South Gloucestershire
Local Development Framework
Pucklechurch Conservation Area
Sustainability Planning Document
November2009
Sustainability Appraisal Report
INTRODUCTION
Under the Planning and Compulsory Purchase Act 2004, Sustainability Appraisals (SA) are mandatory for Regional Spatial Strategies (RSSs), Development Plan Documents (DPDs) and Supplementary Planning Documents (SPDs). The purpose of the SA is to help planning authorities to achieve sustainable development through the policies in their plans.
When preparing RSSs, DPDs and SPDs, planning authorities must also conduct an environmental assessment in accordance with the requirements of European Directive 2001/42/EC on the “assessment of the effects of certain plans and programmes on the environment” (the “strategic environmental assessment” or SEA Directive).
The requirement to carry out a Sustainability Appraisal and a Strategic Environmental Assessment are distinct. However, it is possible to satisfy both through a single appraisal document.
The purpose of the SA is to promote sustainable development through better integration of sustainability consideration into the preparation and adoption of plans. SA is an integral part of good plan making and should not be seen as a separate activity. SA is an iterative process which identifies and reports on the likely significant effects of the plan and the extent to which implementation of the plan will achieve the social, environmental and economic objectives by which sustainable development can be defined.
This Sustainability Appraisal Report documents the SA process that occurred during the preparation of the SPD and accompanies the SPD for public participation in accordance with Regulation 17 of the Town and Country Planning (Local Development) (England) Regulations, 2004.
Government guidance splits the SA process into a series of stages and tasks that coincide with the preparation of the plan upon which the SA is being conducted. A Scoping Report has been prepared which sets out information related to Stage A (the first stage) of the SA process: the South Gloucestershire LDF Scoping Report went out to consultation with the three statutory consultees (Natural England, English Heritage and the Environment Agency) as well as a variety of other stakeholder organisations for six weeks in November and December 2007. Following comments received, it was updated and the final version of the Scoping Report was published in March 2008.
Stage A: Setting the context and objectives, establishing the baseline and deciding on the scope.
This section will summarise the work done at both the pre-production stage of the SPD and during the drafting of the South Gloucestershire Local Development Framework (LDF) Scoping Report. This Scoping Report was drafted to act as a Scoping Report for all documents prepared in the South Gloucestershire LDF. Therefore a Scoping Report to this SA Report and SPD has not been prepared, as it would duplicate work already undertaken.
The information below summaries how the Scoping Report is relevant to this SA and SPD. This SA should be read in conjunction with the Scoping Report.
Task A1: Identifying other relevant plans and programmes
A number of key plans and programmes were identified and reviewed in the LDF Scoping Report. The key issues for thePucklechurch Conservation Area SPDemerging from this review were that:
- The character and appearance of Pucklechurch needs to be responsive to local circumstances
- The guidance needs to be clear and useful to all parties involved in delivery, especially local residents, local landowners, developers and development control planning officers.
- Increased knowledge and understanding of the historic environment will allow more informed and positive conservation and enhancement of the historic environment.
Task A2: Baseline information and characteristics
The collection and assessment of baseline information and data about the current and likely future state of the District in the Scoping Report was looked at from aconservation area perspective. This has been used within this SA to help identify sustainability issues.
Task A3: Sustainability Issues for the SA to address
Planning Policy Statement 1: Delivering Sustainable Development; Planning Policy Guidance Notice 15 (Planning and the Historic Environment (PPG15); and English Heritage Good Practice Notes on Conservation Area Appraisals (February 2006) and Conservation Area Management (February 2006) require that Conservation Areas are reviewed on a regular basis and this has a direct positive impact on the 5th sustainability objective as it helps to “maintain and improve environmental quality and assets”.
The relevant issues are:
- To provide a summary of national, regional and local plan policies relating to the designation of conservation areas;
- To define the “special interest” that justifies designation through a character appraisal of each conservation area;
- To understand the changes to the conservation area since the last adopted Supplementary Planning Guidance was published;
- To identify the potential threats to the character and appearance of the conservation area;
- To base the management of each area on understanding it and consider how its value or importance is vulnerable to harm (or might be reinforced) through using the appraisal as the starting point for developing management proposals and policy guidance for the area;
- Where appropriate, draw up specific enhancement/improvement schemes to reinforce the character of an individual conservation area; and
- To ensure that the key requirements or objectives of the SPD are deliverable and achievable.
Task A4: Sustainability Appraisal objectives, indicators and targets.
The Scoping Report sets out a series of SA objectives that are used to test the effects of the various documents in the LDF. Not all of the SA objectives will necessarily be relevant for each LDF document. In the case of thePucklechurchConservation Areas SPD,after Officer consideration it has been deemed that the following sustainability criteria are relevant to this SPD and therefore have been used to appraise this document:
Table 1 – SA Objectives used for appraising the SPD
Sustainability appraisal objectives – against which to test the effects of the SPD.
Objective
- Improve Health.
- Support communities that meet people’s needs.
- Develop the economy in ways that meets people’s needs.
