Sustainability appraisal report

Mitigation

4.22 As well as showing the sustainability implications of the policies and sites as they appear in this version of the DPDs the SA at this stage also has a key role to play in identifying ways in which the potential impacts identified can be mitigated against.

4.23 These matters relating to mitigation are a very useful output of the SA process and for that reason it may have been suitable to put greater emphasis on these as part of the SA Reports. Therefore in addition to the identification of ‘significant impacts’ a table could have been created with the recommendations and suggestions of the SA on how these need to be addressed in moving forward with the Policies and Sites to help avoid adverse effects.
Consultation

4.24 The process followed in the SA has created a large amount of documentation, meaning the SA Reports are both lengthy documents that are not very accessible and is unlikely to be read in their entirety by many respondents to the consultation process. This means that it is important that the SA Report, and particularly the non-technical summaries, should accurately reflect the outcomes of the appraisal, in a way that allows consultation respondents to make an informed response to the approach and findings of the appraisal process. The SA Report is quite brief in its description of the sustainability issues facing the SDF and the findings of the SA process, and its contents are primarily limited to fulfilling the requirements of the SEA Directive.

4.25 For instance addressing some of the matters discussed in paragraphs 4.5 to 4.12 may have been suitable for inclusion in the SA Reports, such as the overall impacts of a combined approach or the way in which policies have been used as mitigation tools.

5 Appropriate Assessment
5.1 The requirement for Local Development Frameworks (LDFs) to undergo appropriate assessment under the Habitats Directive is an issue that may need to be addressed in the SA of the SDF. From September 2006 there has been a requirement for appropriate assessment of LDF will be included in ‘The Conservation (Natural Habitats, &c.) (England and Wales) Regulations’. This means that appropriate assessment will now applies to LDFs, and therefore all component DPDs need to be screened to determine if it they impact either directly or indirectly on a Natura 2000 nature conservation site (Special Protection Areas or Special Areas of Conservation). If through screening it is identified that any policies, proposals or strategies of the LDF are likely to adversely effect such a site it will then have to undergo appropriate assessment to determine the significance of this impact, and whether it can be mitigated against or effectively compensated for.
5.2 For completeness the outcome of the screening stages should be documented and reported. It is usual for this to accompany the SA process, using the same reporting opportunities. It is unlikely that development in Sheffield City will have any great impact on these protected sites, although as part of screening it may be suitable to consider the potential for impacts on the nearby moors of the Peak District that are designated as SPA and SAC. However, it may be that the Council wish to undertake this requirement as a separate exercise from the SA, given the advance stage the appraisal process has reached. Whatever the outcome a screening decision should be documented to show the appropriate assessment requirement has been recognised and addressed.
6 Conclusions
6.1 Overall, the approach taken to SA has been very thorough, and has played an important role in developing and refining the options for the City Policies and City Sites DPDs of the SDF.
6.2 The SA process also appears to be fully compliant with the SEA Directive, although this will have to be maintained through later stages of the process, and moving forward to the SA Report of the submission versions of the two DPDs.
6.3 Some matters for consideration are raised in respect of the SA process. These mainly arise from the difficulties in appraisal of such a large number of options, and the detail and length of document this produces, with the related difficulties of understanding the appraisal as a cohesive whole. This means that it may have been useful for the SA to begin to draw together the outputs of the various SA processes of each DPD in order to identify their in-combination implications for sustainability. This could include how policies and proposal of some DPDs mitigation for the potential impacts of others.
6.4 Other issues include the possible need for greater clarity on the SA stages completed so far, including any appraisal of Emerging Options. This would be useful in detailing the effectiveness of the SA and how influential it has been in shaping the emerging DPDs.
6.5 The evaluation also identifies some instances where there may be issues relating to the way some matters have been addressed in the SA Reports. These may not be substantive and may be more of an issues of presentation and reporting leading to misapprehension of issues, rather than significant issues for the appraisal process itself. The two matters are, how Green Belt sites have been discounted from consideration in the SA. With the evaluation questioning whether it may have been suitable to test these alongside others urban sites to allow the consideration of the relative sustainability impacts being able to reduce development pressures within the urban area through releasing Green Belt land, with the potential for improved sustainability performance. The other matter is how flood issues have been addressed by the SA and whether the SA had a greater role in questioning the suitability of allocations in High Risk Flood Zones, particularly for those on which housing would be permitted, in order to make sure the adverse sustainability implications of these choices have been fully recognised.
Appendix 1: Evaluation of Compliance of the Sustainability Appraisal SDF City Policies Preferred Options with the Requirements of the SEA Directive

