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[Page 1] An Air Quality Assessment for Cooil Road, Douglas, Isle of Man
On behalf of Eden Park Developments
March 2022
[Page 2] An Air Quality Assessment for Cooil Road, Douglas, Isle of Man On behalf of Eden Park Developments
RE00083 – Rep 1
An Air Quality Assessment
for
Cooil Road, Douglas, Isle of Man
On behalf of Eden Park Developments
Report Reference: RE00083 – Rep 1
This report has been prepared by Resound Environment with all reasonable skill, care and diligence, and taking
account of the manpower and resources devoted to it by agreement with the client. Information reported herein
is based on the interpretation of data collected and has been accepted in good faith as being accurate and valid.
This report is for the exclusive use of Eden Park Developments no warranties or guarantees are expressed or
should be inferred by any third parties. This report may not be relied upon by other parties without written
consent from Resound Environment.
Resound Environment disclaims any responsibility to the client and others in respect of any matters outside the
agreed scope of the work.
Document Issue Record Issue Description Date Approved Rev0 Final for issue 22nd March 2022 MB
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1
INTRODUCTION
1.1
Eden Park Developments has appointed Resound Environment, a trading name of Resound
Acoustics Limited, to undertake an air quality assessment (AQA) for the proposed
commercial development on land off Cooil Road, Douglas, Isle of Man. The National Grid
Reference for the centre of the site is 234387, 475655. A site location plan is included in
Figure A.1 in Appendix A.
1.2
The development site is on the western edge of Douglas, opposite the Isle of Man Business
Park and currently consists of mainly agricultural land associated with Ballavargher Farm,
with the farmhouse and associated farm buildings also falling within the site area, along with
the road network associated with the existing commercial premises adjoining the site to the
north-east.
1.3
The development site is bounded to the north-east by a number of commercial premises
including Riley’s Garden Centre, the existing Eden Park Business Park units, Robinson’s food
distribution facility and Jackson’s car dealership. Cooil Road also runs along part of the north-
eastern boundary. The first phase of development at Zone A will be accessed from Cooil
Road via the existing business park. The main access point to the development will be via
the Jacksons roundabout currently providing access to Jacksons car dealership off Cooil
Road. The site is bounded to the north-west, south and south-east by further agricultural
land, although areas to the south-east form part of a wider development area known as
parcels BE002b and BE006. Land to the south is also controlled by Eden Park
Developments. A map showing the surrounding land uses is provided in Figure A.2 in
Appendix A.
1.4
In the wider area is the Isle of Man Business Park to the north-east and isolated residential
properties to the north-west. Further residential properties are located to the south-east.
1.5
Air quality within the Isle of Man is generally good, with the main pollutants of concern
currently meeting the relevant air quality objectives. The Isle of Man government has not
declared any air quality management areas (AQMA) within the island.
1.6
This report focuses on the following, offering recommendations for mitigation measures
where necessary:
•
assessing the potential dust impacts on the local area from construction of the
proposed development;
•
assessing the potential impacts on air quality from traffic generated by the proposed
development.
1.7
To assist the reader, a glossary of terminology is included in Appendix B.
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2
POLICY CONTEXT
The UK Air Quality Strategy
2.1
The UK Air Quality Strategy (UKAQS)(1) sets “air quality standard” (AQS) concentrations
for a number of key pollutants that are to be achieved at sensitive receptor locations across
the UK by corresponding “objective” dates. The sensitive locations at which the standards
and objectives apply are those where the population are reasonably expected to be exposed
to specific pollutants over the particular averaging period.
2.2
For those objectives to which an annual mean standard applies, the most common sensitive
receptor locations used to compare concentrations against the standards are areas of
residential housing. It is reasonable to expect that people living in their homes could be
exposed to pollutants over such a period of time.
2.3
Schools and children’s playgrounds are also often used as sensitive locations for comparison
with annual mean objectives due to the increased sensitivity of young people to the effects
of pollution, regardless of whether or not their exposure to the pollution could be over an
annual period. For shorter averaging periods of between 15 minutes, one hour or one day,
the sensitive receptor location can be anywhere where the public could be exposed to the
pollutant over these shorter periods of time.
2.4
The objectives adopted in the UK are based on the Air Quality (England) Regulations 2000(2),
as amended, for the purpose of Local Air Quality Management. These Air Quality Regulations
have been adopted into UK law from the limit values required by European Union Daughter
Directives on air quality.
2.5
The Isle of Man Department of Local Government and the Environment (DLGE) has
adopted air quality objectives in accordance with the AQS for use across the island. A
summary of the air quality objectives relevant to this assessment are included in Appendix C.
2.6
Obligations under the Environment Act 1995 require local authorities to declare an AQMA
at sensitive receptor locations where an objective concentration has been predicted to be
exceeded. In setting an AQMA, the local authority must then formulate an Air Quality Action
Plan (AQAP) to seek to reduce pollution concentrations to values below the objective levels.
2.7
DLGE has not identified any exceedances of the air quality objectives and has not declared
any AQMA on the island.
The Isle of Man Strategic Plan 2016
2.8
The Strategic Plan(3) sets out general policies to guide development and other land uses on
the island. The Plan sets out a number of objectives including the following under 3.3
Environment:
“g) to minimise environmental pollution to air, water and land.”
(1) Air Quality Strategy for England, Scotland, Wales and Northern Ireland (Volumes 1 and 2) July 2007. (2) The Air Quality (England) (Amendment) Regulations 2002 Statutory Instrument 2002 No.3043. (3) The Cabinet Office, The Island Development Plan, The Isle of Man Strategic Plan 2016, Towards a Sustainable Island, February 2016
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Page 3 2.9 The Plan goes on to further set out the following for new development: “Strategic Policy 4: Proposals for development must: c) not cause or lead to unacceptable environmental pollution or disturbance” 2.10 In dealing specifically with air quality, the Plan sets out the following: “Environment Policy 22: Development will not be permitted where it would unacceptably harm the environment and/or the amenity of nearby properties in terms of: i) Pollution of sea, surface water or groundwater; ii) Emissions of airborne pollutants; and iii) Vibration, odour, noise or light pollution. Environment Policy 24: Pollution-sensitive development will only be allowed to be located close to sources of pollution where appropriate measures can be taken to safeguard amenity.” The Isle of Man – Area Plan for the East 2.11 The Area Plan for the East(4) elaborates on the policies set out within the Isle of Man Strategic Plan. The document sets out the vision for the east of the Island and a number of Desired Outcomes to deliver this vision including, the following which is of relevance to this assessment: “v. to ensure that all new development avoids adverse environmental impact and is resource efficient to maintain sustainable growth of the East.”
(4) The Cabinet Office, Area Plan for the East, Written Statement, September 2020
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3
BASELINE ASSESSMENT
3.1
The Isle of Man Government currently does not undertake any monitoring of air pollutants
on the Island. Historically, DLGE has monitored NO2, PM10 and PM2.5 at two automatic
monitoring sites and NO2 using passive diffusion tubes. Monitoring was last undertaken in
2009. Data recorded during 2009 has been used to inform the baseline assessment.
3.2
Details of the 2009 monitoring data has been obtained from the Isle of Man Government
2009 Annual Review of Air Quality Monitoring Data report(5).
Automatic Monitoring
3.3
During 2009 DLGE undertook monitoring of NO2, PM10 and PM2.5 at two automatic
monitoring sites; an urban site at Quarterbridge, Douglas and a rural site at Richmond Hill,
to the south-west of Douglas. Data recorded at both sites for 2009 is provided in Table 3.1.
Table 3.1: Monitoring data from Automatic Monitoring Sites
Monitoring site
Objective
2009
Annual Mean NO2
Quarterbridge
21 ppb (40 µg/m3)
8.45 (16.4 µg/m3)
Richmond Hill
2.49 (4.8 µg/m3)
Exceedances of 1-hour NO2 Objective
Quarterbridge
105 ppb (200 µg/m3) – no more than
18 exceedances
0
Richmond Hill
0
Annual Mean PM10
Quarterbridge
40 µg/m3
15.8 µg/m3
Richmond Hill
16.8 µg/m3
Exceedances of the 24-hour PM10 Objective
Quarterbridge
35 µg/m3 – no more than 35
exceedances
0
Richmond Hill
0
Annual Mean PM2.5
Quarterbridge
25 µg/m3
13.8 µg/m3
3.4
The data presented in Table 3.1 show that concentrations of NO2, PM10 and PM2.5 are less
than 75% of (well below) the relevant objective limits both in the centre of Douglas and at
the more rural location of Richmond Hill, with no exceedances recorded of the short-term
NO2 and PM10 objective limits.
