HERE I don't understand the reasoning which is copied below

The law

The law 179. There is no moratorium on development where air pollution levels in an area are higher than limit values. In Shirley111 the Court of Appeal decided that where levels of pollutants in ambient air exceed limit values, the only obligation is to produce an Air Quality Plan. Article 23 of the Air Quality Directive provides: “1. Where, in given zones or agglomerations, the levels of pollutants in ambient air exceed any limit value or target value, plus any relevant margin of tolerance in each case, Member States shall ensure that air quality plans are established for those zones and agglomerations in order to achieve the related limit value or target value specified in Annexes X1 and XIV. In the event of exceedances of those limit values for which the attainment deadline is already expired, the air quality plans shall set out appropriate measures, so that the exceedance period can be kept as short as possible. The air quality plans may additionally include specific measures aiming at the protection of sensitive population groups, including children…” 

180. Article 23 is transposed into UK law by Article 26 of the Air Quality Standards Regulations 2010112, which provides that the Air Quality Plan must: “include measures intended to ensure compliance with any relevant limit value within the shortest possible time….” 

181. The Court in Shirley held that where there is a breach of limit values: “[32] The preparation of an air quality plan is the single prescribed means of addressing the breach…. [33] This does not mean that Member States may not also adopt other measures to address a breach of [limit values], in addition to preparing and putting into effect an air quality plan complying with article 23. But nor does it mean that Member States are compelled by any provision of the Air Quality Directive to do that. A demonstrable breach of [limit values] does not generate some unspecified obligation beyond the preparation and implementation of an air quality plan that complies with article 23. The case law does not suggest, for example, that in such circumstances a Member State must ensure that land use planning powers and duties are exercised in a particular way, such as imposing a moratorium on grants of planning permission for particular forms of development, or for development of a particular scale, whose effect might be to perpetuate or increase exceedances of limit values, or by ensuring that decisions on such proposals are taken only at ministerial level.”

 182. The Court went on to say: “[48] This is not to deny that the likely effects of a proposed development on air quality are material considerations in the making of the decision on the 111 CD10.24 112 SI 2010/1001 Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate Page 48 application for planning permission, to be taken into account alongside other material considerations weighing for or against the proposal….” 

183. Contrary to the case put by CYC, Gladman113 does not affect the ruling in Shirley even though it was decided a few months later. This is because Gladman related to an appeal decision made in 2016, before there was a national Air Quality Plan or any known measures for improving air quality. In Gladman the Court found that the Inspector: “[39] had to form his own judgement on these questions without knowing what measures the Government’s new national air quality plan would contain - where, for example, clean air zones would be introduced - or when compliance with limit values would be secured. Nor did he know how measures taken at the national level would translate into local measures…. [40] In the circumstances he cannot be criticized for not speculating about unknown measures to improve air quality at either national or local level, or for not venturing an opinion on any improvement in local air quality. He was entitled to rely, as he did, on the evidence before him, rather than the evidence that might have been produced but was not…. [41] It was not within the Inspector’s duty as decision maker to resolve the ‘tension’….between the Government’s responsibility as decision maker to comply swiftly with the limit values for air pollutants and the remaining uncertainty over the means by which, and when, the relevant targets would be met….” 

184. Gladman established only that the decision maker could not be faulted for deciding not to speculate on the possible effects of a National Air Quality Plan and other measures to control air pollution. The situation at this Inquiry is entirely different because there is now a National Air Quality Plan114, there is also a plan for Norwich115, the Government has introduced restrictions relating to the vehicle fleet and there is guidance on emission factors116.

 185. Dr Boswell argued that planning permission could not be granted in an AQMA unless there was clear evidence that legal levels of air quality would be delivered117. Dr Mills stated that, as the proposed development would be in an existing AQMA, it is imperative that it makes no addition to current pollution levels118. Neither proposition has any foundation in law or policy. Shirley establishes that, where air pollution breaches limit values, the only duty is to produce an Air Quality Plan. There is no duty to refuse planning permission unless legal levels of air quality will be delivered with a particular development. Air quality is but one of the material considerations which the decision maker must take into account119. The Institute of Air Quality Management advises that: 113 Gladman Developments Ltd v SSCLG [2019] EWCA Civ 1543, appendix 3 to Dr Boswell’s proof (CYC1/3) 114 CD15.28 115 CD15.105 116 WH23 117 Paragraph 31 of opening for CYC (CYC10) and row 33 of SoCG on air quality (ID11) 118 Paragraph 37 of Peckham/Mills proof (CYC3/1) 119 Paragraph 48 of Shirley (CD10.24) Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate Page 49 “The presence of an AQMA should not halt all development, but where development is permitted, the planning system should ensure that any impacts are minimised as far as practicable.”120 The relevance of limit values 