Reporting Requirements of SEA Directive (set out in Annex 1 of the Directive under article 5(1))	Signpost to the relevant SA Reports
a) An outline of the contents, main objectives of the plan or programme, and relationship with other relevant plans and programmes;	A detailed list of all other plans and programmes is included in Appendix 3 of the SA Report, these give details of the objectives of plans and programmes from an international and local level, and indicate how the SA of the SDF will take these into account. The most relevant plans, policies and programmes are identified in section 5 of the each of SA Reports in addition to the appendix, making clear the other plans, programmes and strategies that influence the selection and appraisal of preferred options of sites and policies. This therefore fulfils this requirement of the SEA Directive.
b) The relevant aspects of the current state of the environment and: the likely evolution thereof without implementation of the plan or programme;	A table of baseline data was drawn up for the Scoping stage of the SA, this table is included in the Appendix 4 of the report. This appendix is almost entirely quantified data that allows a subjective identification of issues in the plan area at a ‘snapshot’ in time. This quantified data is supplemented by an ‘Analysis of Baseline Characteristics’ in Appendix 5. This useful exercise gives quantified and qualitative descriptions of what the key sustainability issues facing the SDF area are, and allows all those reading the SA Report an understanding of the issues faced by Sheffield and therefore what the SDF is aiming to change. A summary of issues is also contained in the two SA Reports, although this could be expanded, particularly for the SA of the City Policies DPD to include material from Appendix 5. Additional sites specific information was also gathered for the SA of the options of City Sites. The sites appraisal was not based on site survey it was necessary to gather specific information for site, for example flood (using the Strategic Flood Risk Assessment) and access information, this was incorporated in the SA process. Further information can be found on this process are part of the background documents on the Baseline and Scoping Report of the SA. This requirement is fulfilled in the SA Reports by: an appraisal of the likely implications of a ‘do nothing’ approach in the City Policies SA Report, which considers the likely sustainability implications of continuing with UDP policy approaches the table of baseline data in Appendix 4 indicates the likely change in the baseline position under a ‘do nothing’ approach a ‘do nothing’ approach has not been carried out specifically for the City Sites, as no this does not present a ‘reasonable’ option.
c) The environmental characteristics of areas likely to be significantly affected; d) Any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC.;	These two stages are similar to one another and the requirements of (b). For the SA of the SDF these stages are carried out under the gathering of baseline information at the Scoping stage. That stage included the identification of those features that are most sensitive in the area, and therefore most sensitive to change, and those environmental and sustainability issues that are existing problems in the area and will need to be addressed in by the SDF. Again these are report in Appendix 4 and in Appendix 5.
e) The environmental protection objectives, established at international, Community or national level, which are relevant to the plan or programme and the way those objectives and any environmental, considerations have been taken into account during its preparation;	This requirement was completed at the same time as (a) and the relevant objectives are shown in Appendix 3 of the SA Report. Furthermore as part of the SA process, although not a requirement of SEA sustainability objectives were developed against which to measure the performance of the proposed policy and site options. The generic set of sustainability objectives and criteria, in Appendix 6a uses objectives of other plans and programmes and adapts them to use in the SA, as well as taking into account the identification of key sustainability issues in the area as identified as part of the Scoping process. In Appendix 6b these objectives are expanded to include specific ‘scoring’ criteria used in assessing the sustainability of proposed development sites for the SA of City Site proposals.
f) The likely significant effects (see footnote) on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors.	Sustainability objectives that cover all the issues listed for consideration under this requirement have been used as the basis of the appraisal, these are shown in Appendix 6. Table 1 in both SA Reports also show these objectives. Appendix 2 of the SA Report show the assessment and identification of sustainability implications of the City Policies and City Sites. This is a thorough assessment of each policy or site option against all of the objectives, seeking to identify the nature of the impacts on the factors listed, in addition to economic and social matters. From this ‘significant effects’ of the preferred options for both policies and sites have been identified and are reported as Table 7 in both of SA Reports for the DPDs.
Footnote: These effects should include secondary, cumulative, synergistic, short, medium and long-term permanent and temporary, positive and negative effects.	The SEA Directive seeks to ensure that it is not only the direct effects of the SDF on the environment are taken into account but also the other types of impact. Although the appraisal does not specifically seek to identify all these types of impact, in the commentary that accompanies the appraisal of options where it is apparent that effects beyond the direct will be experience this is made clear. This approach is satisfactory as it would unrealistic to expect all these type of effects to be considered for every option, and still to ensure a manageable task. Several key areas where cumulative impacts may arise have been identified, and reported in paragraph 7.6 in the SA Report of both DPDs.
g) The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme;	The issues that this requirement raises is different for both of the DPDs. The City Policies DPD has a key role to play in helping resolve issues that have been identified for mitigation through the SA of the other parts of the SDF, including the Core Strategy and City Sites proposals. Through setting appropriate policy impacts can be mitigated, such as potential adverse impacts on the natural environment through new development, and reducing travel impacts by prioritising public transport access to new development. However in some instances these policies raise issues in need of mitigation and this is highlighted in the policy appraisal of Appendix 2. Mitigation issues are covered in sections 6 and 7 of the SA Report of the City Policies DPD. The proposed development locations in the City Sites DPD raise a number of matters that may need mitigation. This is addressed within the site appraisal forms of Appendix 2, particularly where negative impacts have been identified. Section 7 of the relevant SA Report contains detail of the main types of mitigation measures identified, although specific site appraisal forms need to be referred to for particular issues. Some sites, listed in Appendix 2 have been removed from consideration due to mitigate against impacts through avoidance where overriding sustainability conflicts have been identified, e.g. areas identified as public open space.
h) An outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information;	It is reported in the SA Reports that the appraisal process has ‘contributed significantly’ towards the choice of preferred option. The City Policy SA Report states that the SA was influential in making decisions on the preferred option, as well as in determining alternatives to be considered. For the City Sites DPD the identification of all the possible sites was not the role of the SA, however the SA did play a key role in helping determine which were the preferred allocation sites. Although for this part of the SA only the preferred site allocations have been subject to a full sustainability appraisal using the objectives, with other sites that have been determined unsuitable simply listed as a schedule, and the process followed in excluding these is unclear in the SA or the text of the DPD itself. The SA Reports set out difficulties in undertaking the SA, both related to technical issues, knowledge and inherent in the process.
i) a description of measures envisaged concerning monitoring in accordance with Art. 10;	The City Policies DPD SA Report shows that monitoring for the SA will be linked into monitoring of the whole SPF using a set of joint indicators. These should be sufficient in enable monitoring of sustainability issues and potential significant environmental effects. The Appendix 8 of the SA Report sets out a proposed SDF monitoring framework, however this does not include the targets as set out in the text of the report. The City Sites will also be monitored through the SDF indicators and targets, and these will specifically seek to consider the employment and housing completions. It may also be worth the SA Report noting the importance of monitoring for potential cumulative impacts of site development, for example the total area of Zone 2 & 3, or the proportion of greenfield vs. brownfield completions. It is also not clear yet what the procedure will be for review of the DPDs where there are unfavourable monitoring findings in terms of sustainability impacts.
j) a non-technical summary of the information provided under the above headings	The SA Report contains a non-technical summary of the large amount of material produced for the SA. This part of reporting is an essential part of the SA as it synthesises the material down to a very manageable for and identifies what the main sustainability considerations are of the strategy and issues where there are likely to be sustainability implications, both positive and negative. It also provides a useful summary of the SA process and the main findings.
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 Sustainability Appraisal Panel meetings were held with a people representing a range of interests to consider the sustainability implications of policies and sites. 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 these SA Reports on the preferred options for City Sites and Policies were 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 Reports include details of how the SA process has made a difference to the SDF preparation process to date. This makes clear that although the SA of options has helped in identifying the sustainability implications of various approaches it is not the appraisal alone that is used in identifying the preferred approach. This is a permissible approach within the requirements of the SEA Directive, that only seeks that the environmental effects are recognised where an option is chosen that does not perform best in terms of environmental impacts the reason behind this can be justified. The SA process continues alongside the DPD preparation and therefore there will be an opportunity to take into account any comments made on the SA Reports and SDF at this consultation stage, making changes as necessary.

