South Gloucestershire New Local Plan Phase 1 Responses

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Response #917454

Response #917454
From Ashfield Land
Agent Matthew Kendrick - Grass Roots…
Date Started: 31 Mar 2021 19:55. Last modified: 31 Mar 2021 19:55
Status Complete
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1: Understanding who is responding

Please help us understand the type of groups and people that are responding and engaging with the preparation of our new Local Plan, by choosing which one of the following stakeholder groups you best represent.


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Developer, land agent or site promoter
If other, please state:
«No response»

2: Comments on the Sustainability Appraisal

If you have any comments on the Sustainability Appraisal please tell us below:

3.0 THE SUSTAINABILITY APPRAISAL:

3.1 There were significant issues with the Sustainability Appraisal that supported the JSP. The primary issue was that the detailed version was undertaken after the Spatial Strategy and certain sites were selected, meaning that the strategy was clearly pre-determined and not justified by the evidence base.

3.2 We are pleased to see that the Issues and Approaches consultation document is accompanied by two SA Reports which indicates that this is assessment is being considered at an early stage within the Plan-making process. One report has been prepared by SGC, the other undertaken by Land Use Consultants (LUC). The SGC report represented an early scoping report that was intended to set the context and objectives of the SA and establish the baseline of this assessment.

3.3 The LUC report further develops this baseline and attempts to provide a SA assessment of the ‘Building Block’ strategy options that the Local Plan is considering, set against the identified 9 key priorities that the SGC scoping document established.

3.4 We have examined both SA Reports in detail and have some comments and concerns in respect of the following key issues.

3.5 Firstly, the SA focuses on the appraisal of the ‘Building Block’ options that the Local Plan is considering. However, these are in effect Spatial Strategies as we set out in the previous section and we have questioned whether it is appropriate that these are determined at the Local Plan, rather than the SDS level.

3.6 Secondly, we have concerns over paragraph 2.10 of the LUC Report which states:

“The SA findings are not the only factors taken into account when selecting options to take forward in a Plan. Indeed, there will often be an equal number of positive or negative effects identified for each option, such that it is not possible to ‘rank’ them based on sustainability performance in order to select an option. Factors such as public opinion, deliverability, and conformity with national policy will also be taken into account by Plan-makers when selected options for their Plan.”

3.7 We disagree with this approach; as we previously demonstrated as part of evidence connected to the JSP, it is possible to provide a ranking system by applying a simple weighting value to each of the effects identified as part of Figure 2.1 of the LUC report. This will then give a ranking system that is easy for the public to relate to. If the other factors, such as those identified in para 2.10 of the LUC report referenced above, then justify why the highest ranked option has not been pursued, these can then be set out in clear and understandable terms. However, this is no reason to not present a ranked system in the way we describe, otherwise we question why rate each effect in terms that grade their positive of negative benefits (+ or -) in any event.

(Please see the attached document for Figure 2)

Figure 2. Illustration of a potential weighting system that could be applied to SA assessment

3.8 The SA should inform the Plan-making process and Planning Practice Guidance (PPG) quite clearly states that ‘sustainability appraisal is integral to the preparation and development of a Local Plan’ (Para: 006, Ref ID: 11-006-20140306), and ‘[the sustainability appraisal] should inform the selection, refinement and publication of proposals (when preparing a Local Plan, paragraph 152 of the NPPF should be considered)’ (Para: 018, Ref ID: 11-018-20140306). Whilst we agree that there are other factors at play, the key aim of Plan-making is to ensure that sustainable patterns of development are delivered. The SA ranking will set out, in SA terms, which option should be selected to achieve this.

3.9 We have undertaken an assessment of the ‘Building Blocks’ within the new SA with the weighting system set out above. This can be found in Figure 5 of these representations and clearly demonstrates that again, following the Building Block 1 Urban Areas, Building Block 2 – Urban Extensions – is the most sustainable option for development. We discuss this further in Section 5 of these representations.

