SHEFFIELD LOCAL PLAN (FORMERLY SHEFFIELD DEVELOPMENT FRAMEWORK)
CITY POLICIES AND SITES SUSTAINABILITY APPRAISAL REPORT
Appendix 9 Baker Associates Evaluation of City Policies and City Sites Preferred Options Sustainability Appraisal Reports & Core Strategy Sustainability Appraisal
Sheffield City Council
1 Union Street
S1 2SH February 2013
Evaluation of the Sustainability Appraisal of the Sheffield Development Framework: Core Strategy Preferred Options
Evaluation of the Sustainability Appraisal of the Sheffield Development Framework: City Sites and City Policies Preferred Options
Evaluation of the Sustainability Appraisal of the Sheffield Development Framework: Core Strategy Submission Version
SHEFFIELD CITY COUNCIL
Evaluation of the Sustainability Appraisal of the Sheffield Development Framework
Core Strategy Preferred Options
1 Task 1.1 The report provides Sheffield City Council with an evaluation and validation of the sustainability appraisal (SA) process of the Sheffield Development Framework (SDF) Core Strategy Preferred Options version. 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.
1.3 This evaluation concentrates on the latest stage of the SA process, which is the Preferred Options pre-submission version of the Core Strategy, with only limited reference to past stages, such as baseline data collection and the initial stages of options appraisal.
1.4 This 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 20041. 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 The work on the SA has been very thorough in its approach. This has involved undertaking a sustainability appraisal of all of the options presented in the Emerging Options document and the Preferred Options report. The SA has taken a rigorous and systematic approach, whereby all emerging 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 approaches. This has meant that 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’ LDF.
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 extremely 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.
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 Preferred Options 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. However, it may be suitable to raise them as considerations for further thought. 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. 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.
3.4 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.
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 not issues of fundamental importance to the SA process and only those that may require some further reflection when moving forward with the appraisal to the submission version of the Core Strategy.
SA of Options
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 Core Strategy Emerging Options Paper and the Preferred Options report, and the decision to appraise all of these in detail as part of the SA process. This meant that in this version of the SA Report there are around 86 issues to be appraised, most of which consisted of one or more alternatives to a preferred option on the matter in question.
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 desire to identify the most sustainable approach to the core spatial strategy in the SDF area. The large amount of information from this assessment has meant that to some extent the sustainability implications of the core strategic spatial options have become hidden amongst the appraisal of the other more specific area based options. This means that it not immediately apparent from this SA Report the overall sustainability implications of implementing the preferred options set out as a cohesive core strategy for the SDF. This is mainly because the options and their appraisal are all presented as independent of one another, so their interaction and cumulative effect is not shown. Again this is not only an issue of the SA, but stems from the lack of overall approach to setting what the overarching strategic policy in the Preferred Options document itself. Although the preferred options document Section 5 does contain a description of what the preferred strategic approach would be.
4.4 The non-technical summary goes some way to providing a joined up analysis of sustainability effects. This section of the SA Report includes some analysis of what the overall sustainability implications of implementing the preferred approach might be. However, it may have been more suitable for the SA Report to draw together the strands of the options appraisal into a review of the likely sustainability impacts of the strategy as it is detailed in section 5 of the Preferred Options Report. This would be of particular use in helping the understanding of those wishing to comment on the sustainability of the approach being put forward through the Preferred Options document, and the SA itself.
4.5 There is also a difficulty in appraisal of options once this Preferred Options stage is reached, and this is that the preferred option is set out in a more detailed way than the rejected alternatives. This means that appraising the preferred option is a more straightforward task as the proposed approach is less open to interpretation. This raises some difficulties when trying to compare the relative sustainability impacts of various approaches, as predicting the impacts of rejected approaches can raise many uncertainties.
4.6 The evaluation notes that the approach to SA, and comparison of options, does not rely on any scoring system or counting of ticks or crosses, and this is welcomed in terms of carrying out a useful SA process. The approach followed means that the difficulty of weighing the importance of meeting one objective against another is recognised, and that approaching selection options through a more qualitative process is likely to lead to more robust outcomes.
