Sustainability appraisal report

3 Compliance with the SEA Directive
3.1 The approach to the SA is to carry out a joint sustainability appraisal and assessment following the requirements of the SEA Directive, in line with current best practice on these matters.
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 report gives the wording of these sections of the SEA Directive and considers how the SA of the Sheffield Core Strategy submission version meets these requirements. This shows that the most the SA is in compliance and fulfils the requirements of the SEA Directive.
3.3 This analysis 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. The purpose of SA is not only to comply with the with the procedural requirements of the SEA Directive, but to help create a better, more effective plan that helps secure more sustainable development and this is something the evaluation concludes has been successfully carried out.
3.4 Section 4 discusses some matters that the evaluation raises in further detail, although as previously stated the evaluation has not identified anything that would see the SA fail in terms of meeting SEA requirements and SA guidance.

4 Matters arising from the SA

4.1 This section considers matters arising from the approach taken to the SA that require comment. For the most part these are support for the approach to the SA and the assumptions that have been used in the appraisal. It may be worth referring to the evaluation of the SA Report produced for the preferred options version in June 2006 for additional mattes in relation to the SA process as a whole.

4.2 The SA Report as it appears now is a very useful document as it draws together in a cohesive and comprehensive way the main strategic issue of the Core Strategy DPD and what, as a result to implementation of policy, would be the impact on sustainable development in Sheffield. This is the purpose of the SA Report, as it enables those reading the Core Strategy as it appears now understand how the appraisal of sustainability has been integrated into the plan, and also importantly it allows the identification of the issues where sustainability impacts may arise on implementation. This allows for other parts of the SDF to put in place appropriate policies, or select appropriate sites, that will ensure negative impacts are avoided or suitably mitigated against. Also it allows key matters where the sustainability impacts of policies are still uncertain to be monitored looking for changes in the baseline that would indicate undesirable impacts are occurring.
Role of SA in plan making

4.3 The SA has been completed through successive stages of preparation of the DPD starting at the emerging issues and options, continuing through the preferred options, to this submission version. This SA Report back across all these stages, pulling out the sustainability issues that arose at each stage, and indicating the influence this may have had on Core Strategy preparation.

4.4 The SA Report indicates that the SA has played a central role in choosing the preferred option and the form of the policies as they appear now in the Core Strategy. This has included refining policy wording and policy approaches to ensure topics are sufficiently well covered and addition of new policy topics to improve the sustainability performance of the Core Strategy. This evaluation is supportive of the input and influence that the SA has had into the plan making process, as the purpose of SA is to feed into plan making in the hope of making a better, more sustainable, plan. In particular the approach to give the sustainability findings weight in the decisions made is supported by the SA, such as with those associated with transport.
4.5 The approach to not always choose the most sustainable option as the preferred options is consistent with the regulatory requirements of SA, so long as the reasoning can be justified. There are instances in the Sheffield Core Strategy where a less sustainable option has been carried forward, with the justification of cost given as the reason for this.
Methodology and approach

4.6 The methodology sections set out in a clear and concise way the role of the SA and how it has been used in the preparation of the Core Strategy. In particular how the SA has played a part in identifying and refining strategic options for the DPD, with the purpose of identifying those that would lead to the implementation of development that helps meet objectives for sustainable development. This provides a useful record of the process followed, as well as helping to demonstrate how the SA meets the regulatory requirements of the SEA directive.

4.7 The approach taken to the SA makes it clear that there are a range of uncertainties and unknowns in this type of appraisal. The reason being that the appraisal is based at a strategic policy level, meaning that how the policy is implemented will ultimately determine the type of impact. Therefore, although aiming to be as objective as possible, there are elements of subjectivity throughout the assessment process and instances where the exact impact is unknown. The evaluation supports the approach taken in the SA Report, at Section 5, in acknowledging these uncertainties and the unpredictability of effects and making an attempt to be realistic in the assessment.
4.8 There are also risks of that as different teams were involved in the appraisal of the various policy topics there may be inconsistency in the way the appraisal was carried out and the weight attached to each sustainability objective. The SA Report indicates attempts have been made to overcome this through use of the Sustainability Appraisal Panel using internal evaluation of the appraisal matrices to look for inconsistencies, particularly in the relation to the weight flood risk is given. The approach is supported by the evaluation in seeking to ensure that the appraisal has been carried out using a common set of terms, removing individual subjectivity. This evaluation itself provides an independent check of the whole process, also helping to ensure any bias removed.
4.9 Section 5 also recognises that whatever the policy objective may be the choices that people make may counteract, or reinforce, desired sustainability benefits, or that matters beyond local control will impact on achieving goals, such as Government policy or the national economy. These are important points to reflect on as, although they will have a major influence over achieving more sustainable development, the SA can not base its assumptions and assessment on these matters. This approach is supported by the evaluation in order to make the appraisal process a manageable task.
Cumulative impacts

4.10 An important component of the of the appraisal of a strategic plan of this type is to consider what the combined impact of the proposed approach to development Sheffield may have on achieving sustainable development. It is also a requirement of the SEA Directive that the ‘synergistic and cumulative’ effects of the proposed plan are appraised as part of identifying where significance of impacts.