(5) Hyder Consulting (UK) Ltd, Isle of Man Government review of Air Quality, 2009 Annual Review of Air Quality monitoring Data, February 2010
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Non-Automatic Monitoring
3.5
DLGE also operated (through Hyder Consulting) a network of 18 no. NO2 diffusion tube
monitoring sites during 2009. Initially diffusion tube monitoring was carried out in 2006 at
eight sites in Douglas, which identified an exceedance of the annual mean NO2 objective on
Lord Street, Douglas. In response a number of additional monitoring sites were set up
during 2007 and 2008 resulting in a network of ten diffusion tubes being set up to record
concentrations in the vicinity of Lord Street during 2009.
3.6
Annual mean NO2 concentrations recorded at the 18 no. monitoring sites during 2009 is set
out in Table 3.2. The data has been bias-corrected by Hyder using the appropriate
methodology. The location of the monitoring sites in and around Lord Street are shown in
Figure A.3 in Appendix A.
Table 3.2: Monitoring data from NO2 diffusion tubes (µg/m3)
Monitoring site
Location
Year
2019
IM1
Prospect Hill
28.0
IM2
Lord Street
34.0
IM3
High View Road
9.2
IM4
Ballaquayle Estate
11.3
IM21
Richmond Hill Monitoring Site
4.9
IM22
Richmond Hill Monitoring Site
5.2
IM23
Quarterbridge Monitoring Site
16.2
IM24
Quarterbridge Monitoring Site
16.2
LS3
Lord Street opposite IM2
25.6
LS9
On the corner of Lord Street and Quine’s
Corner
31.3
LS11
Outside 107 to 114 Lord Street
30.1
LS12
Outside 87 to 98 Lord Street
28.1
LS13
Lord Street, opposite Barrack Street
24.6
LS14
Outside 51 to 66 Lord Street
28.0
LS15
Barrack Street
24.5
LS16
Lord Street outside the Salvation Army
29.2
LS17
Outside St Matthew’s Church, Ridgeway
Street
15.9
LS18
Outside 13 and 15 Lord Street
35.2
3.7
The data in Table 3.2 show that no exceedances of the 40μg/m3 objective for NO2 were
recorded during 2009 in the centre of Douglas or at the rural monitoring location at
Richmond Hill.
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3.8
Short-term NO2 concentrations cannot be recorded by diffusion tubes. However, Local Air
Quality Management Guidance (LAQM.TG(16))(6) produced by the Department of
Environment, Fisheries and Rural Affairs (DEFRA) in the UK indicates that where the annual
mean is below 60 µg/m3 it can be assumed that exceedances of the 1 hour objective for
NO2 are unlikely to occur. Based on the data set out in Table 3.2, it is unlikely that the short-
term NO2 objective was exceeded at any of the monitoring locations during 2009.
Air Quality in the Vicinity of the Site
3.9
As detailed previously, no monitoring of air pollutants has been carried out on the island
since 2009. The data recorded in 2009 showed concentrations of NO2, PM10 and PM2.5 to
be well below the relevant air quality objectives.
3.10
The main source of emissions affecting air quality on the island and in urban areas is road
traffic. Emission factors and background data used in the prediction of future air quality
concentrations in the UK predict a gradual decline in pollution levels over time due to
improved emissions from new vehicles and the gradual renewal of the vehicle fleet, including
the increase in the number of low emission vehicles within the vehicle fleet. These
projections are supported by a decline in monitored NO2 concentrations across the UK in
recent years.
3.11
On this basis, it is expected that NO2 concentrations within Douglas and the surrounding
area will have declined since monitoring was last undertaken in 2009, so are expected to be
well below the annual mean and short-term objective limits at all the monitoring sites
presented.
3.12
In relation to PM10 and PM2.5, similar declines have not been seen due to a significant
proportion of both pollutants being made up of background sources and emissions from
vehicle and tyre wear. Although it is expected that concentrations will have declined slightly,
the levels are expected to have remained relatively stable since 2009.
3.13
The development site is located on the western edge of Douglas, on the edge of an urban
location. Pollution levels are therefore expected to be higher than recorded at the
Richmond Hill rural monitoring site, but lower than at sites located in the centre of Douglas.
3.14
Based on the above commentary and data recorded in 2009 concentrations of NO2, PM10
and PM2.5 are expected to be well below the relevant objective limits in the vicinity of the
development site.
(6) DEFRA (2016) Local Air Quality Management. Technical Guidance LAQM.TG(16)
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4
ASSESSMENT METHODOLOGY
Guidance
4.1
There is no specific air quality assessment guidance published for use in the Isle of Man. The
following guidance used for assessing air quality impacts un the UK has therefore been used
to determine the methodology used for this assessment:
•
Defra’s LAQM Technical Guidance (LAQM.TG(16)) was used to determine the
overall approach to the assessment.
•
The Environmental Protection UK (EPUK) and Institute of Air Quality Management
(IAQM) guidance on Planning for Air Quality(7) was used to undertake the operational
phase assessment.
•
Guidance published by the IAQM on the Assessment of Dust from Demolition and
Construction(8) was used to assess the risk of dust emissions during the construction
phase of the proposed development.
Construction Phase
Construction Traffic
4.2
A qualitative assessment of potential impacts associated with construction generated traffic
has been carried out taking into consideration the likely volumes of traffic generated, the
anticipated duration of the construction period, mitigation and anticipated routing of
vehicles.
Construction/Fugitive Dust Emissions
4.3
The construction phase of the proposed development will involve a number of activities
that could potentially produce polluting emissions to air. Predominantly, these will be
emissions of dust, however, they could also include releases of odours and/or more harmful
gases and particles. Construction phase activities associated with the Proposed
Development may result in the generation of fugitive dust emissions (i.e. dust emissions
generated by site-specific activities that disperse beyond the construction site boundaries).
4.4
If transported beyond the site boundary, dust can have an adverse impact on local air quality.
The IAQM has published a guidance document for the assessment of demolition and
construction phase impact. The guidance considers the potential for dust nuisance and
impacts to human health and ecosystems to occur due to activities carried out during the
following stages of construction:
•
Demolition - removal of existing structures;
•
Earthworks - soil-stripping, ground-levelling, excavation and landscaping;
•
Construction - activities involved in the provision of a new structure; and
•
Trackout - the transport of dust and dirt from the construction site onto the
public road network where it may be deposited and then re-suspended by
vehicles using the network.
(7) EPUK and IAQM (2017) Land-Use Planning & Development Control: Planning For Air Quality. (8) IAQM (2014) Guidance on the assessment of dust from demolition and construction.
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4.5
A qualitative assessment of air quality impacts due to the release of fugitive dust and
particulates (PM10) during the construction phase was undertaken in accordance with the
methodology detailed in the IAQM guidance.
4.6
The assessment takes into account the nature and scale of the activities undertaken for each
source and the sensitivity of the area to an increase in dust and PM10 levels, thus enabling a
level of risk to be assigned. Risks are described in terms of there being a low, medium or
high risk of dust impacts.
4.7
Once the level of risk has been ascertained, then site specific mitigation proportionate to
the level of risk is identified, and the significance of residual effects determined.
4.8
The IAQM assessment is undertaken where there are:
•
human receptors within 350 metres of the site boundary or within 50 metres of
the route(s) used by construction vehicles on the public highway;
•
human receptors up to 500 metres from the site entrance(s);
•
ecological receptors within 50 metres of the site boundary, or within 50m of the
route(s) used by construction vehicles on the public highway; and
•
ecological receptors up to 500 metres from the site entrance(s).
4.9
It is within these distances that the impacts of dust soiling and increased particulate matter
in the ambient air will have the greatest impact on local air quality at sensitive receptors.
4.10
A summary of the IAQM assessment methodology is provided in Appendix D.
Construction Significance
4.11
The IAQM assessment methodology recommends that significance criteria are only assigned
to the identified risk of dust impacts occurring from a construction activity following the
application of appropriate mitigation measures. For almost all construction activities, the
application of effective mitigation should prevent any significant effects occurring to sensitive
receptors and therefore the residual effects will normally be negligible.
Operational Phase
Introduction
4.12
Potential impacts on air quality due to local traffic emissions have been predicted using the
ADMS dispersion model (version 5.0.0.1, released March 2020, updated September 2020).
This is a commercially-available dispersion model and has been widely validated for this type
of assessment and used extensively to assess air quality across the UK.
4.13
The model uses detailed information regarding traffic flows on the local road network and
local meteorological conditions to predict pollution concentrations at specific locations
selected by the user. Meteorological data from the Isle of Man Meteorological Station for
2021 has been used for the assessment.
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4.14
Quantitative assessment of the impacts on local air quality from road traffic emissions
associated with the operation of the development have been completed against the current
statutory standards and objectives set out in Appendix C for NO2, PM10 and PM2.5
Emissions Data
4.15
The model has been used to predict road specific concentrations of oxides of nitrogen
(NOx) and particulate matter (PM10 and PM2.5) at selected receptors.
4.16
The assessment has predicted air quality during 2021 using emission factors released by
DEFRA in November 2021, provided in the emissions factor toolkit EFTv11(9) to predict
traffic related emissions of PM and NOx.