- Provide access to meeting people’s needs with least damage to communities and the environment.
- Maintain and improve environmental quality and assets.
- Minimise consumption of natural resources.
Task A5: Consulting on the scope of the Sustainability Appraisal
The LDF Scoping Report was subject to consultation in November and December 2007 and published in final form in March 2008. It is available separately on request.
Stage B: Developing and refining options and assessing effects
Whereas Stage A of the SA process was conducted prior to the preparation of the SPD and this SA Report, Stage B has been conducted in tandem with the production of the SPD. It is therefore the purpose of this SA Report to outline the process and results of the Stage B of the SA process, as well as subsequent stages. The table below outlines each of the tasks of Stage B and their purpose.
Table 2
SA stages and tasksPurpose
B1Testing the SPD objectives againstTo identify potential synergies or
the SA objectives.inconsistencies between the objectives of
the plan or programme and sustainability
objectives and help in developing alternatives.
B2Developing strategic alternativesTo develop and refine strategic alternatives
B3Predicting the effects of the SPD, To predict the significant environmental,
including alternatives.economic and social effects of the SPD.
B4Evaluating the effects of the SPD, To evaluate the predicted effects of the SPD
including alternatives.and its alternatives and assist in refinement
of the SPD.
B5Mitigating adverse effects and To ensure the adverse effects are identified maximising beneficial effects. and potential mitigation measures are
identified.
B6Proposing measures to monitor theTo detail the means by which the
effects of implementing the SPD.performance of the SPD can be assessed.
B1: Testing the SPD Objectives against the Sustainability Appraisal Objectives
Table 3
Main aims for the proposed of the SPD
1Provide clarity to the existing Local Plan conservation area policy.
2Provide a summary of national, regional and local plan policies.
3Clarify the definition of what is a conservation area.
4Offer detailed guidance on the character and appearance of the existing Pucklechurch Conservation Area.
5Identify the special features within the Pucklechurch Conservation Area.
6Outline how the character of the Pucklechurch Conservation Area can be kept and enhanced.
7To review the open areas which contribute to the landscape character.
The table above outlines the main aims of the Pucklechurch Conservation Area SPD. However as these are process-driven aims, rather than policy or “end-result” aims, they are unsuitable for appraisal against SA criteria. The SPD contains no other specifically identified aims or objectives. Therefore the SA has not been able to appraise a specific set of SPD objectives as is normally conducted in SAs.
The level of detail in the appraisal of plan options for this SPD reflects the work already covered in the appraisal of the Local Plan Policy L12 in relation to conservation areas and the need to avoid duplication of this work. The relevant aspects of the appraisal of this policy are summarised as follows:
The policy requires conservation areas to be reviewed on a regular basis in line with Planning Policy Statement 1: Delivering Sustainable Development (PPS1); and Planning Policy Guidance Note 15: Planning and the Historic Environment (PPG15); and the English Heritage Good Practice Notes on Conservation Area Appraisals (February 2006) and the Conservation Area Management (February 2006). As noted before, it has a direct positive impact on the 5th Sustainability Appraisal Framework Objective in that it helps to “maintain and improve environmental quality and assets” by addressing the majority of sub-headings noted under the 5th objective heading.
The work for the SPD will also involve a review of the open areas within the Pucklechurch Conservation Area which contribute to the landscape character as required under Policy L5 of the Local Plan. This seeks to identify the open areas which contribute to the quality, character, visual amenity and distinctiveness of the locality. Again, such a process will have a direct and positive impact on the 5th SA objection noted above.
Notwithstanding the identified aims for the SPD, the options and approach for reviewing the character of Conservation Areas are largely determined by PPG15 and the English Heritage Good Practice Guidance. Options for Enhancement Strategy seek to build upon this good guidance; comments made during the initial consultation; and general good practice and appeal determination. The objective is to try to provide a robust framework for future development for the area.
The SPD supplements policy L12 of the South Gloucestershire Local Plan (Adopted January 2006) and seeks to avoid duplication by developing the policy in greater detail – with specific policies for the local area.
The following content option were considered but were not included because of the need to keep the document succinct. It is considered that their inclusion would be unlikely to affect the sustainability outcome:
- A list of answers to frequently asked questions about Conservation Areas – this could be covered by a general Guidance Note.
- An explanation of the planning process – pre-application discussions, information requirements for applications, opportunities for public input, the decision makes process and appeal process etc – with guidance now on-line at SGC web site and Planning Portal;
- Photo essay of good and bad practise;
- Summary of the English Heritage guidance;
B2: Developing Strategic Alternatives
A requirement of SA is to consider reasonable alternatives to the preferred approach, in this case the adoption of the proposed SPD.
The consideration of alternatives is limited because the proposed SPD supplements “saved policies” in the Local Plan and the requirement for periodic review and renewal is enshrined in national legislation and guidance. If no provision were made in the Local Plan for Conservation Areas the consideration of alternative options would have been much wider. The alternative considered was:
- Retaining the status quo (i.e. keeping the existing Pucklechurch Conservation Area leaflet which was published in 1995).