4.11 The SA Report includes a summary of the possible cumulative impacts of implementing the Core Strategy, that draws out material from the appraisal matrices, shown in Appendix 2. This indicates both where positive and negative combined impacts may arise. This helps to highlight the overall beneficial role of the Core Strategy in achieving more sustainable development, as well as identifying those areas where possible negative impacts may arise and therefore where there is a need to try and avoid or mitigate against these.
Mitigation

4.12 As required by the SEA Directive and as part of an effective SA, it is necessary to find ways of mitigating against the potential adverse effects of the Core Strategy. It is clear that the SA has played a vital role in this process of identifying ways in which the potential impacts identified can be avoided and mitigated through the SDF. This includes changes as simple as policy clarification and wording, to the need for policies in the City Policies DPD created with the express purpose of mitigating impacts, such as in promoting high quality design.

4.13 This evaluation supports the approach taken to mitigation. However it may be necessary to ensure that there is suitable verification and cross checking between the other parts of the SDF and the Core Strategy, so that the ways of avoiding and mitigating against potential impacts identified as part of this SA are taken forward into other policies and proposals of the SDF. In order for this to be effective it may be necessary to have a schedule of all the potential negative sustainability impacts, and the measure envisaged to mitigate against these. This may need to include the mechanism by which the level of planning that the mitigation measures will be addressed, for example through Core Policies, through appropriate allocation of sites, through detailed work by development control such as in securing section 106 agreements, or through the implementation of other strategies such as the Local Transport Plan.
4.14 The need to ensure the SA of the various DPDs provides a joined up and comprehensive coverage of the potential sustainability impacts of the whole SDF is essential. With the need to suitably acknowledge in the separate SA Reports the influence of other parts of the DPD on the choices and selection of policies and proposals, and the need to take a complete view of the sustainability impacts of the SDF. This may be of particular importance in the SA Reports of lower tiers of the SDF, rather than the Core Strategy, given the purpose of these lower level documents to set out the finer detail and act as the policy tools for avoiding potential adverse effects of implementing the Core Strategy.
Monitoring

4.15 In order to successfully monitor the SA it may be useful to draw out from the monitoring framework for the SDF those indicators that are relevant to the sustainability impacts of the Core Strategy as identified through the SA process. This may include the suggestions for additional criteria if those proposed from the SDF do not cover all suitable issues.

5 Appropriate Assessment
5.1 From September 2006 the requirement for appropriate assessment of SDF has been included in ‘The Conservation (Natural Habitats, &c.) (England and Wales) Regulations’. This inclusion means that appropriate assessment will now apply to Local Development Frameworks, and therefore all component DPDs will be 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 the SDF is 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 The SA includes reference to the screening for appropriate assessment, and that it has been determined by the Council in conjunction with Natural England that there is no need to carry out a full assessment of this kind. The reason being that no internationally designated sites for nature conservation are likely to be effected by development in Sheffield SDF area.