4.17
Emission factors and background data used in the UK to determine future air quality
concentrations predict a gradual decline in pollution levels over time due to improved
emissions from new vehicles and the gradual renewal of the vehicle fleet. In recent years
the DEFRA emission factors published within the Emission Factor Toolkits (EFT) have been
found to predict lower NOx concentrations in future years compared to concentrations
measures at roadside locations across the UK. However, research carried out by Air Quality
Consultants Ltd (AQC) has now shown that emissions of NOx from vehicles within the
recently released EFT are now matching concentrations recorded at roadside locations
between 2013 to 2019. The report(10) concludes that:
“the EFT is now unlikely to over-state the rate at which NOx emissions decline into the
future at an ‘average’ site in the UK. Indeed, the balance of evidence suggests that, on
average, NOx concentrations are likely to decline more quickly in the future than predicted
by the EFT.”
4.18
This has removed the need for the use of any sensitivity tests for future year scenarios.
4.19
In light of the above the relevant future year EFT emissions data would usually be used to
predict concentrations in the anticipated year the development is completed. However, as
there is no recent local monitoring data available to allow verification of the model results,
2021 emissions data has been used for all scenarios to provide a worst-case assessment of
potential impacts.
Background Concentrations
4.20
The ADMS model estimates concentrations arising as a result of vehicle emissions. It is
necessary to add an estimate of local background concentrations to obtain the total
concentration for comparison against the air quality objectives.
4.21
There is no current background monitoring data available for the Isle of Man. The
assessment has therefore used data recorded in 2009 at the Quarterbridge automatic
monitoring site, in the centre of Douglas, as background concentrations for NO2, PM10 and
PM2.5. The location is considered most representative of the study area, however, as NO2
concentrations are expected to have declined since monitoring was carried out in 2009 and
the site is at a roadside location, the data represents a worst-case assumption of existing
background concentrations.
(9) https://laqm.defra.gov.uk/air-quality/air-quality-assessment/emissions-factors-toolkit/ (10) https://www.aqconsultants.co.uk/news/march-2020/defra%E2%80%99s-emission-factor-toolkit-now-matching-measu
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Page 10 4.22 Details of the background data used within the modelling assessment are provided in Table 3.1. Traffic Data 4.23 Traffic data for use in the assessment have been provided by i-Transport LLP. Data have been provided for a number of scenarios, and for this assessment the following scenarios have been used: • Scenario 2 – existing base traffic plus traffic generated by other committed developments. • Scenario 3A – traffic included in Scenario 2 plus trips generated by the proposed development (Be002(a). • Scenario 4A – traffic included in Scenario 3A plus traffic generated by the adjoining development areas Be002(b)g and Be006g – providing a cumulative assessment of all potential development. 4.24 Criteria set out within the EPUK/IAQM air quality planning guidance indicates a risk of significant effects on local air quality from traffic emissions and therefore indicating the need for more detailed assessment where a development results in a change in light goods vehicles (LGV) of more than 100 per day within or adjacent to an AQMA and more than 500 per day elsewhere. The criteria of heavy duty vehicles (HDV) is a change in HDV of more than 25 per day in locations within or adjacent to an AQMA or more than 100 elsewhere. 4.25 The traffic data provided by I-Transport for scenarios 3A and 4A have been compared against data in scenario 2. The assessment has included those road links where the above criteria is exceeded i.e. a change in LGV of more than 500 per day or a change in HDV of more than 100 per day. 4.26 Data used in the assessment are provided in Appendix E. Model Outputs and Processing 4.27 The ADMS Model has predicted traffic-related annual mean emissions of NOx and PM at a number of receptors along the road links set out in Table E.1 in Appendix E. The background equivalent concentrations have subsequently been added to the model outputs to provide the total concentrations of each pollutant. 4.28 The predicted concentrations of NOx have been converted to NO2 using the LAQM calculator (Version 8.1, released August 2020) available on the Defra air quality website(11). 4.29 As discussed in paragraph 3.8, where the annual mean NO2 concentration is less than 60 µg/m3 then the one-hour mean NO2 objective is unlikely to be exceeded where road transport is the main source of pollution. Therefore, in this assessment the annual mean concentration has been used to screen whether the one-hour mean objective is likely to be achieved as recommended within LAQM.TG(16). Similar to NO2, an annual mean PM10 concentration below 32 µg/m3 is used to screen whether the 24 hour PM10 mean objective is likely to be achieved; this approach is also recommended within LAQM.TG(16).
(11) http://uk-air.defra.gov.uk
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Model Verification
4.30
It is recommended that the model results are compared with measured data to determine
whether the model results need adjusting to more accurately reflect local air quality. This
process is known as verification.
4.31
As there is no current monitoring carried out on the Isle of Man it is not possible to verify
the model results against local data. The process of model verification has not therefore
been carried out. However, the assessment has used a number of approaches so that a
worst-case prediction of potential impacts is provided including low traffic speeds, which
result in higher traffic emissions, the use of 2009 roadside monitoring data as background
data and the use of 2021 emission factors to predict the impact of the development in the
anticipated year of completion.
Selection of Receptors
4.32
LAQM.TG(16) describes in detail typical locations where consideration should be given to
pollutants defined in the Regulations. Generally, the guidance suggests that all locations
“where members of the public are regularly present” should be considered. At such locations,
members of the public would be exposed to pollution over the time that they are present,
and the most suitable averaging period of the pollutant needs to be used for assessment
purposes.
4.33
For instance, on a footpath, where exposure would be transient for the duration of passage
along that path, comparison with short-term standards may be relevant, i.e. 15 minute mean
or 1 hour mean. In a school, or adjacent to a private dwelling, however; where exposure
may be for longer periods, comparison with long-term standards may be most appropriate,
such as 24 hour mean or annual mean. In general terms, concentrations associated with
long-term standards are lower than short-term standards owing to the chronic health effects
associated with exposure to low level pollution for longer periods of time.
4.34
For the completion of this assessment, air quality has been predicted at sensitive receptors
(residential properties and educational facilities) located adjacent to the road links set out in
Table E.1 in Appendix E. Each receptor has been selected to represent worst-case exposure
to local traffic emissions.
4.35
The details of each receptor are presented below in Table 4.1.
Table 4.1: Location of receptors used in modelling assessment
Receptor
Number
Receptor Location
Road Link
OS Grid
Reference
Receptor
Height (m)
R1
Anagh Loar Rd
Link 12
235733, 475565
1.5
R2
South of New Castledown Rd
Link 12
235627, 475383
1.5
R3
Springfield Lodge
Link 13
235984, 475751
1.5
R4
Bellaughton Close
Link 19
(Castledown
Rd)
236340, 476052
1.5
R5
Braddon Primary Sch
Link 28
236480, 477244
1.5
R6
River Walk
Link 28
236465, 477211
1.5
R7
The Church View
Link 29
236395, 477377
1.5
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Receptor
Number
Receptor Location
Road Link
OS Grid
Reference
Receptor
Height (m)
R8
Quarterbridge Rd
Link 39
236833, 476311
1.5
R9
Quarterbridge Rd
Link 39
236911, 476385
1.5
R10
Cooil Drive
Link 8
235194, 475466
1.5
R11
Close Moore
Link 9
235299, 475348
1.5
R12
Quarterbridge Rd
Link 38
237105, 476510
1.5
R13
Quarterbridge Rd
Link 38
237179, 476590
1.5
R14
The Gardens, Qaurterbridge
Rd
Link 37
237471, 476783
1.5
R15
Thie Solys
Link 37
237452, 476796
1.5
R16
Mile End Court
Link 40
236868, 475858
1.5
R17
Pleasington Villa, Peel Rd
Link 45
237482, 475524
1.5
R18
Braddon Bridge
Link 26
236541, 476886
1.5
R19
Braddon Bridge
Link 27
236512, 477088
1.5
R20
Braddon Rd
Link 31
236278, 477767
1.5
R21
Ballafletcher Rd
Link 33
236889, 477603
1.5
R22
Ballafletcher Rd
Link 34
237091, 477669
1.5
R23
Willowbrook Gardens
Link 17
235408, 476525
1.5
R24
Vicarage Rd
Link 17
235730, 476563
1.5
R25
Vicarage Park
Link 18
236057, 476654
1.5
R26
Vicarage Rd
Link 19
(Vicarage Rd)
236175, 476701
1.5
R27
Vicarage Rd
Link 19
(Vicarage Rd)
236271, 476735
1.5
Significance Criteria
4.36
The guidance issued by EPUK and IAQM relates to air quality considerations within the
planning process and sets criterion that identify the need for an air quality assessment, the
type of air quality assessment required, and the significance of any predicted impact.
4.37
The guidance suggests expressing the magnitude of incremental change in concentrations as
a proportion of an Air Quality Assessment Level (AQAL) such as the air quality objectives
set out in Table 3.1.
