Joint Core Strategy - Proposed Main Modifications

1 Introduction

1.1 The West Northamptonshire Joint Planning Unit (WNJPU) commissioned LUC in June 2013 to carry out the additional Sustainability Appraisal (SA) incorporating Strategic Environmental Assessment (SEA) work required for the West Northamptonshire Joint Core Strategy.


1.2 During the Examination hearing sessions for the Joint Core Strategy in April 2013, the Inspector requested that the Joint Planning Unit undertake a fresh assessment of objectively assessed housing needs for the Plan area, and that it also prepares a SA/SEA Addendum Report to address shortcomings in the SA work that has been undertaken to date, particularly in relation to the selection of Sustainable Urban Extension (SUE) sites in relation to the reassessed housing needs.

Purpose of this SA Addendum Report

1.3 This report is an Addendum to the full 2011 SA Report[1] for the Pre-Submission Joint Core Strategy, and the 2012 SA Addendum[2] that was prepared to accompany the Proposed Changes Joint Core Strategy for Submission to the Secretary of State, and should be read alongside both of those reports, as together they seek to meet the requirements of the SEA Directive.

1.4 This Addendum describes the options considered by the JPU following the hearing sessions in April 2013, which include options for the quantum of housing and employment development to be delivered as well as spatial options relating to how development should be distributed across the JPU area. The options have been assessed by the JPU and subject to SA by LUC, and these assessments have informed the JPU’s work on preparing Proposed Main Modifications to the Joint Core Strategy. This report describes the potential sustainability effects of the options and summarises the JPU’s reasons for selecting or discounting options. Finally, this Addendum reports on the SA implications of the Main Modifications being proposed to the Joint Core Strategy, and highlights any differences from the Proposed Changes version of the Joint Core Strategy (July 2012) (hereafter referred to as the “JCS as submitted”).

1. West Northamptonshire Joint Core Strategy Sustainability Appraisal Report. Environ, February 2011. [back]
2. West Northamptonshire Joint Core Strategy Volume 1: Sustainably Appraisal Report Proposed Changes Addendum and Volume 2: Appendix D: Sustainability Appraisal Proposed Changes Assessment Tables. Environ, July 2012. [back]

Sustainability Appraisal and Strategic Environmental Assessment

1.5 Under the Planning and Compulsory Purchase Act 2004, SA is mandatory for Local Plans. For these documents it is also necessary to conduct an environmental assessment in accordance with the requirements of the Strategic Environmental Assessment (SEA) Directive (European Directive 2001/42/EC). Therefore, it is a legal requirement for the Joint Core Strategy to be subject to SA and SEA throughout its preparation.

1.6 The requirements to carry out SA and SEA are distinct, although it is possible to satisfy both using a single appraisal process. Government guidance[3] provides information to assist users in complying with the requirements of the SEA Directive through a single integrated SA process – this is the process that is being undertaken for West Northamptonshire. In addition, the guidance widens the SEA Directive’s approach to include social and economic as well as environment issues. From here on, the term ‘SA’ should therefore be taken to mean ‘SA incorporating the requirements of the SEA Directive’.

1.7 The SA process comprises a number of stages, as shown in Figure 1.1:

Figure 1.1: Main stages of Sustainability Appraisal

Stage A:     Setting the context and objectives, establishing the baseline and deciding on the scope    
Stage B:     Developing and refining options and assessing effects    
Stage C:     Preparing the Sustainability Appraisal Report    
Stage D:     Consulting on the preferred options of the Plan and SA report    
Stage E:     Monitoring the significant effects of implementing the Plan    

 

Relationship between this SA Addendum and the SA work undertaken to date for the Joint Core Strategy

Stage A: Scoping

1.8 An SA Scoping Report was published in 2006 as part of the SA of the Joint Core Strategy. This comprised a main Scoping Report and 15 supporting topic papers (combined 260 pages). The information in the 2006 SA Scoping Report was updated in the subsequent SA Reports (most recently in the 2011 SA Report), and much of it is still relevant to the SA work for the Joint Core Strategy as a whole. LUC prepared an additional SA Scoping Report[4] in July 2013 to address the scope of work being covered by the JPU to consider additional options arising from the Examination hearings. A full update of the SA Scoping Report was not necessary, but the July 2013 SA Scoping Report did include specific baseline information relating to the areas around the four main towns, as well as the criteria to be used for determining what were the ‘reasonable’ alternatives to be taken into consideration by the JPU. The Scoping Report was consulted upon between 22nd July and 30th August 2013, and the consultation responses received from the statutory consultees are summarised in Appendix 1 to this Addendum along with an explanation of how and where they have been addressed. Comments were also received from other interested individuals and organisations and the JPU produced a statement of consultation which summarises those representations. These have been taken into account while preparing this SA Addendum.