Before preparing the Draft SPD, the issues and options relating to the SPD were appraised through a questionnaire sent to local residents, local stakeholders and statutory environmental consultees. A series of meetings with individual stakeholders and a meeting with representatives of the local community were also held which were aimed at seeking views on the boundary of the designated area and on identifying the issues which the Enhancement Strategy needed to focus on. This material has been used together with the SA of the South Gloucestershire Local Plan to inform, prioritise and focus material in the draft SPD.
Formal consultation on the Draft SPD and Draft SA is planned to take place over eight weeks between January and April 2010. The format for consultation will be consistent with that previously undertaken for other SPDs and as set out in the Council’s Statement of Community Involvement (SCI). Any comments will be used to refine the content of the SPD.
B3: Predicting the effects of the SPD
The focus of the SA is on assessing the SPD against a set of agreed sustainability criteria to examine whether it enhances the sustainability of the relevant local plan policies.
Where the SPD introduces issues not covered by policies in the South Gloucestershire Local Plan, these issues have been individually assessed against the sustainability criteria.
The results of this appraisal are summarised in Table 4 and uses the following symbols.
Detrimental effect on sustainability
Likelihood of discernable benefit
Likelihood of additional benefit over and above that
achieved by the Local Plan Policy alone
?Uncertain or unpredictable effect
0Insignificant or neutral effect or criteria not relevant
B4: Sustainability Criteria
To employ best practice this SA uses the high level detailed objective and criteria from the Regional Spatial Strategy Strategic Sustainability Appraisal to appraise this document.
B5: Predicting Effects
The effect of the SPD on Sustainability can be categorised as follows:
- Effects of conservation area designation in general on sustainability as they are affected by the SPD;
- Effects of including and excluding further criteria on the SGLP policy in the SPD on sustainability;
- Effects of the particular approach to interpretation of the relevant policy, guidance and regulations taken in the document on sustainability.
The following questions were posed to help anticipate effects of the SPD on sustainability:
- Will the SPD have any impact on health?
- Will it support communities in a way that meet people’s needs?
- Will it help development of the economy in ways that meet people’s needs?
- Will it have any impact on people’s access needs, if so will it damage communities and the environment?
- What impact will it have on environmental quality and assets?
- How will it affect consumption of natural resources?
Table 4 below represents the conclusions of an initial exercise undertaken in December 2008 which shows the likely effects of the SPD.
Table 4 – Likely effects of the SPD against the Sustainability Criteria and Local Plan Policies.
Sustainability Objective / Predicted effects / Explanation(includes consideration of short, medium, long term, cumulative and synergistic effects)
1. Improve Health / Policy on its own 0
Policy + SPD 0 / Positive approach of SPD to preserving and enhancing the character of the local area likely to help provide stability in times of ever faster change. Possible small beneficial effects from such stability.
2. Support communities that meet people’s needs. / Policy on its own
Policy + SPD / Contributing to local sense of community – including providing the local community with a say in the future framework for their area.
3. Develop the economy in ways that meets people’s needs. / Policy on its own
Policy + SPD / The positive approach to preserving and enhancing the character will help ensure long term economic benefits through an approach based on design quality. The emphasis in the SPD of protecting the character of the area and its sense of place will have indirect benefits – from the wider perceptions of being an attractive and pleasant area to live – to potential tourism benefits.
4. Provide access to meet people’s needs with least damage to communities and the environment. / Policy on its own
Policy + SPD / The SPD seeks directly to minimise damage to the local environment – and to clarify issues that any development needs to address.
Negligible effect on car dependence, service access or transport modes expected from the SPD.
5. Maintain and improve environmental quality and assets. / Policy on its own
Policy + SPD / The SPD seeks to directly preserve and enhance the character of the area and of its open spaces. It promotes directly the conservation and protection of those aspects that make the area unique and special. It is focused on defining and protecting those aspects that contribute to the local distinctiveness. It contributes directly to maintaining and enhancing the historical assets of the area.
6. Minimise consumption of natural resources. / Policy on its own
Policy + SPD 0 / By encouraging the repair and retention of the existing fabric the approach will generally minimise new natural resource requirements. No discernable adverse effects on water and mineral consumption, greenhouse emissions and other pollution expected.
B6: Changes to SPD from Sustainability Appraisal
The draft SPD has been affected by the SA. The assessment of social, environmental and economic effects combined with consideration of policy has influenced the content and form of the SPD. Looking at sustainability objectives was an important part of ensuring soundness and conformity of the document.
- Considering the economic, environmental and social effects of enhancement options has sought to balance the benefits of the statement against any resultant inflexibility.
- Considering the pressures of traffic and parking has identified the need for a more sustainable approach to be emphasised.
- The design and layout of the SPD has sought to provide a succinct leaflet that communicates the key points effectively.
- Considering the assessment of open spaces under SGLP Policy L5 it has improved the approach to preserving and enhancing the open spaces and natural environment.
- The SPD is limited by the lack of controls over cumulative minor changes to non-listed buildings.
B7: Considering ways of maximising beneficial effects.