SA of Canalside DPD
2.0 SUSTAINABILITY APPRAISAL METHODS
Approach, Guidance & Methods
2.1 SA incorporating SEA is a mandatory requirement for Local Plan documents in accordance with paragraph 32 of the National Planning Policy Framework (revised 2018)[15]. Guidance on undertaking SA/SEA of plans is provided through UK government planning practice[16]; guidance[17] on HRA for plans is also available. The SA and HRA have been undertaken in accordance with this government guidance and drawing upon professional experience.
2.2 The SA has built upon the previous SA work undertaken during the development of the Local Plan, refining it to be focused on the Canalside DPD with relevant sustainability topics and issues. The opportunity was taken to update the assessments in line with the revised NPPF (2018) and the updated requirements for HRA.
2.3 Available information from Defra Magic maps, Environment Agency flood risk maps, the Council's evidence base for the local planning documents, and the evidence base for the draft Canalside DPD, together with professional judgment, was used to identify the sensitivity of the DPD area and to undertake the assessments.
Screening & Scoping
2.4 The scoping for SA/SEA considered whether the policies and proposals in the emerging DPD are likely to have significant sustainability effects, as follows:
- how they might affect the environment, communities or economy
- whether any of the proposals are likely to affect a "sensitive area", such as a Site of Special Scientific Interest (SSSI) or an internationally designated Site for nature conservation (SAC, SPA, Ramsar)
- whether implementation of policies in the plan might lead to new development in the future
The DPD includes new policies, including 3 site-specific policies for land adjacent to the canal; the canalside areas include nationally important natural and historic environmental assets and their settings.
2.5 The scoping/screening for HRA considered whether the draft DPD could have any likely significant effects (LSEs) on internationally designated sites – Special Protection Areas (SACs), Special Areas of Protection (SPAs) and Ramsar – alone or in-combination with other plans or projects. There is only one isolated internationally designated site – Ensor's Pool SAC – within the Warwick District area. There are no other designated sites within a 20 km radius and therefore, unlikely to be significant effects. However, since the DPD is focused on canals that are linked to other water systems, such as the River Severn, there could be the potential for environmental pathways and implications for functionally linked land and water connected with the Severn Estuary SPA/SAC/Ramsar.
2.6 Therefore, the HRA screening stage has been developed further and the appropriate assessment stage applied with regard to potential changes to water quality & water levels. The HRA process comprises two stages: an initial screening stage considers whether a plan or project is likely to have a significant effect on a European site either alone or in combination with other plans or projects. If likely significant effects (LSEs) are identified through the screening stage, then the plan or project should be tested through a second stage – the appropriate assessment (AA). The Warwick Local Plan and the DPD do include relevant policy mitigation and the approach essentially reinforces this through the updated methodology - thus making the process and conclusions explicit with regard to the updated requirements. This precautionary approach is being taken in particular consideration of the significant changes to HRA methods in the UK since the screening undertaken for the Local Plan.
