4 Method used in SA Addendum work

4.1 As described in Chapter 1, the SA Addendum work has incorporated the requirements of the SEA Regulations. The approach to carrying out the SA Addendum for the Joint Core Strategy has been based on current best practice and the following guidance:

  • A Practical Guide to the SEA Directive (September 2005), Office of the Deputy Prime Minister, Scottish Executive, Welsh Assembly Government and the Department of the Environment for Northern Ireland.

4.2 The SA has been undertaken in close collaboration with those involved in considering the alternatives for the Joint Core Strategy in order to fully integrate the SA/SEA process with the production of the Plan.

Reasonableness criteria

4.3 Regulation 12(2) of the SEA Regulations requires that:
“The (environmental or SA) report must identify, describe and evaluate the likely significant effects on the environment of—
(a) implementing the plan or programme; and
(b) reasonable alternatives, taking into account the objectives and the geographical scope of the plan or programme”

4.4 Therefore, any alternatives to options, policies or site allocations included in the plan need to be “reasonable”. This implies that alternatives that are “not reasonable” do not need to be subject to appraisal. In addition, the SEA Regulations do not require all reasonable alternatives to be subject to appraisal, just “reasonable alternatives”. Part (b) of Regulation 12(2) above notes that reasonable alternatives will take into account the objectives of the plan, as well as its geographical scope. Therefore, alternatives that do not meet the objectives of the plan or national policy, or are outside the plan area are unlikely to be reasonable.

4.5 In order to identify ‘reasonable’ alternatives for component 3 (i.e. spatial distribution of SUEs around the towns) to be assessed as part of this additional work for the Joint Core Strategy, a set of draft ‘reasonableness’ criteria was developed and set out in the Scoping Report Addendum (July 2013). The reasonableness criteria were defined by considering how the constraints and opportunities for development contained in the NPPF and the strategic objectives of the Joint Core Strategy would influence whether an alternative is reasonable. Consultation responses received from the statutory environmental bodies during the consultation on the Scoping Report Addendum have been incorporated into the final set of reasonableness criteria shown in bold text in the second column in Table 4.1.

Table 4.1 Reasonableness criteria used for identifying reasonable alternatives for SUE locations to be covered in the SA Addendum work

Policy or objective in NPPF and Joint Core Strategy

Reasonableness criteria


Flood Risk

Paragraph 100 in the NPPF and the Technical Guidance on Flood Risk require Local Plans to apply a sequential, risk-based approach to the location of development to avoid where possible flood risk to people and property and manage any residual risk, taking account of the impacts of climate change.

Avoid Flood Zones 2 and 3 (as these areas have a medium and high probability of flooding).

National landscape designations

Paragraph 115 in the NPPF states that great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty (AONBs), which have the highest status of protection in relation to landscape and scenic beauty.

Not applicable to West Northamptonshire as it does not contain any National Parks or AONBs.

International and national biodiversity designations

Paragraphs 118-119 of the NPPF discourage development that would adversely affect international and national biodiversity designations.

Avoid international and national biodiversity designations.

Heritage assets

Paragraph 132 in the NPPF states that substantial harm to or loss of these designated heritage assets of the highest significance should be wholly exceptional:

Scheduled monuments


Grade I and II* listed buildings

Grade I and II* registered parks and gardens

World Heritage Sites

Avoid scheduled monuments, battlefields, Grade I and II* listed buildings, Grade I and II* registered parks and gardens

World Heritage Sites are not applicable to West Northamptonshire as it does not contain any.

Minerals Safeguarding Areas

Paragraph 143 of the NPPF states that in preparing Local Plans, local planning authorities should define Minerals Safeguarding Areas and adopt appropriate policies in order that known locations of specific minerals resources of local and national importance are not needlessly sterilised by non-mineral development, whilst not creating a presumption that resource s defined will be worked; and define Minerals Consultation Areas based on these Minerals Safeguarding Areas.

Avoid Minerals Safeguarding and Consultation Areas identified in the Northamptonshire Minerals and Waste Local Plan (Submission version November 2013), but recognising that they are not an absolute constraint to development.

West Northamptonshire Joint Core Strategy

Objective 1 - Climate Change: To minimise demand for resources and mitigate and adapt to climate change, by:

- Promoting sustainable design and construction in all new development;

- Ensuring strategic development allocations are located and designed so as to be resilient to future climate change and risk of flooding;

- Encouraging renewable energy production in appropriate locations; and

- Ensuring new development promotes the use of sustainable travel modes.

Avoid Flood Zones 2 and 3 (also accords with NPPF).

