Background
DustScanAQ’s Gordon Allison relates the development of the air quality guidance for HS2, where he was air quality lead during the development of the Act of Parliament for Phase One (London to Birmingham).
Hundreds of petitions (individual or group objections) concerning the HS2 Hybrid Bill were about construction dust. Euston Station was planned at the time to be an active construction site for 18 years, so the argument that any nuisance would soon pass, was not a valid one.
One of the problems we overcame in developing the #Code of Construction Practice, to address people’s legitimate concerns, was that there was planning guidance for London but nothing for the rest of the route.
The Mayor of London had published Supplementary Planning Guidance covering construction dust, but there was no similar national or local authority guidance outside of the capital.
Dust from construction was actively managed in London and not even a consideration in Birmingham. My experience on the regeneration of coal-mine spoil heaps in Telford, was that when contractors ‘cracked on’ in dry weather, dust could be the cause of genuine grievance to neighbouring residents through dirtying washing, windows and cars. This created a great deal of bad feeling and resentment towards the project. My experience of using Frisbee dust deposit gauges there was that they weren’t sensitive enough to pick up dust problems causing nuisance complaints.
Several considerations guided my thinking in developing the strategy:
- HS2 is a flagship project, to lead best practice
- Social justice – that people outside of London deserved the same level of protection as those in London;
- Health protection – that active measures should address potential harm to health (from breathing in airborne fine particles), as a priority over dust soiling people’s property – cars, windows and the like;
- Monitoring should be an aid to active dust management – advice from my team leader who was an environmental manager on the Olympics construction site was that it was not useful to have dust deposition measurements from weeks ago, revealing a dust management issue in the past: monitoring needed to be near to real time, to guide the site manager’s interventions;
- Continuous monitors for PM10, which were in use as fence-line indicators of dust emissions, were prone to false alarms
- The trigger level in use for construction dust at the time (15 minute average PM10 of 250 µg/m3) was 'borrowed' from research into a dataset from 1998/1999, looking at how construction activities next door to national air quality compliance monitoring sites could affect national compliance with the EU directive for PM10.