SA Addendum Scoping Report

1 Introduction

Preface


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 Scoping Report

 

1.3        The scoping stage of SA/SEA involves reviewing other relevant plans, policies and programmes, considering the current state of the environment in the plan area, identifying any key environmental issues or problems which may be affected by the plan and setting out the "SA framework" which comprises specific objectives against which the likely effects of plan policies and site allocations can be assessed.

1.4         An SA Scoping Report and appended topic papers were 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 recent is 2011), and much of it is still relevant to the SA work for the Joint Core Strategy as a whole. The current additional SA/SEA work is focusing on particular elements of the Joint Core Strategy, and in light of what the SEA Regulations state is required at the scoping stage, a full update of the SA Scoping Report is not necessary.

1.5         The purpose of the consultation on the scope of the SA is to give the consultation bodies (and other organisations and the public, if so desired) an opportunity to comment on the scope of the work to be undertaken and the level of detail of the appraisal work. Although the final SA Report is required to report on a range of matters relating to the current state of the environment, it is not necessarily required of the Scoping Report.

1.6         Therefore, this Scoping Report focuses on the work that will be required in preparing the Addendum to the full SA Report, and rather than being a full update of the 2006 Scoping Report, it provides the context for, and determines the scope of, the additional SA/SEA work required for the Joint Core Strategy.

Additional SA work to be undertaken

 

1.7         There are four components of work that the SA Addendum will cover:

1           Appraisal of reasonable alternatives for the quantum of housing and jobs.

2           Appraisal of reasonable alternatives for the spatial distribution of development, which concerns the overall distribution of development within the plan area.

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, and consideration of one or more locations for a new settlement.

4           Appraisal of reasonable alternatives for strategic site allocations (as a more detailed variation of component 3).


1.8        The alternatives to be considered under 1, 3 and 4 above are still being finalised by the WNJPU.

1. Quantum of housing and jobs

 

1.9         Three options for the quantum of housing and jobs have been identified by the WNJPU as a starting point, as set out in the draft Scope of Works[1] :

  • Option A (Housing) – 49,325 dwellings 2001-2026 (ONS 2011 + 3%), and (Jobs) - 21,635 jobs 2008-2026.
  • Option B (Housing) – 53,120 dwellings 2001-2026 (Short term migration), and (Jobs) – 24,506 jobs 2008-2026.
  • Option C (Housing) – 57,245 dwellings 2001-2026 (Toolkit 2008 + 3%), and (Jobs) – 27,627 jobs 2008-2026.

1.10       However, external consultants have also been commissioned to carry out an objective assessment of housing and employment need rolling forward to 2029 and 2031, and the results of those two studies will be used to finalise the options that will be appraised.

1.11       The purpose of this work is 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. Reasons will be given for the selection of the options and choice of option.

1. West Northamptonshire Joint Core Strategy Local Plan (Part 1). Sustainability Appraisal Report Addendum – Scope of Works. West Northamptonshire Joint Planning Unit, April 2013. [back]

2. Overall spatial distribution of development

 

1.12       This component of work will focus 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.

1.13       Options A and B were already assessed in 2009 against the SA Framework, which was developed as part of the 2006 SA Scoping Report. 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.

1.14       Therefore, the additional sustainability appraisal work will consider Option C and whether the reasons for choosing Option B remain valid in the light of the selected quantum option.

3. Spatial distribution around the four main towns

 

1.15       The purpose of this component is to identify alternatives for the distribution of development 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 will be appraised against the SA Framework drawing on the earlier SA work where appropriate but potentially including alternatives that have not been appraised to date where they meet the "reasonable" test.

1.16       As part of this component, an alternative spatial distribution proposed by Northamptonshire County Council will also be appraised:

  • 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).

