Transformation and Sustainability

SHEFFIELD LOCAL PLAN (FORMERLY SHEFFIELD DEVELOPMENT FRAMEWORK)

CITY POLICIES AND SITES

SUSTAINABILITY APPRAISAL REPORT

Appendix 8

Comments on SDF Baseline

And Scoping Report

Development Services

Sheffield City Council

Howden House

1 Union Street

SHEFFIELD

S1 2SHFebruary 2013

APPENDIX 8

Summary of Responses to Consultation Comments on SDF Baseline and Scoping Report July 2005

Comment Number / Organisation / Comment Summary / Action Taken
1.1 / B. Little, Sheffield Green Party /
  • List of relevant plans missed out the “Climate Change Action Plan For Yorkshire And Humberside” Yorkshire and Humberside Assembly February 2005.
  • Contains action and goals that tie in with national greenhouse gas emission reduction targets.
  • Taking its contents seriously will require the reworking of some of the Sustainability Baseline and Scoping Report.
/
  • ‘Your Climate’ Yorkshire and Humber’s Climate Change Action Plan, Government Office for Yorkshire and the Humber, 2005 is now included in the revised list of other plans policies and programmes to be included in Appendix 3 of the Sustainability Appraisal Report
  • The SDF now includes objectives relating to climate change (see response to comment 2.5 below), and the Core Strategy includes preferred options relating to this

2.1 / The Countryside Agency /
  • Report is fit for purpose, clearly set out and understandable
/
  • Noted

2.2 /
  • Although transport and access matters are included, SCC should consider whether specifically enhanced access and countryside recreation opportunities should be a key issue.
/
  • ‘Access to natural areas and countryside improved’ is one of the SDF objectives, under the aim of improved accessibility and connections.

2.3 /
  • Missing baseline indicator information:
-length and use of cycle way and routes
-areas of green space / public open space, linkages of these areas that have been created and use of these areas
-area of Greenfield sites taken for development (including loss of Green belt areas)
-length of hedge and walls that have been built/ planted and/or lost
-new habitats that have been created
-number of wildlife sites that have been created and/ or access has been created to them
-landscape character relating to Countryside Quality Counts / Some of this information will be added to the baseline data (as below)
-length and use of cycle way and routes will be added to the baseline information, although data may currently be unavailable
-Area of greenfield sites taken for development is likely to be included in future monitoring reports, although it might relate most usefully to housing and business/industrial development
Some information is not going to be included – for the following reasons:
-Currently the area of new space and links is not being monitored, and use is not being monitored
-Although hedges and walls are clearly a vital feature of rural areas, and there is a sustainability aim relating to maintaining and enhancing the quality of natural landscapes, this would be difficult to accurately measure as an indicator.
-there is currently no information collected on the number of new habitats created.
-there is no specific indicator about creation of or access to wildlife sites, however, this would be measured in the indicator relating to the amount of land covered by local nature reserves etc
-landscape character has not been assessed
2.4 /
  • Additional Publications for inclusion:
-The State of the Countryside Reports
-Countryside Character Volume 3, Yorkshire and the Humber
-Planning Tomorrows Countryside
-Countryside in and around Towns
-Environmental Quality in Spatial Planning
-Countryside Quality Counts / Some of the additional publications have been added to the list of relevant plans, policies and programmes, whilst others haven’t. The reasons are listed below:
-The State of the Countryside Report, 2003 – NOT INCLUDED – this report contains no specific information about Sheffield, and regional information about rural areas is not significant, as rural populations in Sheffield are small and closely linked to services and facilities available in the urban area
-Countryside Character Volume 3 – NOT INCLUDED – this report is interesting, but has not provided significant information used in either the SDF or sustainability appraisal process.
-‘Planning Tomorrow’s Countryside’ - INCLUDED
-‘Countryside in and around Towns’ – NOT INCLUDED – this publication is interesting, but has not been directly used in preparation of planning policies.
-‘Environmental Quality in Spatial Planning’ – INCLUDED
-Countryside Quality Counts – NOT INCLUDED – this project has not provided significant information used in either the SDF or sustainability appraisal process.
2.5 /
  • Lack of SDF objectives relating to climate change, CO2 reductions and reduced use of energy and natural resources
  • Could link objectives to encouraging renewable energy businesses to the area and helping existing businesses to be more energy efficient
/

The SDF objectives now cover this issue – objective P3.6 ‘Carbon and other harmful emissions cur by reducing distances that people and goods need to travel, encouraging walking, cycling and energy-efficient and low-polluting forms of transport’.

