Sustainability appraisal report

Consultation:

• authorities with environmental responsibility, when deciding on the scope and level of detail of the information which must be included in the environmental report (Art. 5.4)

The scoping report was made available to the statutory consultees for comment in line with the requirements of the Directive, comments received at this stage were incorporated into the SA where relevant. The outcome of the consultation process is reported in Appendix 7 of the SA Report.
• authorities with environmental responsibility and the public, shall be given an early and effective opportunity within appropriate time frames to express their opinion on the draft plan or programme and the accompanying environmental report before the adoption of the plan or programme (Art. 6.1, 6.2)	Work on sustainability appraisal has been ongoing from the preparation of the Sheffield City Plan under the old planning legislation, this work involved a variety of stakeholders. This integrated work has continued in preparing this sustainability appraisal, which builds on the earlier work. To allow continued participation in the process by stakeholders three Sustainability Appraisal Panel meetings were held in April 2006 with a people representing a range of interests. Outcomes of these panel meetings fed into the appraisal process, including the commentary on options and the conclusions drawn. Consultation on the SA is also part of the continued process of preparation of the Core Strategy, as this SA Report on the preferred options version was put out to consultation alongside the DPD, and will again be consulted upon at submission stage.
• other EU Member States, where the implementation of the plan or programme is likely to have significant effects on the environment of that country (Art. 7)	Not relevant
Taking the environmental report and the results of the consultations into account in decision-making (Art. 8)	The SA has had a fundamental role in shaping the Core Strategy and the selection of Preferred Options. This is detailed in paragraphs 1.21 and 1.22 of the SA Report, and this process of feedback will continue in developing the submission version of the Core Strategy.

July 2007

SHEFFIELD CITY COUNCIL

Evaluation of the

Sustainability Appraisal of the

Sheffield Development Framework

City Sites and City Policies

Preferred Options

Development Plan Documents


1 Task
1.1 The purpose of this report is to provide Sheffield City Council with an evaluation and validation of the sustainability appraisal (SA) process undertaken of parts the Local Development Framework for Sheffield, known as the Sheffield Development Framework (SDF). The SA of two Development Plan Documents (DPDs) are under consideration at this stage. These are the City Policies DPD and City Sites DPD, the former addressing policies for development management and the later identification of site specific allocations for development. The evaluation process seeks to consider the approach taken to the SA process, and whether the SA has been carried out in compliance with the regulatory requirements of the SEA Directive (2001/42/EC) and consistent with a good practice approach to SA.
1.2 The evaluation process does not include the checking of the assumptions and predictions made in appraisal of individual options, but does consider the approach taken in the appraisal and concentrates more on the how effective and complete it is . With this report providing the joint evaluation of the two separate SA Reports produced for the preferred options version City Policies DPD and preferred options version of the City Sites DPD.
1.3 This evaluation concentrates on the latest stage of the SA process, which is the Preferred Options pre-submission version of the City Policies and City Sites DPDs, with only limited reference to past stages, such as baseline data collection and the initial stages of the Emerging Options for each DPD.
1.4 The evaluation report follows early work undertaken by Baker Associates assisting on the development of sustainability objectives for the SA, and evaluation of the SA of the Sheffield City Plan, in 2004². The outcome of the evaluation stages showed that the approach being followed was very positive and innovative for SA at the time. The report also highlighted the importance of considering the requirements of the SEA Directive, and the new planning system, neither of which had come into force at that time.
1.5 An evaluation of the Core Strategy preferred options DPD was also undertaken using the same method as this evaluation³. Overall that evaluation concluded that the SA process seemed reasonable and compatible with the requirements of the SEA Directive. The only slight concerns raised was the amount of material that was produced during the SA and the accessibility of this to stakeholders and whether the task of SA is commensurate with its purpose.
2 Strengths of the SA
2.1 As was the case in the SA of the Core Strategy pre-submission version the work undertaken in the SA of these two DPDs is very thorough in its approach. The appraisal process started with the preparation of the generic background ‘scoping’ stage for the SA of the entire SDF, which was used as the basis for appraisal of the Core Strategy and the two DPDs under consideration at this stage.
2.2 The appraisal of options begun with consideration of the initial preparation stages of the City Policies and City Sites DPDs; the production of Emerging Options document. This approach of integrating SA early in the plan process is essential in order to ensure these considerations are taken into account in preparation of the SDF from the outset, and therefore gives the SA a real role in making a better plan.
2.3 The SA has taken a rigorous and systematic approach, whereby all options have been subject to the same level of testing against the objectives of sustainable development. These were developed for the SA and enabled direct comparison of alternatives and options for sites and policies. Although this has meant that the time taken for the appraisal, and the resulting length of documentation made the process of appraisal a significant undertaking.
2.4 For the City Policies DPD the Emerging Options were consulted on in Spring 2006 and for each issue raised a series of alternative approaches were appraised. This was used to inform the selection of the Preferred Option, although the exact appraisal process and findings at this stage is not reported as the appraisal here already identifies a preferred option. However it performed an invaluable role in the selection of the preferred option in refining policy wording in order to avoid and mitigate against potential impacts of development.
2.5 The SA of the City Sites Emerging Options was also useful in the selection of the more appropriate use for various allocated sites, as well as whether the allocation itself was sustainable due to location. This provided a useful early check of sustainability, although there are no published records of this process that are available for public comment.
2.6 The role the SA has played in formulating options and selecting approaches, through the identification of the differing sustainability implications of the various proposed options is essential to the preparation of a ‘sound’ LDF. This role of aiding the development and refining of options is the key purpose of SA, and for this reason it can be said that the SA of the emerging Core Strategy of the SDF has been extremely effective.
2.7 The value of the approach to SA has been further increased by the involvement of others, beyond the SDF team, in helping to undertake the appraisal and consider what the implications of the approach put forward may be.
2.8 This more collaborative way of working, drawing on the expertise and knowledge of others helps to ensure the completeness of the appraisal and its value in identifying worthwhile conclusions. It also allowed an overview of the interaction between City Policies and City Site options to get a better understanding of issues.