The SA Framework
2.7 The SA Framework provides the basis by which the sustainability effects of the DPD are described, evaluated and options compared. It includes objectives, elaborated by decision making criteria, that are relevant to the objectives of the Local Plan and the DPD, the role and duties of the Warwick District Council, and sustainable development in the Warwick and canalside areas. These objectives were identified through the SA scoping stage for the Local Plan from the information collated in the plans & programmes review, baseline analysis, identification of sustainability issues, and subject to consultation. This SA Framework is the same as that used to assess the emerging Local Plan in order to clearly demonstrate conformity with the higher level of development planning and assessment, as follows:
Table 2.1: SA Framework
Objective |
Key Questions |
1. To have a strong and stable economy
SEA Directive topics: population & health
|
Will it help meet the employment needs of the local community? Will it help diversify the economy in general? Will it enhance the vitality and viability of the town centre? Will it encourage or enable inward investment? Will it promote investment in future prosperity (for example by supporting R&D, small businesses and/or encouraging skills development)? |
2. To enable a range of sustainable transport options SEA Directive topics: air, climatic factors, health |
Will it encourage the use of public transport, walking or cycling? Will it help reduce traffic congestion? |
3. To reduce the need to travel SEA Directive topics: air, climatic factors, health |
Will it reduce the overall need to travel? Will it help reduce the need to travel by car / lorry? |
4. To reduce the generation of waste and increase recycling SEA Directive topics: soil, health, biodiversity |
Will it encourage the management of waste in line with the waste management hierarchy, giving first priority to reducing waste, followed by reuse and recycling, then other forms of energy recovery and lastly disposal? Will any residual disposal be undertaken in the least environmentally detrimental manner? |
5. To ensure the prudent use of land and natural resources SEA Directive topics: biodiversity, flora, fauna and soil |
Does it optimise the use of previously developed land and buildings? Will it minimise development on Greenfield land? Will it reduce the amount of derelict, degraded or underused land? Does it make efficient use of existing physical infrastructure (i.e. instead of requiring new infrastructure to be built)? Does it encourage resource-efficient design and/or construction (in terms of water and/or raw materials)? Does it encourage the use of materials from alternative and renewable sources? |
6. To protect and enhance the natural environment SEA Directive topics: biodiversity, flora, fauna and landscape |
Will it protect and enhance species, habitats and sites designated for their nature conservation interest? Will it safeguard and/or enhance the character of significant landscape areas? |
7. To create and maintain safe, well-designed, high quality built environments SEA Directive topics: landscape, cultural heritage |
Will it help provide a sense of identity and local distinctiveness? Will it protect or enhance the setting of the town? Will it promote design that enhances townscapes? Will it protect or improve safety in built environments? |
8. To protect and enhance the historic environment
SEA Directive topics: cultural heritage |
Will it protect and enhance sites, features and areas of historical, archaeological and cultural value? Will it encourage appropriate use of and/or access to buildings and landscapes of historical/cultural value? |
9. To create good quality air, water and soils SEA Directive topics; soil, water, air |
Will it affect local air quality? Will it affect air quality in the Air Quality Management Areas? Will it minimise pollution of soils? Will it minimise light and noise pollution levels? Will it retain the best quality agricultural land? Will it minimise adverse effects on ground and surface water quality? Will it prevent deterioration of water quality as measured by the Water Framework Directive? |
10. To minimise the causes of climate change by reducing greenhouse gases and increasing the proportion of energy generated from renewable and low carbon sources. SEA Directive topics: air, climatic factors |
Will it reduce overall energy use through increased energy efficiency? Will it reduce or minimise greenhouse gas emissions? Will it increase the proportion of energy generated from renewable and low carbon sources? |
11. To adapt to the predicted impacts of climate change including flood risk SEA Directive topics: water, climatic factors |
Will it reduce or minimise the risk of flooding? Will it minimise sensitive development in medium and high risk flood zones? |
12. To meet the housing needs of the whole community (ensuring the provision of decent and affordable housing for all, of the right quantity, type, size and tenure) SEA Directive topics: population, health |
Is it enabling the housing target to be met? Does it provide for the development of balanced communities by encouraging an appropriate mix of housing (in terms of type, size and tenure)? Will it reduce homelessness and housing need? Will it reduce the number of empty homes? |
13. To protect, enhance and improve accessibility to local services and community facilities SEA Directive topics: population, health |
Will it maintain and enhance existing community facilities? Will it put unacceptable pressure on existing services and community facilities? Will it improve access to local services and facilities for the whole community? |
14. To improve health and well being SEA Directive topics: health |
Will it promote healthy lifestyles? Will it provide and improve access to health and social care services? Will it provide and/or enhance the provision of open space? Will it improve opportunities to participate in the district's cultural, sport and recreational opportunities? |
15. To reduce poverty and social exclusion SEA Directive topics: population, health |
Will it reduce poverty and social exclusion in those areas most affected? |
16. To reduce crime, fear of crime and antisocial behaviour SEA Directive topics: population, health |
Will it reduce actual levels of crime? Will it reduce the fear of crime? Will it reduce / discourage anti-social behaviour? |
Table 2.2: Significance Key
Categories of Significance |
|||
Symbol |
Meaning |
Sustainability Effect |
|
++ |
Major Positive |
Proposed development encouraged as would resolve existing sustainability problem |
|
+ |
Minor Positive |
No sustainability constraints and proposed development acceptable |
|
= |
Neutral |
Neutral effect |
|
?