  • SDF objective P3.13 ‘Renewable energy (including solar and wind power) generated in a variety of schemes and by new buildings, and in excess of regional targets.

3.1 / Environment Agency /
  • Local Authorities are required to undertake a Strategic Flood Risk Assessment. It will be hard to achieve the sustainability aim of minimal risk from flooding without having carried out a Strategic Flood Risk Assessment across the district
/
  • SFRA is now being undertaken

3.2 /
  • Welcome Aims 9, 12, 13, 14, 15, 16, 17, 18 and 19. However, environmental issues such as flood risk and wildlife should be dealt with in the core strategy as well as city policies and city sites.

3.3 /
  • Within Aim 6: 'Good cultural, leisure, and recreation facilities available to all', we recommend the recognition of the health benefits associated with riverside and wetland recreation.
/
  • This has now been incorporated into the criteria for assessing aim 6.

3.4 /
  • Within Aim 12: 'Quality of natural landscapes maintained and enhanced', we recommend the inclusion of 'Safeguard rivers and streams" .
/
  • This has now been incorporated into the criteria for assessing aim 12.

3.5 /
  • Within Aim 13: 'Wildlife and important geological sites conserved', we suggest the inclusion of "providing opportunities forFish Passes in rivers" which will be provided in the forthcoming 'River Don Fish Pass Action Plan' (see section below).
/
  • This has not been included in the criteria for assessing this aim, as it is very specific and does not relate to the broad strategic sustainability aims

3.6 /
  • Include in list of plans and programmes - The Don and Rother Catchment Abstraction Management Strategy (CAMS), Environment Agency, 2003.
/
  • This has been included in the list of relevant plans, policies and programmes

3.7 /
  • Include in list of plans and programmes - Don Flood Risk Management Strategy: A long-term flood risk management strategy
/
  • This has been included in the list of relevant plans, policies and programmes

3.8 /
  • Initial Characterisation Maps required under Water Framework Directive (WFD) have been completed for the water bodies in Sheffield and need to be taken into consideration in the baseline section of the SA. This is available at:
/
  • Currently unable to find this information

3.9 /
  • Yorkshire and the Humber Regional Spatial Strategy; Biodiversity and Natural Environment Study by Yorkshire and the Humber Biodiversity Forum October, 2004.
/
  • This has been included in the list of relevant plans, policies and programmes

3.10 /
  • Yorkshire and the Humber Wetland Feasibility Study by Countryside Agency, English Nature, RSPB and Environment Agency. Identifies areas within the region with potential for wetland conservation and restoration, particularly in floodplain and is linked to the delivery of the UK Biodiversity Action Plan.
/
  • This has been included in the list of relevant plans, policies and programmes

3.11 /
  • The following document will be available at a later date and we will advise you of the implications nearer the time: ‘A Catchment Flood Management Plan’(CFMP) for the Don catchment is due to start in September/October 2005
/
  • This has not yet been included in the list of relevant plans and policies.

3.12 /
  • Work will begin in early 2005 on the 'River Don Fish pass action plan' and this needs to be taken into account when considering any riverside development.
/
  • This has not yet been included in the list of relevant plans and policies.