4.38
The significance of impact is then identified based on the incremental change in the context
of the new total concentrations and its relationship with the assessment criteria, noting
whether the impact is adverse or beneficial based on a positive or negative change in
concentrations. The criteria suggested for assigning significance is set out in Table 4.1.
4.39
To assess the overall significance of the predicted impact the assessment draws on the
approach used for undertaking environmental impact assessments where a moderate and
major impact is deemed to be significant while a minor or negligible impact would not be
classed as significant.
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Page 13 Table 4.2: Impact descriptors for individual receptors Long-term Average Concentration at Receptor in Assessment Year % Change in Concentrations Relative to Air Quality Assessment Level (AQAL) 1 2-5 6-10
10 75% or less of AQAL Negligible Negligible Slight Moderate 76-94% of AQAL Negligible Slight Moderate Moderate 95-102% of AQAL Slight Moderate Moderate Substantial 103-109% of AQAL Moderate Moderate Substantial Substantial 110% of AQAL Moderate Substantial Substantial Substantial AQAL – Air Quality Assessment Level which in this assessment refers to the Air Quality Objectives set out in Appendix C. 4.40 In assessing significance, the following have also been taken into consideration: • the percentage change in concentration should be rounded to a whole number; • the table should only be used with annual mean concentrations; • the descriptors are for individual receptors only: overall significance should be based on professional judgment; • when defining the concentrations as a percentage of the AQAL use the 'without scheme' concentration where there is a decrease in pollutant concentrations and the 'with scheme' concentrations for an increase; • the total concentration categories reflect the degree of potential harm by reference to the AQAL value. At exposure, less than 75% of this value, i.e. well below, the degree of harm is likely to be small. As exposure approaches and exceeds the AQAL, the degree of harm increases. This change naturally becomes more important when the result is an exposure that is approximately equal to, or greater than the AQAL; • it is unwise to ascribe too much accuracy to incremental changes or background concentrations, and this is especially important when total concentrations are close to the AQAL. For a given year, it is impossible to define the new total concentrations without recognising the inherent uncertainty, which is why there is a category that has a range around the AQAL, rather than being exactly equal to it. Consultation 4.41 The Isle of Man Government Environmental protection team was contacted by email on 22nd December 2021 to agree the proposed scope of assessment. 4.42 Subsequent correspondence from relevant members of the Environmental Protection Team confirmed the only monitoring available for the Island is from 2009. However, no correspondence has been received confirming agreement with the proposed scope of works.
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5
CONSTRUCTION PHASE IMPACTS
Construction Traffic
5.1
During construction of the proposed development, lorries will require access to the site to
deliver and remove materials; earthmoving plant and other mobile machinery may also work
on site including generators and cranes. These machines produce exhaust emissions; of
particular concern are emissions of NO2 and PM10.
5.2
The volume of construction traffic generated by the proposed development is not available,
however, there is likely to be a significant fluctuation in the numbers of vehicle movements
associated with the proposed development throughout the construction period. When
Averaged over a year these vehicle movements will be significantly lower than peak
movements.
5.3
Furthermore, volumes of construction traffic generated by the proposed development are
anticipated to be lower than volumes of the development-generated operational traffic,
which is typical for development of this size and type. This being the case, based on
professional judgment, it is reasonable to expect that impacts on local air quality associated
with emissions from construction traffic will be lower than as a result of operational traffic.
5.4
Notwithstanding the above, any potential impacts associated with construction traffic will
be temporary in nature. Furthermore, measures will be set out within a Construction
Environmental Management Plan (CEMP) to minimise emissions associated with construction
vehicles, thus further reducing any potential impacts.
5.5
Taking into consideration the above, it is judged that the overall effect of construction
vehicles on existing receptors are likely to be negligible and therefore not significant.
Construction Dust
Site and Surroundings
5.6
A summary of the proposed development and the surrounding area is provided in Section
1 of this report.
5.7
The site covers an area of 19 hectares and there are residential properties located within
350 metres of the Site. An assessment of construction related impacts in relation to human
receptors has therefore been undertaken.
5.8
Dust emissions from construction activities are unlikely to result in significant impacts on
ecologically-sensitive receptors beyond 50 metres from the site boundary. There are no
sensitive ecological sites within 50 metres of the site boundary. Impacts on ecological
receptors has therefore been excluded from this assessment.
5.9
As discussed in Section 3, PM10 concentrations in the vicinity of the site are expected to be
below the relevant objective limits (see Table 3.1 and paragraphs 3.9 to 3.14). The data
indicates background concentrations in the region of 15-17 µg/m3 in the area. Based on
professional judgment, it is anticipated that PM10 concentrations at the site and at adjacent
properties are unlikely to be much higher than background, therefore PM10 concentrations
are expected to be below 24µg/m3.
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5.10
The precise behaviour of the dust, its residence time in the atmosphere, and the distance it
may travel before being deposited depends upon a number of factors, including wind
direction and strength, local topography and the presence of intervening structures
(buildings etc.) that may intercept dust before it reaches sensitive locations. Furthermore,
dust is naturally suppressed by rainfall.
5.11
A windrose from the Exeter Meteorological Station is provided in Figure A.4, Appendix A,
which shows that prevailing winds are from the south-west. Areas most consistently
affected by dust are influenced by prevailing winds that are generally located downwind of
an emission source. Therefore, the highest risk of impacts would occur at receptors to the
north-east of the site, Land-uses to the north-east of the site are mainly commercial
premises and places of work that would have low sensitivity to dust effects. However, these
areas include short-term car parks which are of medium sensitivity to dust effects.
Dust Emission Magnitude
5.12
With reference to the criteria detailed in Appendix B, the dust emission magnitude for each
of the category’s demolition, earthworks, construction and trackout have been determined.
These have been summarised in Table 5.1.
Table 5.1: Dust emission magnitude
Activity
Criteria
Dust Emission
Magnitude
Demolition
Less than 20,000 m3, less than 10 m above
ground
Small
Earthworks
Building site area approximately 10,000 m2,
10 HDV on site.
Large
Construction Building volume between 25,000 - 100,000m3, main construction material brick and concrete Medium Trackout Expected to be up to 20-30 HDV (>3.5t) movements per day Medium Sensitivity of the Area 5.13 Using the criteria set out in Tables D.2 to D.4 in Appendix D, the sensitivity of the surrounding area to impacts from dust emissions has been determined and are set out in Table 5.2. Dust Soiling 5.14 There are two residential properties located to the north-west of the site and further properties to the south-east on Cooil Road. There are fewer than ten properties within 20 metres of the Site boundary. However, there are short-term car parks associated with commercial premises to the north and north-east. These are considered to be of medium sensitivity. The sensitivity of the surrounding area in relation to dust soiling effects is therefore considered to be medium. 5.15 It is expected that there will be up to 20-30 HDV (>3.5t) movements per day on any given road link during the construction phase which will travel to and from the site along the adjoining access roads via Cooil Road. As a general guide, significant impacts from trackout may occur up to 500 metres from large sites, 250 metres from medium sites and 50 metres from small sites, as measured from the site exit. There are no residential properties located
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Page 16
within 20 metres of the roadside within 250 metres of the site access points. However,
there are short-term car parks immediately adjacent to the access roads and Cooil Road.
The sensitivity of the area to dust soiling effects from trackout is therefore considered to be
medium.
PM10 Effects
5.16
As previously discussed, annual mean PM10 concentrations in the vicinity of the Site are
expected to be below 24 µg/m3. Based on the proximity of sensitive receptors to the site
boundary and the local concentrations of PM10 the sensitivity of the surrounding area is
considered to be low with regards human health impacts.
Table 5.2: Sensitivity of surrounding area
Source
Dust Soiling
PM10 Effects
Demolition
Medium
Low
Earthworks
Medium
Low
Construction
Medium
Low
Trackout
Medium
Low
Risk of Impacts
5.17
The dust emission magnitude as set out in Table 5.1 have been combined with the sensitivity
of the area set out in Table 5.2, to determine the risk of both dust soiling and human health
impacts, assuming no mitigation measures applied at site. The risk of impacts associated
with each activity is provided in Table 5.3 and has been used to identify site-specific
mitigation measures, which are discussed in Paragraphs 5.18 to 5.21 and set out in
Appendix F.
Table 5.3: Summary of effects without mitigation
Source
Dust Soiling Effects
PM10 Effects
Demolition
Low
Negligible
Earthworks
Medium
Negligible
Construction
Medium
Negligible
Trackout
Medium
Negligible
Site-Specific Mitigation
5.18
The control of dust emissions from construction site activities relies upon management
provisions and mitigation techniques to reduce emissions of dust and limit dispersion.
Where dust emission controls have been used effectively, large-scale operations have been
successfully undertaken without impacts to nearby properties.