Stage B: Options development and assessment

1.9 As noted above, this SA Addendum should be read alongside the full 2011 SA Report[5] for the Pre- Submission Joint Core Strategy, and the 2012 SA Addendum[6] that was prepared to accompany the JCS as submitted. Chapter 3 of the 2011 SA Report summarises the options that were
considered at each stage in the Joint Core Strategy’s preparation, and Appendices B, C and D of the 2011 SA Report set out the potential sustainability effects of all of those options.

1.10 The work that the JPU has been undertaking since the Examination hearing sessions in April 2013 has involved revisiting a number of options (or alternatives), e.g. locations for sustainable urban extensions (SUEs) around the four main towns, as well as considering additional new options such as the quantum of housing arising from the objective assessment of housing need. These are described further below, and the reasons for selecting or discounting the SUE options are summarised in Appendix 10.

Stage C: Preparing the SA Report

1.11 The SA Reports up to and including the 2012 SA Addendum were prepared by Environ on behalf of the West Northamptonshire JPU. They are all available for download on the JPU’s website. LUC has prepared the SA Addendum Scoping Report (July 2013) and this SA Addendum to cover the work undertaken by the JPU in determining the Proposed Main Modifications to the Joint Core Strategy.

Stage D: Consulting on the SA Report and plan

1.12 All of the earlier SA Reports were consulted upon alongside the relevant version of the Joint Core Strategy. The Scoping Report for this SA Addendum was subject to a five week consultation period as described above, and this SA Addendum will also be available during the consultation period for the Proposed Main Modifications to the Joint Core Strategy during January-February 2014.

Stage E: Monitoring the significant effects of implementing the Plan

1.13 Chapter 8 of the 2011 SA Report set out recommendations for monitoring the social, environmental and economic effects of implementing the West Northamptonshire Joint Core Strategy. Based on the SA findings from this SA Addendum, the monitoring recommendations have been updated to reflect the Proposed Main Modifications to the Joint Core Strategy in Chapter 11 of this SA Addendum. These monitoring proposals should be considered within the context of the broader monitoring framework for the JCS and the data collection for the JPU’s Monitoring Report.




3. Contained within the Plan-Making Manual hosted on the Planning Advisory Service website (www.pas.gov.uk). [back]
4. West Northamptonshire Joint Core Strategy SA Addendum – Scoping Report. LUC, July 2013. [back]
5. West Northamptonshire Joint Core Strategy Sustainability Appraisal Report. Environ, February 2011. [back]
6. West Northamptonshire Joint Core Strategy Volume 1: Sustainably Appraisal Report Proposed Changes Addendum and Volume 2: Appendix D: Sustainability Appraisal Proposed Changes Assessment Tables. Environ, July 2012. [back]

Additional SA work undertaken for this SA Addendum

1.14 There are six main components of work for the Joint Core Strategy that the SA Addendum has covered:

  1. Appraisal of reasonable alternatives for the quantum of housing and jobs arising from the objective assessment of need described in the JPU’s report Objectively Assessed Housing Needs V2 (December 2013).
  2. Appraisal of reasonable alternatives for the overall spatial distribution of development within the plan area, and consideration of one or more locations for a new settlement.
  3. Appraisal of reasonable alternatives for the spatial distribution of development at the town level, which concerns how much development should be directed to each town and where, including consideration of the alternative spatial distribution proposed by Northamptonshire County Council.
  4. Appraisal of the JPU’s Preferred Choice and reasonable alternatives for the SUE allocations.
  5. Appraisal of reasonable alternatives for strategic employment sites.
  6. Appraisal of the Main Modifications proposed for the Joint Core Strategy.