|
Uncertain |
Uncertain or Unknown Effects |
|
- |
Minor Negative |
Potential sustainability issues: mitigation and/or negotiation possible |
|
-- |
Major Negative |
Problematical & improbable because known sustainability issues; mitigation likely to be difficult and/or expensive |
|
+ |
-
|
SA Objectives 2, 5, 6, 13 and 14 consider more than one topic & as a result there is the potential for different effects. For example, Objective 2 relates to encouraging the use of public transport, walking & cycling as well as reducing traffic congestion. Development could have a negative effect on traffic; however, it could also provide new cycle/walking routes with a positive effect – and thus, two symbols. |
|
Appraising the Warwick Canalside DPD
2.8 The number and extent of reasonable alternatives to be considered through plan-making and the SA are limited. However, the development of the draft DPD has considered vacant or under-utilised land and/or opportunities for regeneration. Section 6 in the draft DPD carefully explains the approach and that the adopted Local Plan identifies some potential areas for additional residential development alongside the canal in urban areas. Appendix 1 lists the potential sites A-Z that were investigated. The 3 areas identified within the Local Plan are proposed to be taken forward in the DPD and these three sites were assessed as the reasonable alternatives identified.
2.8 The 3 DPD site-specific Policies CS9-CS11 will be assessed using the full SA framework and details provided in an appendix in order to show compatibility and correlation with the SA of the Local Plan. The assessment of the other DPD Policies and the DPD as a whole will be presented as a narrative to allow the SA to focus on the aspects of the DPD that are likely to have significant effects, thus providing further detail whilst minimising the number of detailed technical matrices. It allows for the consideration of mitigation measures that may be provided through policies in the adopted Local Plan and embedded within the DPD. This is appropriate and proportional for the level of plan-making and assessment. The SA objectives were grouped into sustainability topics, as follows:
- Economy: SA No 1 Economy
- Housing, Communities, Health & Wellbeing: SA No 12 Housing; SA No 13 Access to Services/Facilities; SA No 15 Reduce Poverty; SA No 16 Reduce Crime
- Transport: SA No 2 sustainable Transport; SA No 3 Reduce Need to Travel
- Air Quality & Climate Change: SA No 9 Good Quality Air; SA No 10 Minimise Causes of Climate Change
- Land/Soil Resources: SA No 4 Reduce Waste; SA No 5 Land/Soil & Sustainable Construction; SA No 9 Good Quality Soils
- Natural Environment: SA No 6 Biodiversity; SA No 6 Landscape; SA No 7 High Quality Design
- Historic Environment: SA No 8 Historic Environment
- Water: SA No 11 Adapt to Impacts of climate change – flooding; SA No 9 Good Quality Water
2.9 The assessment includes consideration of the likely effects on sustainable development, including short, medium and long-term effects, permanent and temporary effects, positive and negative effects, and secondary, cumulative and synergistic effects in accordance with Schedule 2 12(3) of the SEA Regulations. Any possibilities for mitigating any potential significant negative effects, or enhancing potential positive effects, were suggested to the plan-makers, as relevant.
Consultation
2.10 The SA/SEA & HRA scoping and screening report (September 2019) was sent to the statutory environmental bodies for 5 weeks consultation in early September. No comments were received from the Environment Agency at this stage. Historic England advised that they support the approach to the SA process and how it will link in to the SA work previously undertaken in respect of the Local Plan. They made some suggestions for clarification on two of the decision-aiding questions in the SA Framework – relating to settings of heritage assets and archaeology. Also, to consider replacing protect with conserve in line with updated NPPF terminology.
2.11 Natural England advised that they agree with the conclusions provided in the HRA and welcomed the precautionary approach described regarding appropriate assessment, in particular with respect to water levels and water quality. NE indicated that they would like to share the emerging evidence base in relation to the Severn Estuary SPA. NE is aware that SPA birds can travel across and up to the Vale of the Cotswold Scarp and as far north as Longdon Marsh on the Worcestershire/Gloucestershire border and such land is likely to form functionally linked land. NE generally supported the sustainability objectives in the SA framework.