4.7 The SEA Directive, in a footnote to Annex 1 (f), seeks for the assessment to consider effects beyond the direct and immediate. As show in Appendix 1 of this report, this is carried out to a limited extent in this SA through the text summaries accompanying the appraisal of options in Appendix 2 of the SA Report. Assessing the full range of impacts for all of the options appraised would not be a reasonable task, with the time taken to consider these and the ability to accurately estimate impacts disproportionate with the value this would add to the appraisal. However, it may have been suitable for the SA to have considered the cumulative impact of implementing the preferred approach as it is set out in Section 5 of the Preferred Options for the Core Strategy report. It may have been appropriate for the SA to consider the implications of the strategy as a whole seeking to identify any potential cumulative negative effects, in addition to considering the relative effects of the individual policy options.
4.8 The collection of baseline information for the SA has concentrated almost exclusively on the collation of quantified data from a range indicators. This approach is useful in providing the baseline for quantified monitoring of change over time in the SDF area. However, part of the requirements of the SEA Directive is to identify what the key problems or issues are in the area that should be addressed in the assessment. This calls for a more qualitative approach to baseline information. Also for social data where cause and effect relationships of the development plan can be very difficult to identify, using qualitative description that sets out what the desired direction of change would be may be the most appropriate approach. This qualitative identification of issues has been undertaken for the SA, though it is only included as an Appendix to the SA Report. To aid understanding of what the purpose of the SA is, and to give context to the appraisal, it may have been useful to incorporate this within the main body of the Report.
4.9 The process followed in the SA has created a large amount of documentation, meaning the SA report is a lengthy document that is not very accessible and is unlikely to be read in its entirety by many respondents to the consultation process. This means that it is important that the SA Report, and particularly the non-technical summary, 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.
4.10 The lack of more descriptive material in the SA Report also may restrict the clarity of the SA for those who are unfamiliar with the process, and therefore be a further restriction on understanding and being able to respond to the findings of the SA.
The use of SA in influencing the development of the Core Strategy
4.11 The SA Report describes the extent to which the SA process to date has influenced the choice of options from the Emerging Options paper to the Preferred Options stage. It would appear that the SA has had a substantial impact, and this indicates that the process being followed is effective and the SA is achieving its key role of creation a better and more sustainable plan.
4.12 In the appraisal of the options of the Preferred Options report it is evident from the concluding comments for some options that the preferred choice in not simply based on sustainability considerations. For example in PW1 the preferred option has been selected based on it being the more cost effective approach. Choosing an approach that is not shown to be the most sustainable is entirely compatible with SA, and the SEA Directive, so long as the choice is appropriately justified. However the SA should ensure hat it only covers sustainability matters in the appraisal of options, as set out in the objectives, and does not seek to justify choices made or conclusions reached beyond this remit. For example in a few instances in the SA Report Appendix 2 the issue of cost is identified as the reason for choosing one option over another, which may be beyond the role of SA. Justification of the chosen option beyond sustainability issues should be reported as part of the SDF preparation process.
4.13 The list of monitoring indicators put forward for the sustainability appraisal is very comprehensive. However how effective some indicators will be at monitoring the effects of SPF implementation is not clear due to the number of other influences on them. Indicators need to be selected specifically for monitoring the predicted effects on matters that are part of the SA, and on issues over which the SDF will have some effect.
4.14 The SEA Directive sets out that the specific task of monitoring is to monitor the significant environmental effects of the implementation of the LDF, with the purpose being to identify unforeseen adverse effects. Therefore it may not be suitable to finalise a monitoring framework until the final SA Report has been produced and has identified what may be the main impacts of the SDF Core Strategy.