1.15 The alternatives considered under each component are summarised below, with further detail provided in Chapters 5-10.

1. Quantum of housing and jobs

1.16 Three options for the quantum of housing and jobs were identified by the WNJPU as requiring appraisal, on the basis of the JPU’s report on Objectively Assessed Housing Needs[7] :

  • Option 1 – Cambridge Tracking: This option assumes the delivery of 41,760 net additional dwellings and 28,520 net additional jobs over the period 2011-2029 in accordance with the Proposed Main Modifications to the JCS.
  • Option 2 – ONS 2011 Extended (reduced phasing): This option assumes the delivery of 36,972 net additional dwellings and 26,849 net additional jobs over the period 2011-2029 in accordance with the Proposed Main Modifications to the JCS, but with a slower rate of delivery.
  • Option 3 – ONS 2011 Extended (reduced SUEs): This option assumes the delivery of 36,972 net additional dwellings and 26,849 net additional jobs over the period 2011-2029 in accordance with the Proposed Main Modifications to the JCS, but with the deletion of between two and five SUEs (unspecified).

1.17 The purpose of this work was to assess the reasonable alternatives for the quantum of housing and jobs against the SA Framework and to record this assessment in a clear and transparent way.

2. Overall spatial distribution of development

1.18 This component of work focused on three options:

  • Option A – distributing growth widely around the edges of the urban areas in many locations where development is found to be feasible.
  • Option B – focusing growth in a small number of larger development areas.
  • Option C – new settlements in sustainable locations including brownfield land in the countryside.

1.19 Options A and B were already assessed in 2009 by Environ for the SA of the Emergent Joint Core Strategy. This assessment was recorded in the Draft Sustainability Appraisal Report of the EJCS [GLD07] as Option 1 and Option 2, and does not need to be updated. Therefore, the additional sustainability appraisal work considered Option C and whether the reasons for choosing Option B remain valid in the light of the selected quantum option. This is described in Chapter 6 of this SA Addendum.

3. SUE distribution around the four main towns

 

1.20 The purpose of this component of work was to reconsider alternative locations for the distribution of sustainable urban extensions at each of the towns of Northampton, Daventry, Towcester and Brackley and consider whether they are ‘reasonable’ alternatives (i.e. taking into account the objectives and Policy S1 of the West Northamptonshire Joint Core Strategy, as set out in the Pre-Submission Joint Core Strategy and amended by the Proposed Changes [SUB04], as well as deliverability within the Plan period), and to document this decision-making. Each reasonable alternative was appraised against the SA Framework drawing on the earlier SA work where appropriate but also including alternatives that have not been appraised to date where they met the ‘reasonableness’ test.

1.21 The reasonableness test is described further in Chapter 4, and a description of the locations appraised and the SA findings is provided in Chapter 7.

1.22 Alongside the SA of the reasonable alternative SUE locations around each of the four main towns, the JPU undertook a wider planning assessment of whether each SUE location should be allocated in the JCS or not. This involved considering whether the SUE location complies with the JCS Vision, Objectives and overarching Policy S1, taking the SA and Habitats Regulations Assessment (HRA) findings into account, as well as other deliverability issues such as whether the site is available and any infrastructure requirements. The JPU Planning Assessment is set out in a separate document prepared by the JPU entitled: “Site Selection Report” (December 2013).

1.23 The JPU considered the findings from all the above work in order to develop its revised preferred approach. For Daventry, Towcester and Brackley, the JPU’s preferred approach has not changed from the SUEs allocated already in the JCS as submitted. For Northampton, the JPU considered whether there are options for distributing the development by proposing more or less housing at some of the currently allocated SUEs, as well as allocating additional SUEs. The JPU concluded on the basis of the SA work undertaken under Task 3 above and other technical work, that such alternatives should be rejected. The reasons are provided at the end of Chapter 7.

