'A major mistake on public health grounds' but Empire Way primary school approved

Clean Air for Brent sent the following submission to the Planning Committee today but there was little evidence at the meeting that members had taken it into account.[ UPDATE 17.00 June 7th Joe Kwateng has written to CAfB today to say that the document arrived while he was in the pre-meeting with the Committee which was immediately followed by the Planning Committee meeting itself. He could not access his computer and therefore could not bring it to the attention of the committee. He apologised.]

The Committee decided by 7 votes to 1 to approve the application for a 630 pupil primary school on the York House car park on Empire Way. Well done to Cllr Abdi for taking the concerns seriously and voting against. I was surprised that Cllr Colacicco who has fought so hard against the Cricklewood Aggregate Hub on grounds of air and traffic pollution, not only voted for the application but praised it for meeting BREAM standards. A 'green' building in a heavily polluted area is a contradiction.

The Committee were told by officers that as outline permission have already been granted for a much wider area, but one that included the school site, and it had been found 'suitable for a school' that the hearing was really only about planning matters related to design, school travel plans etc.  Design features to mitigate exposure to air pollution included the positioning of classrooms towards the back of the plot with a school hall and non teaching rooms on the ground floor facing Empire Way and the installation of a mechanical ventilation system. Planning Officer told the committee that the Council had Victorian schools in far worse locations- so that's all right then!

The is CAfB's submission:

Objection by Clean Air for Brent

We apologise for the lateness of this objection, but we only became aware of the application on 1 June and have been in dialogue with planning officers since yesterday about the material considered in connection with the outline application 15/5550.

Summary: Clean Air for Brent considers that it would be a major mistake on public health grounds to proceed with the proposal to site the planned Ark Somerville School and associated Day Nursery on the York House site next to the heavily-trafficked Wembley Hill Road. We urge the Council, Quintain and the Ark Academy Chain to consider an alternative site within the development away from the main road.

Outline permission: We appreciate that outline permission was granted in respect of application 15/5550 and that this includes the siting of the school. The implication of the Head of Planning’s email to us of 4^th June is that the question of siting is done and dusted. We agree that this might normally be the case but with respect we regard this as a technicality compared with the risks of damaging the health and development of future nursery and primary school children. So far no development of the critical site has taken place.

Considerations: The UK and London in particular is in serious breach of legal air pollution requirements derived from EU legislation to which the UK is a party. The main pollutant concerned in the legal breach is nitrogen dioxide, NO2. Most of Brent is declared as an Air Quality Management Area because it is in breach of the legal limit for NO2. This includes the site in question.

The legislation is based on World Health Organisation findings on the impact of various air pollutants on human health. In the UK the official Committee on the Medical Effects of Air Pollution (COMEAP) and the Royal College of Physicians among others have published extensive studies on the various adverse health impacts which include respiratory diseases, cancer, stroke, cardiovascular conditions and possibly neurological morbidities. Children are especially vulnerable, possibly because they breathe more rapidly than adults. It is considered that children badly affected by air pollution can have their lung development restricted by up to 10%.

Since road traffic, particularly diesel-powered vehicles, is a major contributor to NO2 pollution The London Mayor, with wide support, has taken a number of initiatives to address the problem of the hundreds of London schools sited for historical reasons on heavily-trafficked roads. An example is the recently published results of a professional air quality audit of 50 of the most-polluted schools, including two in Brent. It is clear that mitigation measures as so far proposed will have no more than a marginal effect on pollution levels affecting children in these schools.

In this situation CAfB believes that it is seriously irresponsible to site any new school on a heavily trafficked road, such as Wembley Hill Road in the present case.

In the short time available CAfB has investigated whether the issue of air quality in relation to the siting of the school was discussed in the papers submitted with the application 15/5550, eventually decided in December 2016. Although the Planning Officer advises that it was we have not found evidence for this in the 77-page Air Quality chapter of the Environmental Statement sent to us yesterday by the Head of Planning. We note that among the documents listed as relevant is the London Plan, but the salient point in the London Plan in relation to the school is in 7.14. This is not discussed but relegated to Appendix 3.3.1. For reference it reads:

“B  Development proposals should:

a  minimise increased exposure to existing poor air quality and make provision to address local problems of air quality (particularly within Air Quality Management Areas (AQMAs) and where development is likely to be used by large numbers of those particularly vulnerable to poor air quality, such as children or older people) such as by design solutions, buffer zones or steps to promote greater use of sustainable transport modes through travel plans (see Policy 6.3)”

The relevant supporting paragraph 7.51 begins:

“Increased exposure to existing poor air quality should be minimised by avoiding introduction of potentially new sensitive receptors in locations where they will be affected by existing sources of air pollution (such as road traffic and industrial processes). Particular attention should be paid to development proposals such as housing, homes for elderly people, schools and nurseries.”

Unfortunately the whole emphasis of the Air Quality chapter is on the effect of the development on the environment and not on the effect of subjecting the school and nursery pupils to the pollution effects of traffic on Wembley Hill Road.

We also note from the Master Plan documents associated with 15/5550, section 5.8 about the school site, that during the early stages three alternative locations for the school were considered but not favoured by Ark Academy or Brent officials. In this section there is no mention of air quality issues arising from siting the school on Wembley Hill Road.

Conclusion: While it would be desirable to install air quality monitoring arrangements close to the site in question and other possible sites before a final decision, this is not really necessary since if the choice is between a busy road and a more local or feeder road within the site the answer is obvious. We therefore urge that this aspect of the overall plan be put on hold for further consideration by the parties in the light of the latest understanding of the effect of air pollution on children’s health and development.

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