5.19
The proposed development has been identified as a medium risk site for dust soiling effects
during earthworks, construction and trackout and a low risk site during demolition as set
out in Table 5.3.
5.20
The developer should therefore implement appropriate dust and pollution control
measures as set out within the IAQM guidance. A summary of these measures is set out in
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Page 17 Appendix F. The proposed measures should be set out within a CEMP and approved by Isle of Man Government prior to commencement of any work on site. 5.21 Following implementation of the measures recommended for inclusion within the CEMP the impact of emissions during construction of the proposed development would be negligible. Residual Effects 5.22 After implementing the mitigation measures detailed in Appendix F, the significance of impacts associated with the construction phase will be reduced and the residual significance of impact for the construction phase is expected to be Negligible.
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6
OPERATIONAL PHASE IMPACTS
Impact of Development
Nitrogen Dioxide Concentrations
6.1
Annual mean NO2 concentrations predicted at the selected receptor locations are
presented in Table 6.1.
Table 6.1: Predicted annual mean NO2 concentrations at existing receptors
(µg/m3)
Receptor
Scenario 2
Scenario 3A
Change due to
Proposed
Development as a %
of AQAL
Significance of
Impact
R1
17.0
17.1
0
Negligible
R2
18.6
18.9
1
Negligible
R3
18.0
18.2
0
Negligible
R4
18.1
18.3
0
Negligible
R5
19.0
19.1
0
Negligible
R6
17.8
17.8
0
Negligible
R7
17.4
17.4
0
Negligible
R8
18.1
18.1
0
Negligible
R9
18.3
18.3
0
Negligible
R10
16.6
16.6
0
Negligible
R11
17.6
17.1
-1
Negligible
R12
19.4
19.5
0
Negligible
R13
17.4
17.5
0
Negligible
R14
18.9
19.0
0
Negligible
R15
17.3
17.3
0
Negligible
R16
18.3
18.4
0
Negligible
R17
18.0
18.0
0
Negligible
R18
19.3
19.3
0
Negligible
R19
17.9
17.9
0
Negligible
R20
18.0
18.1
0
Negligible
R21
18.5
18.5
0
Negligible
R22
19.7
19.7
0
Negligible
R23
17.8
17.8
0
Negligible
R24
17.3
17.3
0
Negligible
R25
17.9
17.8
0
Negligible
R26
18.9
18.8
0
Negligible
R27
17.9
17.8
0
Negligible
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6.2
The modelling assessment is predicting annual mean NO2 concentrations well below the
annual mean objective of 40 µg/m3 (AQAL) at all the selected receptors under both
Scenario 2 and Scenario 3A.
6.3
Traffic generated by the operational development is predicted to increase annual mean NO2
concentrations by no more than 0.3 µg/m3, the highest impact predicted at receptor R2,
adjacent to Link 12. This equates to an increase of no more than 1 % of the AQAL. Based
on the criteria set out in Table 4.2, the predicted increase in NO2 is judged to be of negligible
significance given that concentrations will be well below the AQAL under scenario 3A.
6.4
With predicted annual mean concentrations being less than 60 µg/m3, it is expected that the
hourly objective of 200 µg/m3 will also be met at all locations and impacts in terms of short-
term NO2 will be negligible.
PM10 Concentrations
6.5
Predicted annual mean PM10 concentrations at the selected existing receptor locations are
presented in Table 6.2.
Table 6.2: Predicted annual mean PM10 concentrations at existing receptors
(µg/m3)
Receptor
Scenario 2
Scenario 3A
Change due to
Proposed
Development as a
% of AQAL
Significance of
Impact
R1
15.9
16.0
0
Negligible
R2
16.3
16.4
0
Negligible
R3
16.2
16.2
0
Negligible
R4
16.3
16.3
0
Negligible
R5
16.5
16.5
0
Negligible
R6
16.2
16.2
0
Negligible
R7
16.1
16.1
0
Negligible
R8
16.3
16.3
0
Negligible
R9
16.3
16.3
0
Negligible
R10
15.9
15.9
0
Negligible
R11
16.1
16.0
0
Negligible
R12
16.6
16.6
0
Negligible
R13
16.1
16.1
0
Negligible
R14
16.4
16.5
0
Negligible
R15
16.1
16.1
0
Negligible
R16
16.3
16.3
0
Negligible
R17
16.2
16.2
0
Negligible
R18
16.5
16.5
0
Negligible
R19
16.2
16.2
0
Negligible
R20
16.2
16.2
0
Negligible
R21
16.4
16.4
0
Negligible
R22
16.6
16.6
0
Negligible
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Receptor
Scenario 2
Scenario 3A
Change due to
Proposed
Development as a
% of AQAL
Significance of
Impact
R23
16.2
16.2
0
Negligible
R24
16.1
16.1
0
Negligible
R25
16.2
16.2
0
Negligible
R26
16.4
16.4
0
Negligible
R27
16.1
16.1
0
Negligible
6.6
The ADMS model is predicting annual mean PM10 concentrations at less than 75% of the
AQAL of 40 µg/m3 at all receptor locations in both scenarios.
6.7
Traffic generated by the operational development is predicted to increase annual mean PM10
concentrations by no more than 0.1 µg/m3, which is less than 1% of the AQAL and therefore
judged as a negligible impact based on criteria set out in Table 4.2.
6.8
As annual mean concentrations are below 32 µg/m3 at all the selected receptors,
concentrations are predicted to be meeting the 24 hour objective limit of 50 µg/m3 and
impacts on short-term PM10 will also be negligible.
PM2.5 Concentrations
6.9
Predicted annual mean PM2.5 concentrations at the selected existing receptor locations are
presented in Table 6.3.
Table 6.3: Predicted annual mean PM2.5 concentrations at existing receptors
(µg/m3)
Receptor
Scenario 2
Scenario 3A
Change due to
Proposed
Development as a %
of AQAL
Significance of
Impact
R1
13.9
13.9
0
Negligible
R2
14.1
14.1
0
Negligible
R3
14.0
14.0
0
Negligible
R4
14.1
14.1
0
Negligible
R5
14.2
14.2
0
Negligible
R6
14.0
14.0
0
Negligible
R7
14.0
14.0
0
Negligible
R8
14.1
14.1
0
Negligible
R9
14.1
14.1
0
Negligible
R10
13.9
13.9
0
Negligible
R11
14.0
13.9
0
Negligible
R12
14.3
14.3
0
Negligible
R13
14.0
14.0
0
Negligible
R14
14.2
14.2
0
Negligible
R15
14.0
14.0
0
Negligible
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Receptor
Scenario 2
Scenario 3A
Change due to
Proposed
Development as a %
of AQAL
Significance of
Impact
R16
14.1
14.1
0
Negligible
R17
14.1
14.1
0
Negligible
R18
14.2
14.2
0
Negligible
R19
14.1
14.1
0
Negligible
R20
14.1
14.1
0
Negligible
R21
14.1
14.1
0
Negligible
R22
14.3
14.3
0
Negligible
R23
14.0
14.0
0
Negligible
R24
14.0
14.0
0
Negligible
R25
14.1
14.1
0
Negligible
R26
14.2
14.2
0
Negligible
R27
14.0
14.0
0
Negligible
6.10
The ADMS model is predicting annual mean PM2.5 concentrations at less than 75% of the
AQAL of 25 µg/m3 at all receptor locations in both scenarios.
6.11
Traffic generated by the operational development is predicted to increase annual mean
PM2.5 concentrations by no more than 0.1 µg/m3, which is less than 1% of the AQAL and
therefore judged as a negligible impact based on criteria set out in Table 4.2.
Cumulative Impacts
Nitrogen Dioxide Concentrations
6.12
Annual mean NO2 concentrations predicted at the selected existing receptor locations are
presented in Table 6.4.
Table 6.4: Predicted annual mean NO2 concentrations at existing receptors
(µg/m3)
Receptor
Scenario 2
Scenario 4A
Change due to
Proposed
Development as a
% of AQAL
Significance of
Impact
R1
17.0
17.2
0
Negligible
R2
18.6
19.2
1
Negligible
R3
18.0
18.4
1
Negligible
R4
18.1
18.5
1
Negligible
R5
19.0
19.3
1
Negligible
R6
17.8
17.9
0
Negligible
R7
17.4
17.5
0
Negligible
R8
18.1
18.2
0
Negligible
R9
18.3
18.4
0
Negligible
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Receptor
Scenario 2
Scenario 4A
Change due to
Proposed
Development as a
% of AQAL
Significance of
Impact
R10
16.6
17.2
2
Negligible
R11
17.6
18.2
2
Negligible
R12
19.4
19.5
0
Negligible
R13
17.4
17.5
0
Negligible
R14
18.9
18.9
0
Negligible
R15
17.3
17.3
0
Negligible
R16
18.3
18.5
0
Negligible
R17
18.0
18.1
0
Negligible
R18
19.3
19.5
1
Negligible
R19
17.9
18.0
0
Negligible
R20
18.0
18.3
1
Negligible
R21
18.5
18.6
0
Negligible
R22
19.7
19.8
0
Negligible
R23
17.8
18.0
0
Negligible
R24
17.3
17.4
0
Negligible
R25
17.9
18.1
1
Negligible
R26
18.9
21.9
8
Slight adverse
R27
17.9
19.9
5
Negligible
6.13
The modelling assessment is predicting annual mean NO2 concentrations well below the
annual mean objective of 40 µg/m3 (AQAL) at all the selected receptors under both Scenario
2 and Scenario 4A.