Proximity to sustainable transport options is not considered to be a primary constraint, but rather something to be considered as part of comparison between site options, therefore not a reasonableness criterion.

Objective 2 - Infrastructure and Development: To protect and enhance existing local services and to ensure social, physical and green infrastructure is adequately provided to meet the needs of people and business in a timely and sustainable manner in response to regeneration and new development in West Northamptonshire.

The availability of infrastructure in a timely and sustainable manner is not considered to be a primary constraint, but rather something to be considered as part of comparison between site options, therefore not a reasonableness criterion.

Objective 3 - Connections: To reduce the need to travel, shorten travel distances and make sustainable travel a priority across West Northamptonshire by maximising the use of alternative travel modes.  In so doing, combat congestion in our main towns and town centres, reduce carbon emissions and address social exclusion for those in both rural and urban areas who do not have access to a private car.

Proximity to sustainable transport options is not considered to be a primary constraint, but rather something to be considered as part of comparison between site options, therefore not a reasonableness criterion.

Objective 4 - Protecting and Building Urban Connections: To ensure new development in urban areas effectively supports and links new and existing communities physically and socially, to achieve social cohesion and address the areas of deprivation identified in parts of Northampton and Daventry.

Locations should be adjoining existing urban edge.

Objective 5 - Supporting Northampton Town Centre: To support the regeneration of Northampton's town centre by making it the focus of high quality retail, employment, leisure and cultural development at the heart of Northamptonshire and to support the delivery of the Northampton Central Area Action Plan.

Proximity to Northampton town centre is not considered to be a primary constraint, but rather something to be considered as part of comparison between site options, therefore not a reasonableness criterion.

Objective 6 - Supporting Daventry Town Centre: To support the regeneration of Daventry town centre through planned growth and infrastructure delivery.

Proximity to Daventry town centre is not considered to be a primary constraint, but rather something to be considered as part of comparison between site options, therefore not a reasonableness criterion.

Objective 7: Supporting Towcester and Brackley's Town Centres: To support Towcester and Brackley in their rural service centre roles to ensure their communities are self-sufficient sustainable places and the towns are the focus of services and facilities for surrounding villages.

Proximity to Towcester or Brackley town centre is not considered to be a primary constraint, but rather something to be considered as part of comparison between site options, therefore not a reasonableness criterion.

Objective 8 - Economic Advantage: To strengthen and diversify West Northamptonshire's economy by taking advantage of our internationally well-placed location, strategic transport network and proximity to London and Birmingham.

Not a reasonableness criterion for SUEs as this objective does not affect location of additional housing development.

Objective 9 - Specialist Business Development: To support and develop opportunities for specialist employment clusters and business development focused on a low carbon economy.

Not a reasonableness criterion for SUEs as this objective does not affect location of additional housing development.

Objective 10 - Educational Attainment: To raise educational achievement and the skills base of our communities through supporting the development of West Northamptonshire's learning infrastructure and strengthening the link between local businesses and local schools, Moulton and Northampton Colleges, the University of Northampton and Daventry and Silverstone University Technology Colleges.

Not a reasonableness criterion for SUEs as this objective does not affect location of additional housing development.

Objective 11 - Housing: To provide a range of housing in sustainable locations to ensure all residents have access to a home that they can afford and that meets their needs.  Housing development will be focused at the most sustainable location of Northampton, supported by Daventry and Towcester and Brackley in their roles as rural service centres with limited development in the rural areas to provide for local needs and support local services.

Alternative locations that are not adjoining the four main towns are not reasonable alternatives.

Objective 12 - Protecting and Supporting Rural Communities: To protect and support rural communities to ensure they thrive and remain vital.

Not a reasonableness criterion as this objective does not affect location of additional housing development.

Objective 13 - Rural Diversification and Employment: To support rural diversification and rural employment opportunities, in particular those related to agriculture, horticulture and forestry.

Not a reasonableness criterion as this objective does not affect location of additional housing development.

Objective 14 - Green Infrastructure: To protect natural species present in West Northamptonshire and enhance the existing strategic green infrastructure network, including biodiversity corridors, by incorporating and designing these into Sustainable Urban Extensions (SUEs) at Northampton, Daventry, Towcester and Brackley.

Not a reasonableness criterion as this objective does not affect location of additional housing development.

Objective 15 - High Quality Design: To achieve high quality design in both rural and urban areas that takes account of local character and heritage and provides a safe, healthy and attractive place for residents, visitors and businesses.

Not a reasonableness criterion as this objective does not affect location of additional housing development.

