This document outlines the changes made to the Sustainability Appraisal (SA) of the policies in SCDC’s LDF Core Strategy. It does not attempt to provide a detailed criticism of the SA, and the changes it mentions are only the major ones. Its purpose is to help people respond to the current consultation (which ends on the 14th October 2011).
The latest version the public have had an opportunity to comment on in an official consultation (as opposed to NANT’s lawyers and others writing letters to SCDC) is the November 2010 one (which is actually the June 2010 version plus a description of the changes since June 2010, dated 26th Nov. 2010 – see below).
Here is a summary of the relevant versions of the SA:
|June 2010||Appraises the LDF Core Strategy Pre-submission document, June 2010 (i.e. before the revocation of the RSS)||N|
|Nov. 2010||June 2010 version + introduction dated 26/11/10 + schedule of the main changes between the draft Reviewed and the Interim Core Strategies||Y|
|June 2011||Assesses the LDF Reviewed Core Strategy as amended by Cabinet in Feb. 2011||N|
|August 2011||Assesses the LDF Reviewed Core Strategy as amended by Cabinet in Feb. 2011 and July 2011 and Full Council in July 2011||Y (this one)|
The actual documents can be found at:
§1.1 Non-technical summary
Section expanded significantly to include brief descriptions of earlier versions of the SA and reasons for LDF policy decisions.
§1.2 Likely significant effects of core strategy policies and mitigation required
Mitigation proposals have been expanded significantly, in particular SP20 (Area East of Ipswich). New bullet points on cumulative effects of housing and concerns about tourism.
§3 Method of Appraisal
§3.1 Approach to Sustainability Appraisal
Section expanded to include brief descriptions of earlier versions of the SA and other documents.
§3.4 Who was consulted, when and how
Includes SCDC’s responses to responses to consultations on the SA (Dec. 2008) and Reviewed Core Strategy SA (Nov 2010) (Tables 3.2 and 3.3)
§4. State of the Environment in Suffolk Coastal
Lots of changes due to the data being taken from more recent sources. The section on Landscape and Biodiversity has been expanded to include comments on the Footprint Ecology Report (South Sandlings Visitor Survey) and NANT’s Deben Estuary Survey. Figure 4.11: Paths lost to erosion around Waldringfield has been added, with comments.
Comparison at this point is confusing. The Nov. 2010 version’s Table of Contents doesn’t align with the actual section numbers. §4.2 and §4.3 are missing. These are shown in the Table of Contents as: §4.2 Predicted future baseline and §4.3 Assumptions and limitations on information. The latter actually appears as §4.4. This confusion appears to have been sorted out in the Aug. 2011 version, and the content of §4.2, §4.3 and §4.4 (in the Aug. 2011 version) is largely unchanged.
§5. Sustainability objectives
This section is unchanged (although I haven’t checked Table 5.4 in detail). It is surprising that no change has been made to §5.4 Mitigation, as this issue has moved on significantly since Nov. 2010.
§6. Appraisal of core strategy policies
§6.2 Links with national policy & other plans
§6.3 Core strategy policies and options
Updated to included responses to the Nov. 2010 consultations.
§6.4 Consideration of Policy options/alternatives
New section. Presumably this is in response to criticisms by NANT and others that the policy options hadn’t been properly subjected to sustainability appraisal. (It doesn’t actually address the issue, because to do so would require re-visiting the key decisions and appraising the alternatives properly.)
§6.5 Policy appraisal results
The sustainability of the current policies are compared with earlier versions. Not much has changed. 3 policies have changed score since June 2010:
- SP1 Sustainable Development 27 à 28
- SP2 Housing Numbers 7.5 à 7
- SP19 Settlement Policy 11.5 à 10.5
It is curious that SP21 Felixstowe remains unchanged at 14.5, despite the number of new houses allocated there having increased by 44%, from 1,000 to 1,440.
Changes have been made to the descriptive assessments of the following Core Policies:
SP1 – explanation of the increase in score
SP2 – “The latest updating of the numbers, reducing the total by 70 does not make a significant change to the assessment of the policy. The slight [44% is ‘slight’??] increase in Felixstowe and the Trimleys is proportional to the size of the existing development.” The score went down because of “concerns for disturbance of birds, specifically Nightjars named in the Sandlings SPA designation.”
SP19 – The score has gone down slightly “due to the findings of the Appropriate Assessment that associates this distribution of housing with a 2%- 5% cumulative impact with Ipswich Borough’s housing proposals on the European designated sites in the Suffolk Coast and Heaths AONB” The policy hasn’t actually changed, but they have woken up to the fact that Ipswich BC also has housing plans which will impact on the European sites (how long have we been telling them that?).
SP20 - This policy is described as “marginally more sustainable”, because: “the policy now seeks to preserve and enhance environmentally sensitive locations in this extremely sensitive area and in particular notes the creation of a countryside park on the Foxhall tip by the end of the plan period”. (This is a bit odd, since the score is unchanged at 0.5). The reference to the Foxhall Tip is contradicted in the last paragraph, in which it is stated that designated area will need to be safeguarded “by providing open space as part of the housing development at the beginning of the development” and it is pointed out that “Foxhall Country Park is unlikely to be developed within the plan period”. The need for an Area Action Plan is mentioned.
SP21 - The score is unchanged at 14.5, but no mention is made of the increase in the housing allocation by 44%.
Sections on water and air quality have been added.
The bullet point on SP20 has been expanded.
Extra bullet points have been added to cover the cumulative impact of housing plans by IBC, and tourism.
§6.8 How problems were considered in developing policies and proposals
Table 6.4 (Mitigation following June 2010 and November 2010 SA) has been added.
§6.9 Uncertainties and risks
Section expanded. “There is uncertainty as to when a country park could be delivered at Foxhall tip. Changes”. (But there is no uncertainty that it won’t be there at the start of house building!)
No significant changes.