4. Strategic site allocations/SUEs

 

1.17       The purpose of this work is to identify alternative strategic sites/SUEs, consider whether they are reasonable alternatives, and to document this decision-making. This work involves identifying the list of reasonable alternative SUEs to appraise. The starting point will be the 14 sites put forward during the Examination, as well as the SUEs allocated in the Pre-Submission Joint Core Strategy as amended by the Proposed Changes [SUB04].

Links before the four components

 

1.18       The four component pieces of work are closely linked, and therefore it is anticipated that there will be an element of iteration between the higher level "top-down" components (i.e. components 1 and 2) and the more detailed "bottom-up" components (i.e. components 3 and 4), with the various appraisals informing one another in order to generate more robust results.

Reasonableness criteria

 

1.19      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"

1.20       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.

1.21       In order to identify "reasonable" alternatives for components 3 and 4 (i.e. spatial distribution around the towns and strategic site allocations) to be assessed as part of this additional work for the Joint Core Strategy, a set of draft "reasonableness" criteria has been developed. The draft 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. The draft reasonableness criteria are shown in bold text in the second column in Table 1.1.

Table 1.1 Draft reasonableness criteria for identifying reasonable alternatives to be covered in the SA Addendum work

 

Policy or objective in NPPF and Joint Core Strategy

 

Draft reasonableness criteria

 

NPPF

 

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 are areas of higher risk 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

Battlefields

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 Draft Minerals and Waste Local Plan for consultation (January 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 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 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 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).

Sustainability Appraisal and Strategic Environmental Assessment

 

1.22       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.

1.23       The requirements to carry out SA and SEA are distinct, although it is possible to satisfy both using a single appraisal process. Government guidance[2] 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'.

1.24       The SA process comprises a number of stages, with scoping being Stage A as shown in Figure 1.1 below:

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    

 

1.25       Figure 1.2 below sets out the tasks involved in the Scoping stage

Figure 1.2: Stages in SA scoping (Stage A)

A1:     Identifying other relevant policies, plans and programmes, and sustainability objectives.    
A2:     Collecting baseline information.    
A3:     Identifying sustainability issues and problems.    
A4:     Developing the SA framework    
A5:     Consulting on the scope of the SA.    
2. Contained within the Plan-Making Manual hosted on the Planning Advisory Service website (www.pas.gov.uk). [back]

Meeting the requirements of the SEA Directive

 

1.26       This Scoping Report 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 Scoping Report Addendum that are considered to meet the SEA Directive requirements (the remainder are either met through the existing SA Scoping Report (2006) and the 2011 SA Report for the Pre-submission Joint Core Strategy, or in the SA Report Addendum that will be prepared as part of this additional SA/SEA work). An updated version of this table will be included in the SA Report Addendum to show how the SEA Directive requirements have been met through the SA process.

Table 2.1 Meeting the Requirements of the SEA Directive

 

SEA Directive Requirements

Covered in this Scoping Report?

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):

The SA Report Addendum plus the full 2011 SA Report for the West Northamptonshire Joint Core Strategy will 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 the JCS's relationship with other relevant plans and programmes.

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 Addendum

(i.e. the four main towns and their fringes).

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

Chapter 3 as above.

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.

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 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);

Requirement will be met in the SA Report 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;

Requirement will be met in the SA Report 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;

Requirement will be met in the SA Report Addendum.

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

Requirement will be met in the SA Report Addendum.

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

Requirement will be met in the SA Report Addendum.

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 Scoping Report and the Environmental Report will adhere 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 is being undertaken in relation to this Scoping Report Addendum from Thursday 25th July – Friday 30th

August (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 currently proposed for 6 weeks in October and November 2013.

  • 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.

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.

Habitats Regulations Assessment

 

1.27       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 will be taken into account in the additional SA work where relevant.

Structure of the Scoping Report

 

1.28       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 describes the reasonable alternatives that will be 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 will be used to undertake the appraisal, including the SA framework, approach to predicting effects, monitoring, and the proposed structure of the SA Report Addendum.
  • Chapter 5 describes the next steps and timetable for the appraisal work to be undertaken and consultation on SA Report Addendum.