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CPRE response to Cheshire East Council air quality strategy consultation

20th May 2024

Poor air quality harms health and quality of life, deters people from active travel, and is directly connected with climate change issues. We’re concerned that Cheshire East Council’s draft strategy is an inadequate response to the challenge.

Consultation closed on 17 May 2024 for Cheshire East Council’s draft air quality strategy 2024 – 2029. In our response, we stated our concern that the draft fails to recognise the vital importance of connecting travel, air quality and climate change issues.

Full text of our response

CPRE (formerly the Campaign to Protect Rural England), Cheshire Branch, has a number of comments to make in relation to the Cheshire East Council (CEC) consultation on its draft air quality strategy for 2024 – 2029.  Air quality is an issue that concerns CPRE, not only because of its impacts on health and the quality of life and the fact that poor air quality can put people off from active travel but because of its inter-connection with climate change.

It is crucially important that CEC sees the climate emergency as the key, over-arching glue that binds together so many of its plans, policies and strategies such as the Local Plan, the Local Transport Plan, the Air Quality Strategy and the Carbon Neutrality Action Plans – with a view to attaining carbon neutrality across the Borough by 2040.

It is therefore disappointing to note that the Council recently set back its target for itself as an entity to become carbon neutral by 2035 to 2040.  It is also worrying that the draft Air Quality Strategy being consulted upon does not even mention climate change or the climate emergency in either the executive summary or the conclusion.  Nor is it featured in Fig. 1 which illustrates ‘Inputs and outcomes’. Nor is it mentioned under ‘Central Government Framework’ in paragraph 3.1.  In fact, it is only mentioned specifically twice – in the first bullet point of para. 4.1 (as a “such as”, along with health improvement programmes) and in para. 4.4, (along with ‘energy management’).

At the same time as responding to this consultation, CPRE has been making a substantial submission on the first stage consultation in relation to the new local plan Issues Paper.  Question 3(c) in this ongoing consultation is:  “How can the local plan help to improve air quality across Cheshire East?”  Our answer to this is: “CEC needs to adopt a different mindset.  It cannot, on the one hand, be declaring a climate emergency and publishing fine words about tackling climate change and poor air quality and, on the other, be endorsing developing on a peat bog and building new roads.  Its actions need to comply with its words if it is to square the circle.  It should be taking all actions possible to reduce the need to travel – by ensuring everyone has access to good digital connectivity and communities are sustainable entities – and, when residents do need to travel, providing them with sustainable and seamless public transport options and good conditions for active travel”.

This followed on from us having drawn attention in the local plan consultation to the fact that Cheshire East is amongst the most polluting authorities for greenhouse gas emissions according to the map published in October by the Department for Energy, Security and Net Zero that was posted on the Department for Transport website:  Note particularly the map for 2021.

CPRE would also like to make the point that it is odd for CEC to be holding a consultation on air quality without featuring as part of it key information that is held, ie: and also:  It is not appropriate that respondents should be expected to hunt around the CEC website to source such fundamental information.  However, from these sources it is possible to discern that insufficient monitoring is taking place (from any permanent sites) around Manchester airport and close to the M6 and M56 in particular.  There is also no information supplied on where, if anywhere, random monitoring takes place around the borough.

CPRE regrets to have to conclude that the draft Air Quality Strategy is an inadequate and unimpressive document.

More information

Air quality monitoring NO2 diffusion tube data 2023

Air quality monitoring NO2 diffusion tube data 2024

Air quality in Cheshire East – information and maps

Cheshire East Council new Local Plan Issues Paper consultation (closes 31 July 2024)

CPRE Cheshire response to Local Plan Issues Paper consultation