4. Preferred and alternative SUE allocations

1.24 In order to test its revised preferred approach, the JPU decided that the sustainability effects of the revised preferred approach needed to be appraised in more detail and then compared with an appraisal of the current distribution of SUEs as allocated in the JCS as submitted. A third option was also subject to appraisal, being the alternative spatial distribution proposed by Northamptonshire County Council:

  • Northamptonshire County Council proposes within the same total amount of development identified in the Pre-Submission Joint Core Strategy for the Northampton Related Development Area:
    • Deletion of the Northampton West Sustainable Urban Extension (Policy N4);
    • Deletion of the Northampton South Sustainable Urban Extension (Policy N5); and
    • Enlargement of the Northampton North Sustainable Urban Extension (Policy N3).

1.25 More detail regarding the three options is provided in Chapter 8, along with the SA findings.

5. Appraisal of reasonable alternatives for strategic employment sites

1.26 In addition to the SUE alternative locations appraised, a number of alternative strategic employment site locations were also appraised, as these sites had been promoted by stakeholders during the Examination hearing sessions in April 2013. These are described in more detail in Chapter 9 of this SA Addendum.

6. Appraisal of the Main Modifications proposed for the Joint Core Strategy

 

1.27 Proposed Main Modifications to the JCS as submitted have been prepared by the JPU. These Proposed Main Modifications set out changes identified before, during and soon after the Examination Hearings in April and May 2013 as well as changes which have resulted from the Objectively Assessed Housing Needs and the SA Addendum work. The proposed Main Modifications are shown in a schedule as further changes to the JCS as submitted [SUB04]. Chapter 10 of this SA Addendum describes whether or not any of the proposed Main Modifications to the JCS have changed the findings set out in the previous SA Reports (2011 and the 2012 SA Addendum).

 

 

 

 

7. West Northamptonshire Joint Core Strategy. Objectively Assessed Housing Needs. West Northamptonshire Joint Planning Unit, July 2013. [back]

Meeting the requirements of the SEA Directive

1.28 This SA Addendum includes some of the required elements of the final ‘Environmental Report’ (the output required by the SEA Directive). Table 1.1 below signposts the relevant sections of the SA Addendum that are considered to meet the SEA Directive requirements (the remainder have either been met through the SA Scoping Reports (2006 and 2013), the 2011 SA Report and 2012 SA Addendum).

Table 1.1 Meeting the Requirements of the SEA Directive

SEA Directive Requirements

Where has the requirement been met?

Preparation of an environmental report in which the likely significant effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and geographical scope of the plan or programme, are identified, described and evaluated.  The information to be given is (Art. 5 and Annex I):

This SA Report Addendum plus the full 2011 SA Report and 2012 SA Addendum for the West Northamptonshire Joint Core Strategy constitute the ‘environmental report’.

a)   An outline of the contents, main objectives of the plan or programme, and relationship with other relevant plans and programmes;

Chapter 1 describes the focus of the Addendum, and Chapter 2 provides the outline of the JCS contents, main objectives and relationship with other relevant plans and programmes, plus Chapter 4 of the 2011 SA Report.

b)   The relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme;

Chapter 3 describes the current state of the environment, focusing on the areas most likely to be affected by the options being appraised through the SA Addendum (i.e. the four main towns and their fringes), plus

Chapter 5 of the 2011 SA report.

c)   The environmental characteristics of areas likely to be significantly affected;

Chapter 3 as above, plus

Chapter 5 of the 2011 SA report.

d)   Any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC.;

Chapter 3 as above, plus

Chapter 5 of the 2011 SA report.

e)   The environmental protection, objectives, established at international, Community or national level, which are relevant to the plan or programme and the way those objectives and any environmental, considerations have been taken into account during its preparation;

Chapter 2 summarises the environmental and sustainability objectives contained in international, European and national plans or programmes published since those included in Chapter 4 of the 2011 SA Report.

f)    The likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors. (Footnote: These effects should include secondary, cumulative, synergistic, short, medium and long-term permanent and temporary, positive and negative effects);

Chapters 5-10 of this SA Report Addendum, plus Chapter 7 of the 2011 SA Report and Appendix D of 2012 SA Addendum.

g)   The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme;

Chapters 5-10 of this SA Report Addendum, plus Chapter 7 of the 2011 SA Report and Appendix D of 2012 SA Addendum.

h)   An outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information;

Chapters 5-10 of this SA Report Addendum, plus Chapter 3 of the 2011 SA Report.

i)    a description of measures envisaged concerning monitoring in accordance with Art. 10;

Chapter 11 of this SA Report Addendum, plus Chapter 8 of the 2011 SA Report.

j)    a non-technical summary of the information provided under the above headings

A non-technical summary has been prepared for this SA Report Addendum, plus separate non-technical summary to the 2011 SA Report.