3.13 /
  • Baseline information for Aim 15 should also include data on the following:
  • river chemistry quality, water abstraction licences, groundwater vulnerability zones, water quality discharge consents, Source Protection Zones.
  • Initial Characterisation Maps (referred to earlier).
  • The Water Framework Directive
  • The Don and Rother CAMS as mentioned earlier should also be included.
/
  • Some of this information has now been included in the baseline.
  • Unable to find this information
  • Not included within the baseline information – referred to in the list of relevant plans
  • Not included within the baseline information – referred to in the list of relevant plans

3.14 /
  • Baseline information relating to aim 17 (flooding) states that this information is not available.
  • Number of properties in areas at risk from flooding
  • Flood defences provided in areas at risk from flooding
This data is now available and should be included.
  • The Environment Agency Flood Zone Maps (2004) issued should also be included in this.
/
  • This information is now included in the baseline information

4.1 / Steve Simmons, Sheffield City Council /
  • Suggest rewording of 4.26
“Levels of nitrogen dioxide in areas of the city adjacent to busy roads and junctions exceed the Government’s health-based objective level. These areas are also affected by airborne particulate matter to the extent that they are likely to exceed the European objective set for 2010. To the east the M1 motorway is the major source of such pollution, and in the city centre small scale combustion plant makes a significant contribution to nitrogen dioxide levels. The aim of Sheffield’s Air Quality Action Plan is to achieve the health-based objectives across the city” /
  • This wording has been included in the amended sustainability analysis in the Sustainability Appraisal Report Appendix 8.

4.2 /
  • Additional documents “Draft EU Sustainability Strategy” and EU Noise Directive “Assessment and Management of Environmental Noise” 2002/49/EC, and National Ambient Noise Strategy and Sheffield City Council Contaminated Land Strategy
/
  • These documents have now been included in the list of relevant plans, policies and programmes

4.3 /
  • P31 – 8 – should be a reference to air quality and noise
  • P75 - % households with noise nuisance (wrong term as this is actually a specific thing
  • P79 – needs to be a link between air pollution and transport
  • P74 – needs to be a link between air pollution and health
  • P96 – Contaminated land strategy ( Peter Knight) should refer to contaminated sites
  • P95 – link between health and pollution (cross cutting theme – link to air quality/ resources etc)
/
  • This has now been included in the criteria for appraising aim 8
  • This term relates to wording in the survey from which the information was taken and has therefore not been altered
  • This link is recognised, however information relating to air quality is already covered in the baseline information under Aim 16
  • This link is recognised, however information relating to health is already covered in the baseline information under Aim 4
  • Contaminated land strategy included in list of relevant plans, policies and programmes
  • This link is recognised, however information relating to health is already covered in the baseline information under Aim 4

5.1 / Stuart Bennett (individual) /
  • 1.2 – the use of the words “whilst minimising detrimental impacts on the environment” contradicts the Governments Sustainable Development Strategy aims summarised in the previous paragraph (also 1.2). To be in line with Government policy this should say “whilst protecting and enhancing the environment”
/
  • The Sustainability Appraisal Report now reflects current Government guidance

5.2 /
  • Para 1.3 – the use of the words “wherever possible” seems to contradict the clear statement on p10 of Securing the future – UK Government Strategy for Sustainable Development which says “placing sustainable development at the heart of the land use planning system and at the core of new planning guidance”
/
  • Noted. Sustainable development is at the heart of work on the SDF, and guides the choice of policies which will eventually form the SDF.

5.3 /
  • P19, para 5.2 – the way in which the draft aims are expressed gives the impression that aim 1 which is the only one which contains the words “promote and develop” is the most important, and that the other aims are subservient to it. This seems to be contrary to the whole ethos of sustainable development as expressed in government documents which is that development should be assessed on the basis of how it promotes and enables all the aims. A better way of expressing the aims to reflect Government strategy could be: “the SDF will promote and enable development which will: . contribute to economic …., reduce the gap …that allow everyone to benefit, protect … features and assets, increase … stem increases in congestion, enhance … safe place for everyone.”
/
  • The SDF aims have now been developed significantly. Each of the aims depends on the others to achieve the vision of both transformation and sustainability. The aims are now worded as follows:
  • A strong economy
  • Opportunities for all
  • The natural environment conserved
  • Improved accessibility and connections
  • Places well designed, distinctive and revitalised

6.1 / English Heritage /
  • Suggest re-naming SA aim 11 as ‘Historic Environment Protected and Enhanced’
/
  • This has now been altered as suggested