3.10 As part of the Plan-making process, SGC would be able to acknowledge which options are the most sustainable from the SA, following which they then can decide whether there are other Plan-making decisions which influence the selection of policies and sites, and set out the clear reasons for this. However, we would question why public opinion would be a reason to ignore the most sustainable strategy on its own; often development is unpopular and simply saying the negative public option will sway such decision making is very concerning, given the need to select the most sustainable strategy in the context of the declared climate emergency.

3.11 We then have concerns over certain aspects of the Framework and the effect criteria set out. Table 5A of the South Gloucestershire Scoping Report sets out the objectives and effects that will be used, albeit we note that in several instances these are still yet to be confirmed/ratified, and on certain pages the tables have printed incorrectly and can’t be viewed in full. We query why these are yet to be confirmed, particularly as this information is very similar to the SA Scoping Report that was published in 2018 as part of the original Local Plan Review that was being undertaken in conjunction with the JSP. For example, the effect criteria of Objectives 1a, 1b, 2c, 3a, 5b, 5d, and 7a are all yet to be confirmed and there also appears to be a description of the significant positive effects missing for some of the other objectives. These need to be defined as soon as possible to allow for objective analysis to be undertaken.

3.12 Paragraph 2.23 of the LUC SA Report states that ‘the reasonable alternative policy options for the Local Plan has been appraised against the SA objectives in the SA Framework.’ However, we then go on to note that it states in paragraph 2.30 that ‘as site options and allocations will only be considered at a later stage in the Plan preparation process and have not been considered for the Local Plan 2020 Phase 1 document, the criteria have not been used for the appraisal work included in this SA Report.’ Whilst we appreciate this, there is then no explanation of how the Phase 1 document has been assessed against the sustainability objectives, and as such, this leads us to question how the SA work undertaken by LUC could have assessed the effects of the policy options presented in the Local Plan Phase 1 document, other than via subjective assessments.

3.13 Of more concern, the LUC Report states ‘in some instances, the appraisal of policy options reflects other factors which are of relevance in relation to the achievement of an SA objective but which falls outside of the scope of the site assessment effects criteria.’ It is therefore unclear whether the SA has been influenced by other decisions that the reader doesn’t know about; the SA should be an independent, objective assessment with a clear set of criteria that proposals are assessed against.

3.14 We also have concerns over the scoring system used – we note that the Scoping Report published in support of the new SDS has been simplified and a new scoring system has been proposed as set out in Figure 3.

(Please see the attached document for Figure 3)

Figure 3. Extract of the IIA Framework proposed in support of the Spatial Development Strategy

3.15 This is much easier to understand for the general reader and we question why this approach couldn’t be used for the SGC Local Plan. Again, a simple weighing system could be applied to the SDS criteria to give the reader a better understanding of which strategy is the most sustainable and should be given most thought for the Plan to pursue.

3.16 Regarding Table 4.4 of the SA Report, which begins to assess the policy options in terms of ‘Building Blocks,’ again the SA has begun to slip back into the more complicated scoring process used in the JSP by incorporating other symbols which aren’t set out in the Scoring Key. For example, there is now ++/-- used, as well as --?, and symbols mixed up the wrong way (i.e. +/--). We appreciate that the SA process isn’t a simple task and there will be a mixture of effects, but there is no doubt that this method contributes to confusion and could be easily simplified.

3.17 The importance of this point has been emphasised by the Courts at the highest level. For example, Berkeley v SSETR [2001] 2 AC 603 the Housing of Lords stated that it must be compiled in a way that is easily understood by the lay person without the need for expert assistance; the same applies to a SA. This is further reiterated in the RTPI’s Strategic Environmental Assessment Practice Note (January 2018) which states ‘given the wider public involvement and interest in the outcomes, the SA also needs to be presented in such a way that it can be readily understood’ (page 23).

3.18 Whilst we consider that the SA is headed in the right direction, it has still taken quite some time for a team of professionally accredited Planners to understand what the process is, let alone for a member of the general public. This needs further refinement for the next stages of consultation and we strongly urge the council to consider an alternative, simpler assessment system to which a numerical weighting is applied.

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