3 Compliance with the SEA Directive
3.1 The approach to the SA of each of the DPDs is to carry out a joint sustainability appraisal and environmental assessment following the requirements of the SEA Directive, in line with current best practice on these matters. Separate SA Reports have been produced for the Core Policies and Core Sites DPD, however these share much in common including the majority of Appendices and are both evaluated in this report.
3.2 The key process stages that have to be complied with, and reported in the SA Report, are detailed in Annex 1 of the Directive. Consultation requirements are also set in Article 5 and in Article 6. Appendix 1 of this evaluation report gives the wording of these sections of the SEA Directive and considers how the SA of the Sheffield Core Strategy Preferred Options meets these requirements. This table shows that the SA is in compliance and fulfils the requirements of the SEA Directive successfully for the majority of issues. This evaluation of compliance raised a few matters for consideration, although these are not substantive, and are unlikely to put compliance with the SEA Directive in doubt.
3.4 It is also worth reflecting that the purpose of SA is not only to comply with the with the procedural requirements of the SEA Directive and existing guidance, but also to help create a better, more effective plan that helps secure more sustainable development. Section 4 raises matters arising from the compliance evaluation with the SEA Directive as well as some other matters relating to good practice for SA, which may need further consideration.
3.5 The two SA Reports only show the process as far a Preferred Options the SA process and further reporting will need to be carried out as the DPDs move from preferred option to submission versions. A further draft of the SA Report will have to be produced to report on the sustainability process from now until the finalisation of the submission version of the Core Strategy. This report will also have to be in compliance with the SEA Directive. As the SA progresses it should also begin to add to compliance with the SEA Directive, shown in table 1, as more material is produced relating to additional matters such as monitoring.

4 Matters arising from the Sustainability Appraisal

4.1 This section considers matters arising from the approach taken to the two SAs that require comment. For the most part these are not issues of fundamental importance to the SA process and only those that may require some further reflection; may assist in moving forward with the appraisals to the submission version of the City Policies and City Sites DPDs and may help improve the clarity of the SA process of those seeking to understand the process and its conclusions and findings.

Approach to appraisal

4.2 One of the main aspects of this appraisal process that is immediately evident is the scale of the work that was involved. This arises from the extremely detailed options developed for, and presented in, the Emerging Options Papers and the Preferred Options versions and those developed specifically as part of the SA.

4.3 For the SA of the City Policies a decision was made to appraise all of the rejected alternatives and a ‘do nothing’ approach required by the SEA Directive of each policy proposal. The number of policies considered made this quite a large task. For the SA of the City Sites DPD the task was even greater and included the appraisal of a large number of sites for allocation as well as the relative impacts of alternative uses on these sites.
4.3 Although not a criticism of the SA process followed by Sheffield City Council, the amount of work that this has involved may not be entirely commensurate with the outcomes of the appraisal and the influence it has had on the choice of Preferred Option, and there is some question that despite the role of the SA in selecting a preferred option the same conclusions could have been reached without the need for such a detailed process.
4.4 The large amount of information produced in the two SA process (over 1000 pages of appraisal matrices alone) means that to some extent the sustainability implications and findings of the appraisal have become hidden amongst the appraisal of the other more specific area based options. Although extremely useful for plan makers as a test of each option it does mean that it is not immediately apparent from those wishing to comment on and understand sustainability issues identified by the SA Report the overall sustainability implications of implementing these parts of the SDF.
Sustainability implications of the Sheffield Development Framework

4.5 A further issue with the amount of material presented and the separation of the sustainability appraisal of the two DPDs into separate SA processes and reports is that it can be difficult to understand what the overall sustainability implications may be of the SDF as it now stands.