6.14
Traffic generated by the cumulative developments is predicted to increase annual mean NO2
concentrations by up to 3.0 µg/m3, the highest impact predicted at receptor R26, located
adjacent to Link 19, Vicarage Road. This equates to an increase of 8 % of the AQAL at this
location, with a 5% increase at receptor 27, also located on Vicarage Road. Based on the
criteria set out in Table 4.2, the predicted cumulative impact on NO2 is judged to be slight
adverse at receptor R26 and negligible at R27. At all other receptors the cumulative impact
would be negligible.
6.15
Predicted annual mean concentrations would remain at less than 60 µg/m3 therefore
cumulative impacts on short-term NO2 are predicted to be negligible.
PM10 Concentrations
6.16
Predicted annual mean PM10 concentrations at the selected existing receptor locations are
presented in Table 6.5.
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Table 6.5: Predicted annual mean PM10 concentrations at existing receptors
(µg/m3)
Receptor
Scenario 2
Scenario 4A
Change due to
Proposed
Development as a
% of AQAL
Significance of
Impact
R1
15.9
16.0
0
Negligible
R2
16.3
16.5
0
Negligible
R3
16.2
16.3
0
Negligible
R4
16.3
16.4
0
Negligible
R5
16.5
16.6
0
Negligible
R6
16.2
16.2
0
Negligible
R7
16.1
16.1
0
Negligible
R8
16.3
16.3
0
Negligible
R9
16.3
16.3
0
Negligible
R10
15.9
15.9
0
Negligible
R11
16.1
16.0
0
Negligible
R12
16.6
16.6
0
Negligible
R13
16.1
16.1
0
Negligible
R14
16.4
16.5
0
Negligible
R15
16.1
16.1
0
Negligible
R16
16.3
16.3
0
Negligible
R17
16.2
16.2
0
Negligible
R18
16.5
16.5
0
Negligible
R19
16.2
16.2
0
Negligible
R20
16.2
16.2
0
Negligible
R21
16.4
16.4
0
Negligible
R22
16.6
16.6
0
Negligible
R23
16.2
16.2
0
Negligible
R24
16.1
16.1
0
Negligible
R25
16.2
16.2
0
Negligible
R26
16.4
17.2
2
Negligible
R27
16.1
16.6
1
Negligible
6.17
The ADMS model is predicting annual mean PM10 concentrations at less than 75% of the
AQAL of 40 µg/m3 at all receptor locations in both scenarios.
6.18
Traffic generated by the cumulative developments is predicted to increase annual mean
PM10 concentrations by up to 0.2 µg/m3, which equates to 2% of the AQAL. Based on
criteria set out in Table 4.2, the cumulative impacts are predicted to be negligible on annual
mean PM10.
6.19
As annual mean PM10 concentrations would remain below 32 µg/m3 the cumulative impacts
on short-term PM10 will also be negligible.
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PM2.5 Concentrations
6.20
Predicted annual mean PM2.5 concentrations at the selected existing receptor locations are
presented in Table 6.6.
Table 6.6: Predicted annual mean PM2.5 concentrations at existing receptors
(µg/m3)
Receptor
Scenario 2
Scenario 4A
Change due to
Proposed
Development as a %
of AQAL
Significance of
Impact
R1
13.9
13.9
0
Negligible
R2
14.1
14.2
0
Negligible
R3
14.0
14.1
0
Negligible
R4
14.1
14.1
0
Negligible
R5
14.2
14.2
0
Negligible
R6
14.0
14.0
0
Negligible
R7
14.0
14.0
0
Negligible
R8
14.1
14.1
0
Negligible
R9
14.1
14.1
0
Negligible
R10
13.9
13.9
0
Negligible
R11
14.0
13.9
0
Negligible
R12
14.3
14.3
0
Negligible
R13
14.0
14.0
0
Negligible
R14
14.2
14.2
0
Negligible
R15
14.0
14.0
0
Negligible
R16
14.1
14.1
0
Negligible
R17
14.1
14.1
0
Negligible
R18
14.2
14.2
0
Negligible
R19
14.1
14.1
0
Negligible
R20
14.1
14.1
0
Negligible
R21
14.1
14.1
0
Negligible
R22
14.3
14.3
0
Negligible
R23
14.0
14.0
0
Negligible
R24
14.0
14.0
0
Negligible
R25
14.1
14.1
0
Negligible
R26
14.2
14.6
2
Negligible
R27
14.0
14.3
1
Negligible
6.21
The ADMS model is predicting annual mean PM2.5 concentrations at less than 75% of the
AQAL of 25 µg/m3 at all receptor locations in both scenarios.
6.22
Traffic generated by the cumulative developments is predicted to increase annual mean
PM10 concentrations by up to 0.4 µg/m3, which equates to 2% of the AQAL. The cumulative
impacts are therefore judged to be negligible.
[Page 28] An Air Quality Assessment for Cooil Road, Douglas, Isle of Man On behalf of Eden Park Developments
RE00083 – Rep 1
Resound Environment
Page 25 Mitigation 6.23 The modelling assessment has found that impacts associated with operational traffic, both by the proposed development and as a result of cumulative impacts from the wider development area to be not significant therefore no mitigation measures are considered necessary. Residual Effects 6.24 As the modelling assessment has predicted an overall negligible impact on local air quality residual effects will also be negligible.
[Page 29] An Air Quality Assessment for Cooil Road, Douglas, Isle of Man On behalf of Eden Park Developments
RE00083 – Rep 1
Resound Environment
Page 26
7
DISCUSSION
7.1
Air quality across the Isle of Man has been found to be meeting relevant air quality objectives
and the Isle of Man Government has not declared any AQMAs.
7.2
Historical monitoring data has shown concentrations of NO2, PM10 and PM2.5 to be well
below the relevant air quality objectives within Douglas and the surrounding area.
7.3
An air quality assessment was principally required to assess the following, for planning:
•
potential impacts of the construction phase of the development; and
•
potential operational impacts of generated traffic on nearby sensitive receptors.
7.4
The construction phase of the development could potentially give rise to emissions that
cause dust soiling effects on adjacent uses. Following the IAQM guidance, the construction
phase of the proposed development can be considered to be Medium risk. After the
implementation of the mitigation measures listed in Appendix F, emissions from the
construction programme will be reduced and the residual significance of impact for the
construction phase is expected to be Negligible.
7.5
The operational development is expected to generate additional vehicle movements on the
adjacent road network. The increase in traffic on some road links was found to be exceeding
the screening criteria set out in the EPUK/IAQM air quality planning guidance indicating a
risk of significant impacts on local air quality. A detailed assessment of operational traffic
impacts was therefore undertaken.
7.6
The detailed assessment used detailed dispersion modelling to predict emissions associated
with local traffic emissions and to determine the impact of these emissions on locally
sensitive receptors.
7.7
The modelling assessment found concentrations of NO2, PM10 and PM2.5 would remain well
below the relevant air quality objectives at all sensitive receptors following operation of the
proposed development. Impacts on local air quality as a result of the development would
not therefore be significant.
7.8
The assessment also considered impacts associated with development in the wider area,
assessing the cumulative impact of traffic generated by this additional development. The
cumulative impact on local air quality was also found to be not significant.
[Page 30] An Air Quality Assessment for Cooil Road, Douglas, Isle of Man On behalf of Eden Park Developments
RE00083 – Rep 1
Resound Environment
Page 27
8
CONCLUSION
8.1
Eden Park Developments has appointed Resound Environment, a trading name of Resound
Acoustics Limited, to undertake an air quality assessment (AQA) for the proposed
commercial development on land off Cooil Road, Douglas, Isle of Man.
8.2
It is inevitable that with any development, construction activities could cause some
disturbance to those nearby and the assessment has predicted a minor to moderate adverse
impact prior to the implementation of any on-site mitigation. However, following the
implementation of appropriate mitigation measures, which would be set out within a CEMP,
impacts associated with the construction of the development are likely to be insignificant.
8.3
The ADMS dispersion model has been used to predict the impact of the operational
development on local NO2, PM10 and PM2.5 concentrations. The assessment has predicted
an overall negligible impact on NO2, PM10 and PM2.5 concentrations as a result of traffic
generated by the development on sensitive receptors located in Douglas.
