Bath & North East Somerset Local Plan
Sustainable Development Appraisal 

Introduction

Levett-Therivel and Oxford Brookes University’s Impacts Assessment Unit have been commissioned by Bath and North East Somerset Council to advise on, participate in, and audit the results of the sustainable development appraisal of the Bath and North East Somerset local plan deposit version.

We have:

• Advised on the appraisal criteria and appraisal format used

•  “Screened out” roughly 10% of the plan policies that we felt were unlikely to have significant sustainability impacts

• Participated in a three-day intensive appraisal session involving a dozen Council staff and two consultants, in which the remaining plan policies were appraised

This report sets out our conclusions/audit about the appraisal process and findings.

Context 

The aim of sustainability appraisal is to ensure that consideration for sustainable development is ingrained in the strategy making process.   A range of Government guidance[1] and international reports[2] suggest how this can be done, including what appraisal stages should be carried out, and what issues should be covered in an appraisal.  These documents suggest that a good appraisal would:

• Consider sustainability, not just environmental issues

• Base the plan on clear objectives, and test the achievement of these objectives using indicators

• Describe the baseline environment and key problems/issues for sustainability, as a context for the appraisal

• Identify the main costs and benefits of each aspect of the plan

• Identify and compare options/alternatives where appropriate

• Propose mitigation measures for significant negative impacts

 Our own experience, and findings from a recent questionnaire of local authorities[3], suggests that how the appraisal process is carried out is also integral to its effectiveness.  So, for instance, we would wish to see that an appraisal: 

• Starts early and integrates the appraisal in the plan-making process

• Is treated as a way of improving the plan, not as a “snapshot” taken once the plan is finalised; and focuses on improving the plan rather than justifying it

• Involves a range of experts/stakeholders in the appraisal process, including the planners who wrote the plan.

The following audit findings refer to these elements of good practice: appraisal content and process.

Audit findings

 Appraisal content 

Bath and North East Somerset’s appraisal covered the full range of sustainability issues.  The appraisal checklist was based on a checklist that the Council had used for their issues papers, supplemented with the criteria used by Leicester City and LB Hounslow, both known for their leading edge work on sustainability appraisal.  

The plan is currently only in its draft stages, and so the links between objectives (strategic policies/aims) and the plan policies have not yet been finalised.  Overall we would wish to see clearer links between the strategic policies and the rest of the plan, and arguably between the strategic policies and the Government’s sustainable development objectives.  This could take the form of a compatibility matrix which shows the strategic policies on one axis and the other plan policies on another (and/or the government’s objectives v. B&NES’s strategic policies).  

A related issue raised during the appraisal process was whether the Council should (especially given the area’s relative affluence) promote more innovative, leading-edge, “truly sustainable” development. 

At present the appraisal includes no documented reference to the baseline environment.  This is not a severe problem, since B&NES’s planners clearly know what the relevant issues are.  However for the sake of transparency – and because it will become legally required from 2004 -- we suggest that the final appraisal at least lists what the planners perceive to be the major relevant issues/problems, supplemented with monitoring data where it already exists. 

The appraisal clearly identifies the main costs and benefits of each policy.  For Policy GDS1, which proposed a range of development sites, an appraisal was carried out of all of the sites that had not already received planning permission, were not very small, and were not very similar in terms of sustainability impacts.  A previous issues and options paper appraised key alternatives.    

The appraisal considered mitigation measures throughout.  Some of these will be incorporated in the plan before it is put on deposit.  The rest will be considered in parallel with the submissions made during the deposit stage. 

In summary, the appraisal of the pre-deposit draft of the plan included most of the key requirements of good practice appraisal contents, and certainly all of those needed for a basic appraisal under current Government requirements: sustainability issues, costs and benefits, alternatives, mitigation.  Clearer links to objectives will presumably be made anyway as part of the next stages of plan-making.  A description of the baseline environment would be useful.

Appraisal process 

Bath and North East Somerset’s local plan was appraised at virtually the same time as it was going to Committee.  The results of the appraisal will, in the short term, be used only to refine the wording on a limited number of policies.  However we understand that the appraisal findings will be fully considered in parallel with other submissions after the plan deposit stage.  As such, although the appraisal will have limited impact in the short term, it was carried out at a time when it will (in the longer term) still clearly have a chance to influence the plan. 

 In our view the most positive, and enjoyable, aspect of the appraisal process was the planners’ willingness to treat the appraisal process as a way of improving the plan.  This can be seen from the final column in each appraisal matrix, which refers to potential changes to the policy.  Changes were proposed for most of the policies, including quite fundamental changes in some cases. 

Finally, the appraisal was carried out in groups of 3-5 people, with a range of expertises represented in each group.  Each group also contained either a consultant or Stephen George (the sustainability appraisal co-ordinator for B&NES) to ensure impartiality.  This variety of viewpoints contributed greatly to the effectiveness of the process, particularly in terms of challenging preconceptions and clarifying points that seemed obvious to the policy author but not to everyone else.  In some cases the planner who wrote the relevant policy was not in the group that appraised that policy.  However the presence of other planners in that group, and the comprehensive documentation of the appraisal results, should help to ensure that the appraisal findings will be taken into account in time. 

The appraisal was carried out as a three-day intensive away event.  We feel that this approach meant that minds were concentrated on the appraisal, so that it was completed both more consistently and with a shorter time input than might otherwise have been necessary.  Equally importantly, this immersion approach, combined with the opportunity to look at policies beyond their own usual acquaintance, should mean that when writing policy in future, these planners will "think sustainability first" and draft in that spirit. 

In summary, we feel that the appraisal process was carried out using a best practice approach to a high standard. 

Dr. Riki Therivel                                                           Dr. Jake Piper

Levett-Therivel                                                            Impacts Assessment Unit

                                                                                    Oxford Brookes University