4.6 The SA Reports do address some issues related to cumulative impacts of sites and policies as part of the SA process, and this was also discussed as part of the Sustainability Appraisal Panel discussions. In addition the ‘Implementation’ section of each report notes how the various documents of the SDF will work together to implement development. These approaches are supported by this evaluation, however, as with other issues, it may have been useful to further draw out some of the sustainability issues from the various SA Reports to deal with the interaction of sites, policies and strategy and their interactions and in-combination effects.
4.7 This would highlight any outstanding unresolved sustainability issues, or where through the combined approaches, sustainability impacts are likely to be successfully mitigated against. Such an approach would aid in understanding the sustainability implications of the SDF (rather than individual DPDs) and how significant effects need to be mitigated against through development control decisions and the implementation of other plans and strategies by Sheffield City Council and others (including other SDF documents) and successfully monitored as a whole.
4.8 The non-technical summaries of the each appraisal stage provide a useful summary of the appraisal process of each DPD and the conclusions reached, and a similar approach would be useful for the whole of the SDF as it emerges. This could show the significant sustainability issues arise, and are mitigated against, through the combination effects of the DPDs and other parts of the SDF as they are prepared and appraised. Summaries of this type and the integration of SA findings may also aid those preparing the various component documents of the SDF by allowing the findings of the appraisal of one document to help in the formulation of another. For example site allocation choices impacts on policy decisions.
The role of sustainability appraisal in testing the SDF

4.9 In addition to the role for SA as set out in the SA good practice guidance and through the requirements of the SEA Directive, SA can also play a key role in testing the DPDs and the SDF to check its likely effectiveness in delivering development as desired. The purpose of which is to consider whether the approach as set out in the documents of the SDF will actually be useful in implementing the more sustainable form of development that is sought. For this reason it may have been suitable for the SA to widen its comments on some aspects of the two DPDs to look at issues wider than that required by regulation and requirement and can not be identified through the systematic appraisal of individual policies and sites.

4.10 For the two DPDs under consideration here there are a few instances where this type of critique of the process being followed may have proved useful. In the City Policies DPD it may have been useful for the SA on reflect on the advice of PPS12: Local Development Frameworks. This states in paragraphs 2.28 and 2.29, that: “The local development framework should contain a limited suite of policies” and that “the focus… should be on topic-related policies”. Policies should also avoid repeating national policy statements. The purpose of this is to keep policies to an essential minimum for clarity and to clearly define the criteria for development that would and would not be accepted. This encourages more sustainable development by focusing on those issues that are really important to the local area. Therefore it may have been worthwhile for the SA to address these issues and discuss whether the approach and number of policies proposed in the DPD is compatible with the current requirements on producing a more effective plan to deliver sustainable development.
4.11 For the City Sites DPD the SA could have been used in a more challenging way in respect to proposed development in Green Belt, looking for sites that performed better than alternatives within the urban boundaries. This approach may have allowed a more effective comparison, in terms of sustainability, of the relative merits of concentrating development in sites within the urban area or seeking other sites in the Green Belt. With the purpose of releasing some pressure of development from urban sites with the potential for this to be the most sustainable solution in the long term. For instance those sites at high risk of flooding in the urban area could have been avoided or used for leisure purposes and sites more suited for business uses would not have to be developed for housing to meet Regional Spatial Strategy needs. Instead additional land could have been found through Green Belt review, with land that has good access to the city and low environmental quality, released for development.
4.12 A further matter not addressed in either of the DPDs or the associated SA Reports is the extent to which the sites identified for housing in the preferred options document will be sufficient to meet the housing needs of the RSS, as well as employment leisure and retail needs. Clearly, ensuring this will be a key element of delivering a sustainable plan, as this has a major influence in the location and the way development is delivered. Therefore including information of expected housing yield from sites and how this cumulatively will deliver the identified needs would be useful in allowing the SA to verify how effective the DPD is likely to be in successful in delivering development. This may also help in making decisions on the how to proceed with the preferred option in moving forward to submission version DPDs.
Evaluation of sustainability appraisal matters

4.13 It has not been the role of this validation and evaluation process to look at detail at all of the appraisal matrices, the conclusions drawn and the recommendations made, as this would be equivalent do a reappraisal. However in some instances this exercise has identified issues where a different approach could have been taken a different conclusions drawn.