8.4
The cumulative impact of traffic generated by the development in conjunction with
development in the wider area was also found to be negligible.
8.5
The proposals meet the requirements set out current planning policy.
8.6
Based on the results of the assessment air quality does not pose a constraint to development
of the site as proposed.
[Page 32]
APPENDIX A
Appendix A – Figures
Figure A.1: Site Location Plan
[Page 34]
APPENDIX A
Figure A.3: Location of Diffusion Tube Sites in Douglas12
(12) Hyder, Isle of Man Government Review of Air Quality, 2009 Annual Review of Air Quality Monitoring Data, February 2010
[Page 36] APPENDIX B
Appendix B – Air Quality Terminology
Table B.1: Air quality terminology
Term
Definition
AEA
AEA Energy and Environment
Air quality
objective
Policy target generally expressed as a maximum ambient concentration to be achieved,
either without exception or with a permitted number of exceedances within a specific
timescale (see also air quality standard).
Air quality standard
The concentrations of pollutants in the atmosphere which can broadly be taken to
achieve a certain level of environmental quality. The standards are based on the
assessment of the effects of each pollutant on human health including the effects on
sensitive sub groups (see also air quality objective).
Annual mean
The average (mean) of the concentrations measured for each pollutant for one year.
Usually this is for a calendar year, but some species are reported for the period April to
March, known as a pollution year. This period avoids splitting winter season between
two years, which is useful for pollutants that have higher concentrations during the
winter months.
AQAP
Air Quality Action Plan.
AQMA
Air Quality Management Area.
AQS
Air Quality Standard
ASR
Annual Status Report
Defra
Department for Environment, Food and Rural Affairs.
Exceedance
A period of time where the concentrations of a pollutant is greater than, or equal to, the
appropriate air quality standard.
HDV
Heavy Duty Vehicles: Heavy Goods Vehicles and buses.
HGV
Heavy Goods Vehicles
LAQM
Local Air Quality Management.
LDV
Light Duty Vehicles: motorcycles, cars and Light Goods Vehicles.
NBC
Northampton Borough Council
NLES
Northampton Low Emission Strategy
NO
Nitrogen monoxide, a.k.a. nitric oxide.
NO2
Nitrogen dioxide.
NOx
Nitrogen oxides.
Percentile
The percentage of results below a given value.
PM10
Particulate matter with an aerodynamic diameter of less than 10 micrometres.
PM2.5
Particulate matter with an aerodynamic diameter of less than 2.5 micrometres.
µg/cu.m. micrograms
per cubic metre
A measure of concentration in terms of mass per unit volume. A concentration of
1µg/cu.m. means that one cubic metre of air contains one microgram (millionth of a
gram) of pollutant.
UKAQS
United Kingdom Air Quality Strategy.
[Page 37] APPENDIX C
2020 As objective. Target: 2010
[Page 38] APPENDIX D
Appendix D: IAQM Construction Dust Assessment Procedure
To assess the potential impacts, the activities on construction sites are divided into four categories.
These are:
•
demolition (removal of existing structures);
•
earthworks (soil-stripping, ground-levelling, excavation and landscaping);
•
construction (activities involved in the provision of a new structure); and
•
trackout (the transport of dust and dirt from the construction site onto the public road
network where it may be deposited and then re-suspended by vehicles using the network).
For each activity, the risk of dust annoyance, health and ecological impact is determined using three
risk categories: low, medium and high risk. The risk category may be different for each of the four
activities. The risk magnitude identified for each of the construction activities is then compared to the
number of sensitive receptors in the near vicinity of the site in order to determine the risks posed by
the construction activities to these receptors.
Step 1: Screen the Need for an Assessment
The first step is to screen the requirement for a more detailed assessment. An assessment is required
where there is:
•
a ‘human receptor’ within 350m of the boundary of the site or 50m of the route(s) used by
construction vehicles on the public highway, up to 500m from the site entrance(s); and/or
•
an ‘ecological receptor’ within 50m of the boundary of the site; or 50m of the route(s) used
by the construction vehicles on the public highway, up to 500m from the site entrance(s).
Step 2A: Define the Potential Dust Emission Magnitude
This is based on the scale of the anticipated works and the proximity of nearby receptors. The risk is
classified as small, medium or large for each of the four categories.
Demolition: The potential dust emission classes for demolition are:
•
Large: Total building volume >50,000m3, potentially dusty construction material (e.g.
Concrete), on site crushing and screening, demolition activities >20m above ground level;
•
Medium: total building volume 20,000m3 – 50,000m3, potentially dusty construction
material, demolition activities 10-20 m above ground level; and
•
Small: total building volume <20,000m3, construction material with low potential for dust
release (e.g. metal cladding or timber), demolition activities <10m above ground,
demolition during wetter months.
Earthworks: This involves excavating material, haulage, tipping and stockpiling. The potential dust
emission classes for earthworks are:
•
Large: Total site area >10,000m2, potentially dusty soil type (e.g. clay, which will be prone
to suspension when dry due to small particle size), >10 heavy earth moving vehicles active
at any one time, formation of bunds >8m in height, total material moved >100,000 tonnes;
•
Medium: Total site area 2,500 m2 – 10,000m2, moderately dusty soil (e.g. silt), 5 – 10 heavy
earth moving vehicles active at any one time, formation of bunds 4m – 8m in height, total
material moved 20,000 tonnes- 100,000 tonnes; and
[Page 39] APPENDIX E
• Small: Total site area <2,500m2, soil type with large grain size (e.g. sand), <5 heavy earth moving vehicles active at any one time, formation of bunds <4 m in height, total material moved <20,000 tonnes, earthworks during wetter months. Construction: The important issues here when determining the potential dust emission magnitude include the size of the building(s)/infrastructure, method of construction, construction materials, and duration of build. The categories are: • Large: Total building volume >100,000m3, on site concrete batching, sandblasting; • Medium: Total building volume 25,000m3 – 100,000m3, potentially dusty construction material (e.g. concrete), on site concrete batching; and • Small: Total building volume <25,000m3, construction material with low potential for dust release (e.g. metal cladding or timber). Trackout: The risk of impacts occurring during trackout is predominantly dependent on the number of vehicles accessing the Site on a daily basis. However, vehicle size and speed, the duration of activities and local geology are also factors which are used to determine the emission class of the Site as a result of trackout. The categories are: • Large: >50 HDV (>3.5t) outward movements in any one day, potentially dusty surface material (e.g. high clay content), unpaved road length > 100m; • Medium: 10-50 HDV (>3.5t) outward movements in any one day, moderately dusty surface material (e.g. high clay content, unpaved road length 50-100m; and • Small: <10 HDV (>3.5t) outward movements in any one day, surface material with low potential for dust release, unpaved road length >50m. Step 2B: Defining the Sensitivity of the Area The sensitivity of the area is defined for dust soiling, human health (PM10) and ecological receptors. The sensitivity of the area takes into account the following factors: • the specific sensitivities of receptors in the area; • the proximity and number of receptors; • in the case of PM10, the local background concentration; and • site specific factors, such as whether there are natural shelters, such as trees, to reduce the risk of wind-blown dust. Table D.1 is used to define the sensitivity of different types of receptors to dust soiling, health effects and ecological effects. Based on the sensitivities assigned to the different receptors surrounding the site and numbers of receptors within certain distances of the site, a sensitivity classification can be defined for each. Tables D.2 to D.4 indicate the criteria used to determine the sensitivity of the area to dust soiling, human health and ecological impacts.
[Page 40] APPENDIX D
Table D.1: Examples of factors defining sensitivity of an area Sensitivity of Area Dust Soiling Human Receptors Ecological Receptors High Users can reasonably expect enjoyment of a high level of amenity The appearance, aesthetics or value of their property would be diminished by soiling’ The people or property would reasonably be expected to be present continuously, or at least regularly for extended periods, as part of the normal pattern of use of the land. E.g. dwellings, museums and other important collections, medium and long term car parks and car showrooms. 10 – 100 dwellings within 20 m of site. Local PM10 concentrations close to the objective (e.g. annual mean 36 -40 μg/m3). E.g. residential properties, hospitals, schools and residential care homes. Locations with an international or national designation and the designated features may be affected by dust soiling. Locations where there is a community of a particularly dust sensitive species such as vascular species included in the Red List for Great Britain. E.g. A Special Area of Conservation (SAC).
Medium
Users would expect to enjoy a
reasonable level of amenity, but
would not reasonably expect to
enjoy the same level of amenity as
in their home.
The appearance, aesthetics or
value of their property could be
diminished by soiling
The people or property wouldn’t
reasonably be expected to be
present here continuously or
regularly for extended periods as
part of the normal pattern of use
of the land.
E.g. parks and places of work.
Less than 10 receptors within
20 m.
Local PM10 concentrations
below the objective (e.g. annual
mean 30-36 μg/m3).