6.2 /
  • Prefer the use of ‘preserve’ rather than ‘conserve’ as this more closely reflects primary legislation.
  • Add ‘and their settings’ to criteria about the historic Environment’
/
  • This has now been altered as suggested

6.3 /
  • (Scoping Report Table 3)The SEA directive requires considering the effects of the plan on ‘architectural and archaeological heritage. Therefore all three SDF documents should examine the effects of aim 11. Unsure why they are not thought to be relevant.
/
  • The effect of all the documents in the SDF will be measured against aim 11 which relates to the historic environment. This table in fact simply illustrates which documents are most likely to cover issues which would directly impact on this aim. In other words, only the City Policies document is highlighted, as this is where policies to protect and enhance the historic environment will be included. The other documents will still be tested against this aim, however.

6.4 /
  • Include reference to the DCMS publication ‘The Historic Environment: A Force for Our Future’ (2001) and the ‘Regional Cultural Strategy’
/
  • These are both now included in the list of relevant plans, policies and programmes

6.5 /
  • Baseline information should include reference to Sheffield’s 11 RegisteredHistoricParks and Gardens and 46 ScheduledMonuments
/
  • This is now included in the Baseline information.

6.6 /
  • Reference to sport should be removed from aim 11 (Historic environment) and moved to aim 6 (Good cultural, leisure and recreation facilities)
/
  • Appendix 4 of the Scoping report links sustainability aims to the features of a successful city described in the Sheffield City Strategy. Aim 11 is about the Historic environment, however the feature in the city strategy refers to ‘a great cultural and sporting life’. This will remain, as the link is with cultural life which relates to the historic environment – it is also linked to aim 6

6.7 /
  • In the scoping report Appendix 4 there should be a link from aim 11 (Historic environment) to ‘living within environmental limits’, as this covers ensuring that irreplaceable assets are not lost.
/
  • The theme of ‘living within environmental limits’ is not referred to at all in this table, which specifically refers to SEA directive requirements and City Strategy aims, and neither include this specific wording. It is however, recognised that protection of the historic environment would be considered as living within environmental limits.

6.8 /
  • Monitoring. Suggested indicators for monitoring aim 11 (Historic Environment) refer to number of listed buildings identified as being ‘at risk’. This should be stated as a proportion of all listed buildings.
/
  • This has been altered, as suggested.

6.9 /
  • Suggested indicators for the historic environment
a)Number of listed buildings under each grade
b)Number and % of listed buildings at risk
c)Number of listed buildings demolished
d)Number of Scheduled Ancient Monuments
e)Number and % archaeological sites at risk
f)Number of RegisteredHistoricParks and Gardens at risk
g)Number of Conservation Areas
h)Number and % Conservation Areas with appraisals /
  • Some of these indicators are already included in the Baseline information
a)Not included
b)Included
c)Included
d)Included
e)Not included
f)Included
g)Included
h)Not included
7.1 / English Nature /
  • Baseline information – more consideration could be given to greenspace of biodiversity value
/
  • Unsure how to quantify this without suggested information

7.2 /
  • Suggest alteration of aim 13 to read ‘ Wildlife and Important Geological sites conserved and enhanced’
/
  • This has now been altered as suggested

7.3 /
  • Monitoring – don’t agree with monitoring indicator about the amount of land covered by conservation designations as this could be misleading and mask changes
/
  • This is a Regional Indicator required as part of the Annual Monitoring Report, and will therefore be retained.

7.4 /
  • Monitoring – number of up-to-date countryside character assessments carried out records council effort rather than environmental change and is irrelevant
/
  • This indicator has been removed from the list of proposed monitoring indicators

7.5 /
  • Monitoring – don’t agree with proposed indicator regarding areas of biodiversity importance as this is difficult to measure and would be very resource consuming
/
  • This is an ODPM Core Output indicator and will therefore be retained.

7.6 /
  • Monitoring – suggest alternative indicators
  • ‘Number of planning applications refused wholly or partly on nature conservation grounds’ and/or ‘number of planning applications where ecological habitat or species surveys were required to be, or were voluntarily, submitted and outcome of those applications’
/
  • These will be proposed as monitoring indicators