4.15 The SEA Directive, and guidance on SA, makes it clear that the monitoring for the appraisal process can be part of monitoring for the SDF. It may be most appropriate to integrate SA monitoring into LDF monitoring. This approach also advisable as an integrated approach will help to ensure that if unexpected adverse effects are found to be occurring it can trigger a review of the relevant parts of the SDF to offset negative effects. If monitoring were carried out of the SA alone, coordinating such a review may be more difficult.
5 Appropriate Assessment 5.1 The emerging 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 the requirement for appropriate assessment of LDF will be included in ‘The Conservation (Natural Habitats, &c.) (England and Wales) Regulations’. This inclusion will mean that appropriate assessment will now apply to LDFs, 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 LDF 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 For completeness the outcome of the screening stages should be documented and reported. Current thinking on the approach to be taken is to integrate appropriate assessment and SA to as great an extent is possible, and therefore use 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.
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 Core Strategy 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 version of the Core Strategy. This includes identifying what are likely to be impacts of the Core Strategy on sustainability, including consideration of how development control policies might be used to mitigate against these.
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 also highlights that the appraisal does not include an appraisal of the cumulative effects of the implementation of all the preferred options into a cohesive strategy for development in the SDF area. This omission from the SA could mean that the preferred approaches taken, when implemented as a whole, are no longer identified as the most sustainable approach due to cumulative effects and conflicts. Therefore to clarify this, and identify other effects, it may have been suitable to undertake such an appraisal.
6.4 Other issues raised in part relate to the lack of an appraisal of a cohesive ‘core strategy’ and the accessibility of the document to readers who are unfamiliar with SA, but yet want to make a response or understand the process, due to its length and the limited description of the findings of the appraisal and baseline context. Although the inclusion and clarity of writing mean that to some extent the non-technical summary to overcoming this issue.
Appendix 1: Evaluation of Compliance of the Sustainability Appraisal SDF Core Strategy 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. 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 5 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 8 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, and for this reason could be usefully contained within the main text of the report instead of as an Appendix. 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 by the inclusion in the table of baseline data in Appendix 5 under the ‘do nothing’ scenario. Furthermore in the appraisal of option, as shown in Appendix 2, the ‘continue with UDP’ approach is often citied, and this shows the likely impacts on sustainability of continuing with existing policy.
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 5 and in Appendix 8.
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 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 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 6.
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, and again The sustainability objectives are used as a baseline against which all of the options have been tested, and this is reported in Table 5 of the main report and in Appendix 2.
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.
However, it may have been suitable for the SA to give some more consideration to the cumulative effect of implementing the combined preferred option approach for all of the issues. This is addressed to some extent in the text of the non-technical summary, although this drawing together the diverse strands of the strategy from all the preferred options presented may help to add clarity to the likely overall sustainability impacts of implementing the preferred strategic approach.
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;
This requirement is partly fulfilled by the selection of alternatives that have are better in terms of achieving more sustainable development. Fulfilling this requirement will be an ongoing process throughout the preparation of the SDF, for example through developing specific policy or planning obligations to offset potential adverse impacts.
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 selection of alternatives was largely the role of the SDF preparation and this is reported in the Emerging Options Report and other background reports. However, the SA of these emerging options was also an important component of the choosing and refining the preferred option.
Difficulties in the SA are reported in the text of the SA Report at Section 3.
i) a description of measures envisaged concerning monitoring in accordance with Art. 10;
The proposed monitoring framework is linked to establishing sustainability objectives for the SA, and the collection of baseline information. The proposed monitoring framework at present is very detailed, with numerous indicators. In moving forward with the SA process it may be necessary to consider refining these and selecting a core set to monitor the SA as part of the monitoring process for the RSS. In selecting indicators it is vital that those chosen relate directly to the likely effects identified through the SA, and will provide a measure of matters over which the SDF could have a direct influence, and there is a sufficiently clear cause and effect relationship.
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. The information here goes beyond summarising the large amount of analysis in the main SA Report and Appendices and is the only location where the findings of the appraisal are brought together into an easily comprehensible whole.