E.g. office and shop workers
but will generally not include
workers occupationally
exposed to PM10 as protection
is covered by the Health and
Safety at Work legislation.
Locations where there is a
particularly important plant
species, where its dust
sensitivity is uncertain or
unknown.
Locations with a national
designation where the features
may be affected by dust
deposition
E.g. A Site of Special Scientific
Interest (SSSI) with dust
sensitive features.
Low
The enjoyment of amenity would
not reasonably be expected.
Property would not reasonably
be expected to be diminished in
appearance, aesthetics or value
by soiling.
There is transient exposure,
where the people or property
would reasonably be expected to
be present only for limited
periods of time as part of the
normal pattern of use of the land.
E.g. playing fields, farmland unless
commercially sensitive
horticultural, footpaths, short
lived car [parks and roads.
Locations where human
exposure is transient.
No receptors within 20 m.
Local PM10 concentrations well
below the objectives (less than
75%).
E.g. public footpaths, playing
fields, parks and shopping
streets.
Locations with a local
designation where the features
may be affected by dust
deposition.
E.g. Local Nature Reserve with
dust sensitive features.
[Page 41] APPENDIX E
Table D.2: Sensitivity of the area to dust soiling on people and property Receptor Sensitivity Number of Receptors Distance from the Source (m) <20 <50 <100 <350
High
100 High High Medium Low 10-100 High Medium Low Low 1-10 Medium Low Low Low Medium 1 Medium Low Low Low Low 1 Low Low Low Low Table D.3: Sensitivity of the area to human health impacts Receptor Sensitivity Annual Mean PM10 Concentration Number of Receptors Distance from Source (m) <20 <50 <100 <200 <350 High 32 μg/m3 100 High High High Medium Low 10-100 High High Medium Low Low 1-10 High Medium Low Low Low 28-32 μg/m3 100 High High Medium Low Low 10-100 High Medium Low Low Low 1-10 High Medium Low Low Low 24-28 μg/m3 100 High Medium Low Low Low 10-100 High Medium Low Low Low 1-10 Medium Low Low Low Low <24 μg/m3 100 Medium Low Low Low Low 10-100 Low Low Low Low Low 1-10 Low Low Low Low Low Medium 32 μg/m3 10 High Medium Low Low Low 1-10 Medium Low Low Low Low 28-32 μg/m3 10 Medium Low Low Low Low 1-10 Low Low Low Low Low 24-28 μg/m3 10 Low Low Low Low Low 1-10 Low Low Low Low Low <24 μg/m3 10 Low Low Low Low Low 1-10 Low Low Low Low Low Low
1 Low Low Low Low Low
[Page 42] APPENDIX D
Table D.4: Sensitivity of the area to ecological impact Receptor Sensitivity Distance from the Source (m) <20 <50 High High Medium Medium Medium Low Low Low Low Define the Risk of Impacts The final step is to combine the dust emission magnitude determined in step 2A with the sensitivity of the area determined in step 2B to determine the risk of impacts with no mitigation applied. Tables D.5 to D.7 indicate the method used to assign the level of risk for each construction activity. The identified level of risk is then used to determine measures for inclusion within a site-specific Construction Management Plan (CMP) aimed at reducing dust emissions and hence reducing the impact of the construction phase on nearby receptors. The mitigation measures are drawn from detailed mitigation set out within the IAQM guidance document. Table D.5: Risk of dust impacts from demolition Sensitivity of Area Large Medium Small High High Risk Medium Risk Medium Risk Medium High Risk Medium Risk Low Risk Low Medium Risk Low Risk Negligible Table D.6: Risk of dust impacts from earthworks/construction Sensitivity of Area Large Medium Small High High Risk Medium Risk Low Risk Medium Medium Risk Medium Risk Low Risk Low Low Risk Low Risk Negligible Table D.7: Risk of dust impacts from trackout Sensitivity of Area Large Medium Small High High Risk Medium Risk Low Risk Medium Medium Risk Low Risk Negligible Low Low Risk Low Risk Negligible
[Page 44]
Figure E.1: Location of road links used in modelling
[Page 45] APPENDIX F
Appendix F: IAQM Highly Recommended Mitigation Measures for Medium Risk Sites The measures below will be incorporated into the site wide CEMP and approved by Isle of Man Government prior to commencement of any work on site: Communications • Develop and implement a stakeholder communications plan that includes community engagement before work commences on site. • Display the name and contact details of person(s) accountable for air quality and dust issues on the site boundary. This may be the environment manager/engineer or the site manager. • Display the head or regional office contact information. • Develop and implement a Dust Management Plan (DMP), which may include measures to control other emissions, approved by the Local Authority. The level of detail will depend on the risk, and should include as a minimum the highly recommended measures in this Appendix. The DMP may include monitoring of dust deposition, dust flux, real-time PM10 continuous monitoring and/or visual inspections. Site Management • Record all dust and air quality complaints, identify cause(s), take appropriate measures to reduce emissions in a timely manner, and record the measures taken. • Make the complaints log available to the local authority when asked. • Record any exception incidents that cause dust and/or air emissions, either on- or off-site, and the action taken to resolve the situation in the log book. Monitoring • Carry out regular site inspections to monitor compliance with the Dust Management Plan, record inspection results, and make an inspection log available to the local authority when asked. • Increase the frequency of inspections by the person accountable for air quality and dust issues on site when activities with a high potential to produce dust are being carried out and during prolonged dry or windy conditions. • Agree dust deposition, dust flux, or real-time PM10 continuous monitoring locations with the Local Authority. Where possible commence baseline monitoring at least three months before work commences on site or, if it is a large site, before work on a phase commences. Further guidance is provided by the IAQM on monitoring during demolition, earthworks and construction. Preparing and Maintaining the Site • Plan site layout so that machinery and dust causing activities are located away from receptors, as far as possible. • Erect solid screens or barriers around dusty activities or the site boundary that are at least as high as any stockpiles on site. • Fully enclose site or specific operations where there is a high potential for dust production and the site is active for an extensive period. • Avoid site runoff of water or mud. • Keep site fencing, barriers and scaffolding clean using wet methods. • Remove materials that have a potential to produce dust from site as soon as possible, unless being re-used on site. If they are being re-used on site cover as described below. • Cover, seed or fence stockpiles to prevent wind whipping. Operating Vehicle/Machinery and Sustainable Travel • Ensure all vehicles switch off engines when stationary – no idling vehicles.
[Page 46] APPENDIX F
•
Avoid the use of diesel or petrol powered generators and use mains electricity or battery powered
equipment where practicable.
•
Produce a Construction Logistics Plan to manage the sustainable delivery of goods and materials.
Operations
•
Only use cutting, grinding or sawing equipment fitted or in conjunction with suitable dust
suppression techniques such as water sprays or local extraction, e.g. suitable local exhaust
ventilation systems.
•
Ensure an adequate water supply on the site for effective dust/particulate matter
suppression/mitigation, using non-potable water where possible and appropriate.
•
Use enclosed chutes and conveyors and covered skips.
•
Minimise drop heights from conveyors, loading shovels, hoppers and other loading or handling
equipment and use fine water sprays on equipment wherever appropriate.
•
Ensure equipment is readily available on site to clean any dry spillages, and clean up spillages as
soon as reasonably practicable after the event using wet cleaning methods.
Waste Management
•
Avoid bonfires and burning of waste materials.
Demolition
•
Ensure effective water suppression is used during demolition operations. Hand held sprays are
more effective than hoses attached to equipment as the water can be directed to where it is
needed. In addition high volume water suppression systems, manually controlled, can produce fine
water droplets that effectively bring the dust particles to the ground.
•
Avoid explosive blasting, using appropriate manual or mechanical alternatives.
•
Bag and remove any biological debris or damp down such material before demolition.
Construction
•
Ensure sand and other aggregates are stored in bunded areas and are not allowed to dry out,
unless this is required for a particular process, in which case ensure that appropriate additional
control measures are in place.
Trackout
•
Use water-assisted dust sweeper(s) on the access and local roads, to remove, as necessary, any
material tracked out of the site. This may require the sweeper being continuously in use.
•
Avoid dry sweeping of large areas.
•
Ensure vehicles entering and leaving sites are covered to prevent escape of materials during
transport.
•
Inspect on-site haul routes for integrity and instigate necessary repairs to the surface as soon as
reasonably practicable.
•
Record all inspections of haul routes and any subsequent action in a site log book.
•
Install hard surfaced haul routes, which are regularly damped down with fixed or mobile sprinkler
systems, or mobile water bowsers and regularly cleaned.
•
Implement a wheel washing system (with rumble grids to dislodge accumulated dust and mud
prior leaving the site where reasonably practicable).
•
Ensure there is an adequate area of hard surfaced road between the wheel wash facility and the
site exit, wherever site size and layout permits.
•
Access gates to be located at least 10 metres from receptors where possible.
[Page 47]
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