4.14 The way that Green Belt issues are dealt with by the appraisal may not necessarily be compatible with choosing the most sustainable approach for development in every instances. It is reported in paragraph 4.11 that Green Belt proposal could have been tested for their relative sustainability in relation to urban sites. The reason for this is Green Belt has no particular environmental quality designation and the identification of this land is purely to preserve openness and restrict urban growth. Therefore development of this type of land may be more favourable in sustainability terms than city sites where Green Belt land provides a site that is better connected to jobs and services that an urban site; where a vacant urban site has re-vegetated creating a biodiversity asset potentially greater than improved grassland on the urban fringe; or where development on sites in the urban area would cause overdevelopment impact on the lives of new and existing residents in the area. This means that careful selection of suitable sites to be developed in Green Belt may actually be preferable to concentration in the urban area. Therefore the process of discounting sites automatically where they are in the Green Belt potentially may not have lead to the most sustainable locations for development.
4.15 Also in the City Sites DPD land has been identified for development within the zones at risk of flood according to the Strategic Flood Risk Assessment (SFRA). Table 7 that summarises the ‘significant effects of implementing the plan’, against the objective 17 of avoiding flood risk states that “sites score positively against this objective as those with flood risk issues will not be allocated for sensitive uses such as housing”. However in reviewing the appraisal matrices in Appendix 2b this is not necessarily the case as several allocations are within high flood risk areas, these are:

• 
  site 1104 Former Jacob’s Factory Building a Housing allocation, part of which is in a high risk flood zone
  
  
  
• 
  sites 1304 Cross Turner St / Fordham St; 1303 Bernard Works, Sylvester Gardens; 1375 Klausners Site / Sylvester Street / Mary Street, are all Housing and Business allocation that would see 30% of the site used as housing
  

• 
  sites 606, 632, 1322, 1325, 1333, 1343 are all allocated for Business uses that allow housing
  

4.16 Other sites allocated for other types of use are in the high risk flood zone, it will be vital in granting permissions for these sites that future businesses have plans and insurance in place for times of flood so as not to too severely adverse their economic viability. Industrial uses will also need to be managed to avoid uses in these area that would cause adverse pollution effects to water at times of flood. In addition site 1326 at Earl Street/Eyre Street/Jessop Street is in a high risk flood area and is allocated as a new Fire Station which may not be the most appropriate location for an emergency service.

4.17 The City Policies document does not raise any additional issues other than those reported elsewhere in this section.
The Role of the SA in selecting preferred options

4.18 Both the SA Reports state that the SA was influential in identifying the preferred options following appraisal of the initial Emerging Options document. This process of ensuring the SA is integrated into the plan making process and the decision made is supported by this evaluation, as it should help ensure the assimilation of sustainability matters into the DPDs. However, how this early stage of the SA was carried out and how the findings were presented is not entirely clear from these versions of the SA Reports.

4.19 For the City Sites DPD the evaluation recognises that some filtering process of sites was carried out in order to identify those sites that should be tested as part of the Preferred Options. The DPD itself does give some information on this, however it would have be advantageous to see greater detail of how this process worked, in order to ensure the method was robust and suitable in choosing sites for development. For instance in the rejection of Green Belt sites as addressed in paragraph 4.14 of this evaluation report which could have been more fully assessed as part of a systematic appraisal in order to detail their relative sustainability implications compared to urban allocations.
4.20 For the City Policies DPD the difficulty lies in the SAs role early in the appraisal of the Emerging Options. Policies at this stage were quite fully developed in some instances, often with no explicit alternatives, by the time the Preferred Options version was developed policies had been further refined and knowing the role of SA in this process may have been a useful inclusion. It may also have been suitable for the SA to give some consideration to alternative targets and thresholds for development on allocated sites to help provide a view on the sustainability implications of following a different approach.
4.21 This evaluation process does recognise that it is not possible to state every instance where part of the SA process resulted in a wording change or change of emphasis in a policy some details of an ‘audit trail’ may have been useful to give those reading the SA a fuller understanding of the influence of the SA on the choice of preferred option. Despite this slight lack of an ‘audit trail’ of the influence of the SA on the preferred option the SA at this stage still has a very useful purpose, with the way it is reported providing a key role essential in moving forward with the DPDs – that is identifying potential impacts in need of mitigation.