186. CYC argued that there is no safe limit for NO2 or particulates. Dr Mills referred to a report of the Royal College of Physicians121 and suggested that a safe level for NO2 could be 5 micrograms/m3. However, there is a need for development and the Government has set limit values for pollutants in paragraph 181 of the Framework. These are the limits which are to be used for planning purposes. In setting them, the Government would have been aware of the research referred to by CYC. Moreover, the limit values are kept under review. The recently published Clean Air Strategy 2019122 sets an aspiration to reduce the number of people experiencing PM2.5 levels greater 10 micrograms/m3 by 50%. However, it does not set new limit values, either for particulates or for NO2. The application should be assessed by reference to the current limit values. The application site is the most sustainable location 

187. Norwich needs development, including a significant amount of new housing. If a substantial part of that need cannot be met within the city then these homes are likely to be built on less sustainable sites in the Greater Norwich area. There was no challenge to the Council’s evidence that this is the most sustainable major development site in the City123. Its location on the fringe of the city centre enables high levels of accessibility by all modes of travel and its proximity to facilities and transport hubs creates the very best conditions for promoting sustainable travel behaviour.

188. Locating development on highly sustainable brownfield sites such as this minimises vehicle emissions because it reduces the need to travel by car. Future residents of Anglia Square would be less likely to use their cars for work, shopping and other trips because public transport is excellent and facilities are available nearby. Existing residents in the surrounding area would have a better range of shops and other facilities within walking distance. However, CYC’s case on air quality took no account of the need for development or the sustainability of this location. Dr Mills suggested that the site would be better developed as a park124 and that, if development was needed, it should be located away from the urban area. If that approach were adopted the result would be more vehicle emissions and more air pollution, not less. 

189. Planning policy prioritises development in sustainable urban locations, particularly on brownfield sites. Locations such as this are likely to experience greater levels of air pollution than green field sites out of town. That is inevitable and is not a reason to reverse the policy presumption in favour of 120 Paragraph 8.3 of Land-Use Planning & Development Control: Planning for Air Quality (CD15.108) 121 Every Breath We Take (CD15.11) 122 CD15.28 123 Paragraph 485 of the officers’ report (CD2.15) 124 Paragraph 41 of Peckham/Mills rebuttal (CYC3/4) Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate Page 50 developing sustainable urban sites. The issue here is whether, having regard to the existing urban context, there is any air quality reason to refuse permission. No such reason exists. Taking account of the impact of Government policy on emission factors 

190. In the officers’ report, future air quality was assessed without taking account of potential reductions in vehicle emissions associated with changes in engine and fuel technology125. It is now clear that this approach is too conservative. CYC accepted that the assessment with the development in place should take account of future reductions in accordance with Government policy. The Government has stated that EFT is a tool which allows emissions for a particular year to be calculated126. This amounts to a clear Government policy that anticipated reductions in emissions should, indeed, be taken into account.

 191. It is therefore unsurprising that the Inspector examining the Wealden Local Plan concluded that it would be unreasonable and lacking in scientific credibility to assume no improvements over time. The Inspector referred to reservations about EFT v9 and commended use of CURED v3A as being conservative and consistent with the precautionary principle established in relation to Habitats Regulations Assessment127. (In this case there is no statutory requirement to take a precautionary approach). Moreover, Dr Mills himself suggested using CURED v3A as a sensitivity test128. On any reasonable view, it is appropriate to predict air quality with the development in place using CURED v3A. Dr Boswell’s criticism of CURED v3A was not credible. The results of the assessment of NO2 

192. The evidence of Ms Hobson shows the impacts of the proposal129. The assessments take account of monitoring data from 2017 (provided by the applicant) and 2018 (provided by the Council), as used in versions 2 and 3 of the air quality assessment, as well as the Council’s full year’s monitoring for 2019130. There was no suggestion of exceedances of NO2 limit values in relation to any of the first floor residential accommodation within the scheme. 