The report shall include the information that may reasonably be required taking into account current knowledge and methods of assessment, the contents and level of detail in the plan or programme, its stage in the decision-making process and the extent to which certain matters are more appropriately assessed at different levels in that process to avoid duplication of the assessment (Art. 5.2)

This SA Report Addendum has adhered to this requirement.

Consultation:

·         authorities with environmental responsibility, when deciding on the scope and level of detail of the information which must be included in the environmental report (Art. 5.4)   

Consultation with the relevant statutory environmental bodies was undertaken in relation to the Scoping Report Addendum from Thursday 25th July – Friday 30th August 2013 (5 weeks and 1 extra day to compensate for the August Bank Holiday).

·         authorities with environmental responsibility and the public, shall be given an early and effective opportunity within appropriate time frames to express their opinion on the draft plan or programme and the accompanying environmental report before the adoption of the plan or programme (Art. 6.1, 6.2)

Public consultation on the SA Report Addendum is proposed for January-February 2014.

·         other EU Member States, where the implementation of the plan or programme is likely to have significant effects on the environment of that country (Art. 7). 

Not relevant as there will be no effects beyond the UK from the West Northamptonshire Joint Core Strategy.

Taking the environmental report and the results of the consultations into account in decision-making (Art. 8)

Provision of information on the decision:

When the plan or programme is adopted, the public and any countries consulted under Art.7 must be informed and the following made available to those so informed:

·         the plan or programme as adopted

·         a statement summarising how environmental considerations have been integrated into the plan or programme and how the environmental report of Article 5, the opinions expressed pursuant to Article 6 and the results of consultations entered into pursuant to Art. 7 have been taken into account in accordance with Art. 8, and the reasons for choosing the plan or programme as adopted, in the light of the other reasonable alternatives dealt with; and

·         the measures decided concerning monitoring (Art. 9)

Requirement will be met at a later stage in the SA process, once the JCS has been adopted.

Monitoring of the significant environmental effects of the plan's or programme's implementation (Art. 10) 

Requirement will be met at a later stage in the SA process, once the JCS has been adopted.

 

Habitats Regulations Assessment

1.29 Under Article 6 (3) and (4) of the Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora (Habitats Directive) land-use plans, including Local Plans, are also subject to Habitats Regulations Assessment (HRA). The purpose of HRA is to assess the impacts of a land-use plan against the conservation objectives of a European Site and to ascertain whether it would adversely affect the integrity of that site. The HRA process for the West Northamptonshire Joint Core Strategy has been undertaken separately but the findings have been taken into account in the additional SA work where relevant.

Structure of the SA Addendum Report

1.30 This chapter (Chapter 1) has described the background to the additional Joint Core Strategy work and the requirement to undertake additional SA work. It also summarises the types of reasonable alternatives that have been subject to appraisal. The remainder of this report is structured into the following sections:

  • Chapter 2 describes the updated policy context for the Joint Core Strategy, as well as the relationship between the additional Joint Core Strategy work and other relevant plans or programmes, and the current environmental, social and economic policy objectives set at the international, European and national level.
  • Chapter 3 presents an update of the key environmental, social and economic characteristics and factors pertaining to the plan area, focusing on the areas likely to be affected, insofar as they are relevant to the appraisal work to be undertaken.
  • Chapter 4 presents the method that has been used to undertake the appraisal, including the reasonableness criteria used to identify reasonable alternatives, the SA framework, and the approach to predicting effects including assumptions used.
  • Chapters 5 to 10 describe the findings of the appraisal of the different sets of reasonable alternatives: quantum of development, overall spatial distribution of development, SUE distribution around the four main towns, preferred and alternative SUE allocations, strategic employment sites, and finally the Proposed Main Modifications to the JCS.
  • Chapter 11 summarises the conclusions of the SA Addendum work, including the influence of this component of the SA on the JCS and any additional monitoring requirements not already identified in the earlier SA work (2011 SA Report and 2012 SA Addendum).