Appendix 1: Evaluation of Compliance of the Sustainability Appraisal SDF Core Strategy submission version 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 5 of the SA Report, these give details of the objectives of plans and programmes from an international to local level, and indicate how the SA of the SDF will take these into account. There is also reference the Core Strategy as part of the larger SDF and the overall purpose of preparing a cohesive whole. There need for the SA of each of the DPDs to reflect that these are integrated appraisals of integrated documents, and ensure that the mitigation measures, for instance, are appropriate addressed.
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 6 of the report. This baseline information collection exercise was almost entirely quantified, which although removes subjectivity does mean that the overall character of the area is lost and could have been enhanced by the inclusion of more qualitative detail of the area. Appendix 7 contains an ‘Analysis of Baseline Characteristics’, 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. Some key matters are also addressed in the text of the SA Report in section 3, although these do not cover all topics of Appendix 7, and it may have been useful to include some additional discussion on these matters and their influence in helping prepare the sustainability objectives for the SDF. This has been fulfilled throughout the SA stages of the emerging Core Strategy, and it is set out in the text of the SA Report how the appraisal was carried at each stage. Including at emerging issues and in the preparation and appraisal of preferred options, where a ‘do nothing’ approach was appraised where there would be no policy change and the UDP policy approach would remain. This requirement is also met through the inclusion in the table of baseline data in Appendix 5 under the ‘do nothing’ scenario.
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 current environmental and sustainability issues in the area and will need to be addressed in by the SDF. Again these are reported in Appendix 6 and in Appendix 7.
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 relative objectives are shown in Appendix 5 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 options. This framework 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, these are reported in full in Appendix 1.
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 objectives are included in table 1 of the SA Report. The effects of the emerging Core Strategy proposed policy and approach have been repeatedly appraised through the preparation of the DPD. This included identifying, refining and helping select the preferred policy approach, and as part of each stage the ‘significant effects’ were on sustainability were identified. The appraisal matrices through which effects were assessed is shown in Appendix 3. Significant effects of the preferred option of the submission version are reported in table 8 and 9 of the SA Report, these summarise the findings of the completed appraisal matrices, indicating where potentially significant effects, both positive and negative, have been identified for each policy topic area. Table 10 also is useful in showing how the Core Strategy will meet the sustainability objectives developed for the SDF which is also useful in identifying significant effects.
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 that 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. The SA Report in section 7 (from 7.10) shows the likely cumulative and other effects of the Core Strategy, summarising parts of the matrix appraisal in Appendix 3. This draws out matters from the DPD that together may have a combined impact, allowing where necessary the need for mitigation to be identified. As the other SAs are carried out of the various component parts of the SDF it may also be necessary to draw together any combined impacts of the different documents that have been identified. The purpose of which would be to see how the SDF as a whole would have an impact on sustainability, and any matters that may still require mitigation.
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 appraisal matrices in Appendix 3, include details of where impacts arising will need to be mitigated against. Furthermore in Section 7 (from para 7.16) these issues are drawn together highlighting key matters for mitigation, and how this can be undertaken. It will be vital to ensure this identification of mitigation measures is complete as possible, particularly those matters that need to be specifically addressed in other parts of the SDF such through appropriate City Policies, so that there is sufficient time to incorporate these into those documents. It will then be important for SA of those parts of the SDF to ensure all matters have been suitably taken into account as part of a joined up approach to SA, as set out under (f) above.
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;	The SA has played an important role in refining and helping in the choice of preferred option for this submission version Core Strategy. This has included the appraisal of the emerging Core Strategy from the early issues stage and then in the selection of preferred options up to this point of defined policies. The SA Report reflects on the role the appraisal has played in this selection of alternatives, and includes examples of the justification given where the option identified as most sustainable has not be chosen. The appraisal matrices in Appendix 3 shows the appraisal of the individual policies of the submission version and the rejected alternatives, providing a summary of the alternatives that were appraised as part of the extended process of sustainability appraisal. This gives a clear audit trail of policy evolution and the role of the SA. It may also be suitable for the text of the Core Strategy itself to reflect on the sustainability appraisal process and its role in creating a more sustainable plan. Section 5 of the SA Report sets out principles by which the SA was undertaken, and this includes a useful reflection on the difficulties and uncertainties inherent in SA of this type of plan, and the strategic level on which issues are addressed.
i) a description of measures envisaged concerning monitoring in accordance with Art. 10;	Monitoring measures are set out in the section 8 of the SA report and are supplemented by Appendix 11. It is proposed that the monitoring framework for the SDF will also serve the purpose of monitoring for the SA. A supplementary report has been produced, titled ‘Core Strategy – Proposals for Monitoring’. This clearly shows that the SA has had an influence over the selection of indicators for monitoring, both as part of the baseline information collection and as part of the identification of significant effects. It may be suitable to elaborate on the role the SA has played in developing monitoring arrangements for the SDF within the section 8. It is worth reflecting that this is only the SA of part of the SDF and that it will be necessary to integrate into the monitoring framework any other significant impacts identified as part of the appraisal of other component parts of the SDF, to ensure that all impacts are suitably addressed as part of a common process.
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.
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 8 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. The use of a Sustainability Appraisal Panel that included representatives of the environmental, social and economic sectors in Sheffield enabled people to have a direct input into the appraisal process. Meetings were held in April 2006 where the Panel scrutinised the sustainability appraisal matrices produced by planning officers as part of testing the emerging options for Core Strategy policy. 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 submission version will be available for consultation on alongside the DPD. The SA Report produced at consultation was also subject to consultation with the DPD at that stage, and the outcomes of this process and responses received are contained in Appendix 9 of this SA Report.
• 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 and the policy to submission. This is detailed throughout the SA Report in the discussion of how the SA was one of influences to the emerging strategy and policy approaches. It may be suitable for the text of the Core Strategy DPD itself to reflect on the role of the SA in shaping the plan, and ensuring that sustainability considerations have been at the heart of decision making.

1 Baker Associates (May 2004), Evaluation of the Sustainability Appraisal of the Sheffield City Plan, Initial Report (revised)

2 Baker Associates (May 2004), Evaluation of the Sustainability Appraisal of the Sheffield City Plan, Initial Report (revised)

3 Baker Associates (July 2006), Evaluation of the Sustainability Appraisal of the Sheffield Development Framework Core Strategy preferred options

4 Baker Associates (June 2006), Evaluation of the Sustainability Appraisal of the Sheffield Development Framework Core Strategy Preferred Options (Draft Report)

5 Baker Associates (July 2007) Evaluation of the Sustainability Appraisal of the Sheffield Development Framework City Sites and City Policies Preferred options Development Plan Documents

6 Baker Associates (May 2004), Evaluation of the Sustainability Appraisal of the Sheffield City Plan, Initial Report (revised)