193. The only ground floor residential accommodation in the scheme would be in Block B, which corresponds to receptor location H (Edward Street). The assessment examined NO2 levels at that location and also at existing housing at Edward Street and Dalymond Court. CURED v3A modelling based on the 2018 and 2019 monitoring shows NO2 well below the limit value of 40 micrograms/m3 at all these locations131. Only the modelling based on the 2017 monitoring suggests levels in any location higher than the limit value. 125 Paragraphs 509 to 525 (CD2.15) 126 Emissions Factor Toolkit v9 (WH23) 127 Paragraphs 7 and 8 of CD10.23 128 Paragraph 21 and 22 of Peckham/Mills rebuttal (CYC3/4) 129 WH20 and WH24 130 Appended to the Air Quality SoCG (ID11) 131 The same outcome is reached when Edward Street is assumed to be a canyon, although Ms Hobson stated that this assumption makes a difference of only 0.1 microgram/m3 Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate

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 194. The 2017 monitoring at Edward Street was carried out for only three months (contrary to guidance in TG16132) and is therefore less reliable than the Council’s 2019 monitoring which was for 12 months. This showed an annual mean NO2 level of 26 micrograms/m3, confirming the view of Ms Oldfield (the Council’s Public Protection Officer) that the 2017 results were not representative133. Overall, the assessments show that air quality in Edward Street, at receptors within the scheme and at existing residential accommodation, would be well within the limit values and entirely acceptable.

 195. The 2017 monitoring showed a high result at a location in Magdalen Street134. However, that result was also unrepresentative. The monitoring location was at the kerbside, in front of a bus stop where bus movements may be expected to create a hotspot. The 2019 monitoring at various locations on Magdalen Street135 shows all results below the limit value of 40 micrograms/m3. The assessments also considered the effect on ground floor residential accommodation in St Augustines Street. There is no cause for concern here. With the development in place, the CURED v3A modelling shows NO2 levels well below the limit value, whether based on 2018 or 2019 monitoring data. Bias factors 

196. The Council’s 2019 Air Quality Annual Status Report136 applied a local bias factor (as opposed to the national bias factor) to the 2018 monitoring data. This approach was criticised by CYC. Dr Boswell submitted a note on the topic, to which the applicants and the Council have submitted a joint response137. In summary, use of a local bias factor was appropriate because of good correlation between diffusion tube results and the Lakenfield chemiluminescent analyser (which is part of DEFRA’s Automatic Urban and Rural Network) and because there was only a limited number of results within the national database. Moreover, DEFRA has approved the Annual Status Report and must therefore have been satisfied with the use of a local bias factor.

 197. In any event, even if the national bias factor of 0.89 had been used (rather than the local bias factor of 0.86 applied by the Council), it would have changed the results by only 3%, which would make no material difference. Dr Boswell suggested that a higher “national” bias factor should be derived by excluding from the national database results from Redcar and Cleveland. This would be a misuse of the national dataset which is published by DEFRA with the intention that it be used in a consistent way. Particulate matter 

198. All projections show levels of PM10 and PM2.5 well below the current Government target levels. The 2019 Annual Status Report results for Lakenfield and Castle 132 Paragraph 7.123 (CD11.37) 133 Paragraph 3.4 of Ms Oldfield’s rebuttal (NCC6/4) 134 70 micrograms/m3 at monitoring location H 135 Results for DT6 at table 3 on page 9 of Air Quality Assessment v3 (location shown on the plan at page 14) (WH8/3); the Council’s 2019 monitoring at points DT2 and DT3, shown in the table appended to the Air Quality SoCG (ID11) 136 CD15.126 137 CYC11 and ID17 respectively Report APP/G2625/V/19/3225505 https://www.gov.uk/planning-inspectorate Page 52 Meadow (which has the worst air quality in the city) show PM2.5 levels no higher than the World Health Organisation limit of 10 micrograms/m3. As Ms Oldfield said, these results are encouraging for Norwich. Conclusion on air quality 

199. Overall, the evidence shows clearly that planning permission for the proposed development should not be refused because of air quality concerns.