September 2007

SHEFFIELD CITY COUNCIL

Evaluation of the Sustainability Appraisal of the Sheffield Development Framework

Core Strategy Submission Version

DRAFT REPORT

1 Task
1.1 The purpose of this note is to evaluate and validate the sustainability appraisal (SA) process of the Sheffield Development Framework (SDF) Core Strategy Submission version on behalf of Sheffield City Council. This notes considers how effective the SA, undertaken by the Council, of the Submission Version DPD (Development Plan Document) is in meeting the regulatory requirements of Strategic Environmental Assessment (SEA) and SA, and also to reflect on whether the process followed is likely to be effective in producing a Core Strategy that will help implement more sustainable development in Sheffield.
1.2 The evaluation process seeks to consider the approach taken to the SA, and whether it has been carried out in compliance with the regulatory requirements of the SEA Directive (2001/42/EC), and is consistent with a good practice approach to SA. The purpose of the evaluation process is not include the checking of the assumptions and predictions made in appraisal of individual options, as this would be equivalent to re-appraisal, but it does consider the approach taken in the appraisal.
1.3 At this stage the evaluation looks at the way issues have been presented in this SA Report for the submission version. Details of the evaluation of the preferred option version can be found the earlier report prepared by Baker Associates⁴. However, this evaluation concentrates on the latest stage of the SA process, with only limited reference to past stages as they appear in this version of the SA Report. For a fuller picture of the overall evaluation process it may be worth referring to this earlier evaluation, in addition to the evaluation note prepared for the Preferred Options version of the City Site and City Policies⁵.
1.4 These SA evaluations have all followed on from early work undertaken by Baker Associates assisting on the development of sustainability objectives for the SA, and evaluation of the proposed approach to SA of the SDF⁶. 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.

2 Strengths of the SA
2.1 It has been noted in previous evaluations of the SA that the work on the appraisal has been very thorough. It has involved undertaking a sustainability appraisal running alongside plan making and assisting the preparation and selection of the preferred strategic and policy options. The SA has taken a rigorous and systematic approach throughout the process, whereby all emerging options have been subject to the same level of testing against the objectives of sustainable development, and now at submission the policies have been subject to similar rigorous assessment. The result of this is the time taken for the appraisal, and the resulting length of documentation, we made the process a significant undertaking.
2.2 Most importantly the SA has been shown to have played a key role in formulating options and selecting approaches, through the identification of the differing sustainability implications of the various proposed options. This is essential to the preparation of a ‘sound’ development framework.
2.3 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 very effective. The value of this approach has been 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.