Objective 16 - Heritage: To conserve and where possible enhance, through carefully managed change, the important heritage assets and their settings of Northampton, Daventry, Towcester and Brackley, and to recognise the role of rural heritage assets and their settings to support a sense of place and local distinctiveness.

Avoid heritage assets (and their settings) (also accords with NPPF).

SA Framework

4.6 The SA has taken an ‘objectives-led’ approach to the assessment that addresses the key sustainability issues identified for West Northamptonshire, while ensuring all the SEA topics (a) to (l) in the box below are covered.

The SEA Regulations, Schedule 2(6) require the Environmental Report to consider:
The likely significant effects on the environment, including short, medium and long term effects,
permanent and temporary effects, positive and negative effects and secondary, cumulative and
synergistic effects, on issues such as (a) biodiversity, (b) population, (c) human health, (d)
fauna, (e) flora, (f) soil, (g) water, (h) air, (i) climatic factors, (j) material assets, (k)
cultural heritage including architectural and archaeological heritage, (l) landscape and (m) the
inter-relationship between the issues referred to in sub-paragraphs (a) – (l).


4.7 The same SA Framework as was developed originally for the SA of the Joint Core Strategy (presented in the 2006 SA Scoping Report), which included a set of SA objectives covering all of the SEA topics, has been used. Following the original scoping consultation, the SA Framework was updated to reflect statutory consultee comments in the 2007 SA Report (Table 3), and the same updated SA Framework continued to be used in the 2009 SA Report (Table 6.1) and 2011 SA Report (Table 6.1). Using the same SA Framework for this SA Addendum work will ensure that alternatives are assessed in a comparable way to the options previously considered as part of developing the Joint Core Strategy. The SA Framework is re-presented below in Table 4.2, and some minor changes have been added to address the statutory consultee comments on the July 2013 Scoping Report (these are shown as underline for new text and strikethrough for deleted text).

Table 4.2: SA Framework for the West Northamptonshire Joint Core Strategy SA Addendum

SA Objective

Appraisal questions.  Will the plan/option lead to…?

1. Air quality and noise

a) Reduce the need to travel and facilitate modal shift.

b) Reduce/minimise the potential increase in congestion.

c) Avoid sensitive development within areas of high noise levels or poor air quality.

• An increase in motor vehicle trips and increased dependence on car use?

• Sensitive location of new development in areas of high noise levels or poor air quality.

• Support for the objectives of local air quality action plans?

• Improvements in existing local public transport infrastructure or access to public transport?

• Exacerbating existing traffic congestion hotspots or improvements to the current situation?

• The inclusion of policies to enhance air quality where new development may deliver a means of doing so?

2. Archaeology and cultural heritage

a) Protect the fabric and setting of designated and undesignated archaeological sites, monuments, structures and buildings, registered Historic Parks and gardens, registered battlefields, listed buildings and conservation areas (or their settings).

• Development that affects listed buildings, conservation areas, scheduled ancient monuments, registered historic parks and gardens, and registered battlefields (or their settings)?

• Development being steered to where it can be accommodated in less sensitive areas?

• Distinctive development that is well related to the natural environment and characteristic scale, form materials and detailing of the settlement and contributes to a sense of place?

• Promotes the enhancement of the archaeological resource and other aspects of heritage, such as, parks and open spaces, and areas with a particular historical or cultural association?

• Will the plan proposals provide opportunities for the enhancement of historic assets, townscapes and landscapes?

3. Biodiversity, flora and fauna

a) Maintain and enhance the structure and function of habitats and populations of species, including those specifically protected.

b) Enhance and protect greenspace networks and habitat connectivity, including river and stream corridors, to assist in species migration and dispersal.

c) Increase the land area of UK Biodiversity Action Plan habitats within the area.

d) Maintain and improve the conservation status of selected non-designated nature conservation sites.

• Avoidance of net loss, damage to, or fragmentation and positive enhancement of designated wildlife sites protected species and priority species / habitats within the Northamptonshire BAP?

• Opportunities for people to come into contact with robust wildlife places whilst encouraging respect for and raising awareness of the sensitivity of these sites?

• Development which includes the integration of ecological conditions and contributes to improvement in ecological connectivity in rural and urban areas?

4. Crime and community safety

a) To improve community safety, reduce crime and the fear of crime.

• Changes in crime levels and fear of crime through improvements to the environment, layouts of streets and public space, passive surveillance, lighting etc.

• Leisure facilities for young people at the neighbourhood level including consideration of provision as part of large new residential developments.

5. Education and training

a) Improve educational attainment and promote lifelong learning.

b) Promote sustainable modes of travel to access education.

• Improvements in educational attainment, qualification levels and participation in education and training.

• Adequate supporting educational infrastructure associated with new residential developments.

• New education facilities well located in relation to walking, cycling and public transport routes.

6. Energy and climatic factors

a) Continue to improve energy efficiency of dwellings.

b) Continue to increase the provision of ‘affordable warmth’.

c) To decrease the dependency on oil for space heating.

d) Increase the local renewable energy generating capacity.

• An average increase in the SAP rating of dwellings?

• A reduction of the average household fuel bill.

• A decrease in oil consumption.

• Major developments incorporating renewable energy measures into the design.

• An increase in energy efficient measures and CHP in the design new developments.

• An increase in the number of large scale renewable energy schemes.

• A better consideration of climate change adaptation measures?

7. Health and well being

a) To improve health and reduce health inequalities.

• Healthier lifestyles?

• Improved access to healthcare?

• Improve the quality of homes?

8. Labour market and economy

a) To create high quality employment opportunities and develop a strong culture of enterprise and innovation.

• An adequate supply of land, skills and infrastructure (such as ICT) to meet the requirements of growth sectors and fully exploit locational/ economic opportunities while not harming the environment.

• Minimise travel distances to work and commuting by modes other than the car. Ensuring access to employment by public transport, walking and cycling.

• An appropriate range of employment opportunities in rural areas.

9. Landscape and townscape

a) Ensure that the quality, character and local distinctiveness of the landscape, and the features within them are conserved and enhanced.

b) Enhance the form and design of the built environment.

• Provide the character areas and SLA’s with the highest level of policy protection, make appropriate provision for their economic and social wellbeing and reflect Management Plan objectives?

• Encourage development which considers the existing character, form and pattern of the landscape, buildings and settlements?

• Encourage development which incorporates green infrastructure into the design e.g. green corridors, linking open space etc.?

• Encourage development which incorporates sports infrastructure into the design e.g. public football pitches, mini pitches, swimming pools?

10. Material assets

a) To ensure that the housing stock meets the housing needs of the local people.

• Sufficient affordable housing to meet identified needs, including the needs of the community and local economy.

• Achieve well-designed compact communities which are developed at sufficient density to support viable local services and public transport provision and which achieve efficient use of land.

• Good access to facilities, particularly by public transport, walking and cycling.

11. Population

a) To develop and maintain a balanced and sustainable population structure with good access to services and facilities.

• Development which delivers an appropriate mix of housing including affordable housing and appropriate housing for older people in locations close to local services/facilities.

• Appropriate community, social and transport infrastructure.

Minimise and reduce local flood related risks to the population and the environment and adverse impacts on human health.

12. Social deprivation

a) To reduce spatial inequalities in social opportunities.

• Improved provision of key services in deprived communities.

• Reduced spatial inequalities in access to services including healthcare and education and local/community services.

• Provision of local facilities which are accessible by walking and cycling and public transport.

13. Soil, geology and land use

a) Reduce land contamination, and safeguard soil and geological quality and quantity.

• The remediation of contaminated sites?

• Levels of development on brownfield sites that are above the national target of 60%?[1]

• Development that protects soil processes and functions?

• Development that protects sites valued for their geological characteristics?

14. Waste

a) To reduce waste generation and disposal, increase recycling and achieve the sustainable management of waste.

• Explicitly set out to reduce the amount of waste generated by development and land use change?

• Explicitly encourage development to use re-cycled materials and make provision for recycling / composting in all new development?

• Make positive provision for appropriate sites for waste management facilities including waste to energy generation, with landfill being the least favoured option?

• Encourage the reduction in the production and movement of hazardous waste?

15. Water

a) Maintain and continue to improve the ecological and chemical quality of groundwater and river water surface waters.

b) Reduce risk of flooding.

c) Improve efficiency of water use.

d) Identify opportunities to implement strategic flood risk management options/measures to reflect the objectives in the River Nene and Great Ouse CFMPs.

• Development where adequate water supply, foul drainage, sewage treatment facilities and surface water drainage is available?

• Water efficient design and reduction in water consumption (e.g. rainwater recycling/grey water reuse and BREEAM/EcoHomes Excellent Standard)?

• Development which supports and corresponds with PPS 25 and the flood risk management policies of the EA? the NPPF, Planning Practice Guidance and the flood risk management policies of the EA and LLFA.

• Development likely to affect the ecological and chemical status of groundwater and surface water and the ability of receiving water to accept additional flows?

• Development that results in increased spills from combined sewer outlets?

• The incorporation of the flood risk management policies set out in the River Nene CFMP and the Great Ouse CFMP?

• Safeguarding of flood storage areas identified in the Nene and Great Ouse CFMPs?

• Development which incorporates SUDS (including their long-term maintenance), to ensure there is no increase in flood risk (and where possible lead to a reduction in flood risk)?

The sustainable use of water resources?

The requirements of the Water Framework Directive River Basin Management Plans being met (incl. improvement of water bodies)?

Maintain and enhance riverside and water based recreational activities (including navigation, angling, canoeing)?


1. Note that this is no longer a national target in the NPPF. Paragraph 111 of the NPPF states that local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land. The sub-objective has not been changed but the appraisal, but the appraisal has just considered whether options contribute to re-use of previously developed land rather than exceeding the former national target of 60%. [back]

Predicting effects

4.8 The assessment has focused on the likely significant effects of implementing the reasonable alternatives for each of the components being addressed in the Addendum work, and has, where possible and reasonable, distinguished between and reported on the different types of effects (listed in the box above, i.e. temporal, cumulative etc.).

Determining significance

4.9 Schedule 1 of the SEA Regulations sets out criteria for determining the likely significance of effects. These criteria relate to:

  • The characteristics of the plan or programme (in this case the West Northamptonshire JCS).
  • The characteristics of the effects and of the area likely to be affected (in this case, generally the urban edges of the four main towns, but also some other locations in the JPU area where employment or new settlement sites have been proposed).

4.10 In determining the significance of the effects of the additional reasonable alternatives considered for the Proposed Main Modifications to the West Northamptonshire JCS, it is important to bear in mind its relationship with the other documents in the planning system such as the NPPF and other Local Plans being prepared by the constituent local authorities (as described in Chapter 2 of this report), as some of these documents may provide additional safeguarding, protection or mitigation of potential effects. In addition, other Local Plans may themselves already have been subject to SA and therefore have assessed in more detail the potential effects of certain proposals addressed in the JCS (e.g. development proposed in the Northampton Central Area Action Plan, which is referred to in Policy N2 of the JCS).

4.11 However, the likely effects of the Proposed Main Modifications to the West Northamptonshire JCS (and reasonable alternatives) need to be determined in order that their significance can be assessed. This inevitably requires a series of judgements to be made, and for the SUE alternative locations, and the strategic employment alternative locations we have set out our specific assumptions used for each SA objective (see Appendices 5 and 12 respectively).

4.12 The sustainability appraisal has been carried out using a matrix based approach (see Appendices 3, 4, 6-9, 11 and 13). Our appraisal has attempted to differentiate between significant effects and other more minor effects through the use of colours and symbols as shown below. Note that each of these effects may have uncertainty attached (shown by a ‘?’ after the score), but the colour does not change.


Significant positive effect likely


Minor positive effect likely


Negligible effect likely


Minor negative effect likely


Significant negative effect likely


An element of uncertainty is attached to the effect


Mixed (significant positive and significant negative) effect likely


Mixed (significant positive and minor negative) effect likely


Mixed (significant negative and minor positive) effect likely


Mixed (minor positive and minor negative) effect likely


Information used in predicting effects

4.13 In carrying out the SA use has been made of Geographical Information Systems (GIS) which provide mapped data of key factors of relevance to the identification of significant effects such as:

  • Biodiversity and cultural heritage designations.
  • Agricultural land classifications.
  • Areas at risk of flooding.
  • Location of schools, colleges, doctor’s surgeries and hospitals.
  • Existing walking and cycle routes and bridleways.
  • Local Geological Sites.
  • Land instability classifications.
  • Air Quality Management Areas.

4.14 The SA has also been informed by the technical studies listed as the Evidence Base within the Hearings Document List (18 April 2013) as well as any updates since that list was produced, and relevant documents submitted to the Hearings and subsequently by representors. 

4.15 The SA has also taken into account the findings of the Habitats Regulations Assessment (HRA) undertaken by Environ[2] , and the HRA Addendum work prepared by LUC[3] .


2. West Northamptonshire Joint Core Strategy Pre Submission Appropriate Assessment. Environ, 2011, and West Northamptonshire Joint Core Strategy Habitats Regulations Assessment Addendum Report. Environ, 2012. [back]
3. HRA of West Northamptonshire Joint Core Strategy. Addendum Report to Reflect Post-Submission 'Main Modifications'. LUC, 2013. [back]