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The Local Government Association is promoting the ‘Sustainability Appraisal’ (SA) process from PAS – England’s Planning Advisory Service – as ‘more than just a tick-box exercise – it should be an integral part of Local Plan preparation.
Local Government Association writes:
… SA provides the evidence to inform, and the framework to test and develop, options ultimately helping to deliver a more sustainable strategy. What’s more, SA is a legal requirement and will be vital to demonstrating to the Inspector that your plan is ‘justified’ at Examination in Public. The aim of this guide is to provide tips and good practice to help LPAs working on Local Plans now to avoid duplication, speed up plan-making and make their Local Plan more accessible and transparent with a focus on good quality evidence…
…The purpose of the sustainability appraisal process is to appraise the social, environmental and economic effects of a plan. In doing so it will help ensure that decisions are made that contribute to achieving sustainable development.
- Sustainability Appraisal (SA) is integral to the plan making process.
- It should perform a key role in providing a sound evidence base for the plan and form an integrated part of the plan preparation process.
- It is good practice for SA to be transparent and open to public participation.
- SA should inform the decision-making process to facilitate the evaluation of alternatives and demonstrate that the plan is the most appropriate given the reasonable alternatives.
However Sustainability Appraisal is often seen as cumbersome and complicated with a focus on process and avoiding challenge, rather than supporting the creation of plans that avoid and address environmental impact and deliver sustainable development. The aim of this guide is to provide tips and good practice to help LPAs working on Local Plans now to avoid duplication, speed up plan-making and make their Local Plan more accessible and transparent with a focus on good quality evidence. It looks at how local authorities might address some of the issues highlighted by the 2022 PAS Barriers and Challenges for Environmental Assessment Report, including the risk of legal challenge (see below). This guide is intended to support LPAs as we wait to find out if reforms to the environmental assessment regime (see EORs below) will be a priority for the new government and through transition to any new system of assessment, as well as a reforms to plan-making. It does not offer detailed guidance or a ‘how-to’ on SA, but hints and tips to make SA and plan-making better and easier.
- Legislative requirements
- Legal challenges
- Guidance and Advice
- Environmental Outcomes Reports
Good practice
Each Council will have its own approach to SA/SEA that is adapted to fit with their plan-making approach. We outline some good practice suggestions below based on a review of SAs written across the country and feedback from local authority officers, as well as SA/SEA consultants and ex-planning inspectors.
- Choosing the resource model that works for you or ‘who’s going to do it?’: There are three main ways that you can resource sustainability appraisal. Each has its pro’s and con’s and you need to carefully consider what the best approach is for your council and plan. This decision should be based on a proactive consideration of what will work best given your local context, rather than a fear of process pitfalls.
- In-house
- External consultant
- Critical friend
- Setting the assessment framework: It’s important to think carefully about how you set the SA Framework, deciding on appropriate sustainability objectives and associated indicators and/or questions for the assessment of your plan and local context. Using a focused, locally relevant framework helps integrate the SA into your plan, keep the process transparent and saves time and money.
- Establish a focused list of SA objectives relevant to your local context
- Think about the relationship between your plan objectives and SA objectives
- Understand the implications of each objective and make sure they are relevant and proportionate
- Decide how you will assess against the objectives
- Integrating SA into plan-making: It’s good practice to keep a project plan for your plan and evidence base including SA, e.g. a Project Initiation Document (PID) – see the PAS Local Plan Route Mapper – and telling the ‘story’ of how SA has informed the plan is key. Some tips are outlined below to help ensure your SA is integrated into plan-making to make a better plan in a more efficient and transparent way.
- Start early and keep your SA focused and proportionate to the status and stage of your plan
- Be transparent and tell the story well
- Be clear on the role of SA and focus on likely significant effects
- Integrate your SA into the wider Local Plan evidence base
- Integrate SA with policy writing
- Consult on the SA alongside your Local Plan consultations
- Integrate other assessments into SA
- Considering reasonable alternatives: The assessment of reasonable alternatives has the potential to take up huge amounts of time and resource, so it’s important to focus and make sure your assessment is useful, thinking about why you are assessing an alternative and whether it is actually reasonable. Remember to focus only on the likely significant effects and that the legal requirement is to assess alternatives to the plan (not every policy or site allocation). Being strict in avoiding the assessment of unrealistic alternatives saves time.
- Identify reasonable alternatives early on
- Ensure alternatives are realistic and viable
- Consider all reasonable alternative options at the same level of detail, regardless of the stage of the process at which they are identified
- Explain why the preferred option has been selected
- Assessing site allocations: Assessing site allocations takes up a significant amount of time and effort in plan preparation. Having a spatial strategy that has been tested through SA before site assessment makes for a simpler, more efficient process. You should think carefully about why you are doing any assessment of sites. For SA, the key considerations will usually be: ‘should we allocate this site?’ and ‘if we allocate this site, is there any specific mitigation that is required to address any significant effects?’ You may not have all the information on impacts at this stage and mitigation measures can link to a subsequent EIA. If no significant effects are likely, there is no need to do a SA of the allocation.
- Integrate site assessment and SA
- Automate aspects of your assessment
- Think carefully about your site assessment criteria
- Monitoring outcomes: Monitoring is a real challenge for most LPAs to resource, but getting it right first off can save significant time and effort at Local Plan review stage and in SA preparation, especially baseline.
- Consider your future Local Plan review and SA when planning for monitoring and preparing your AMR (Annual Monitoring Report)
- Monitor locally specific indicators and make sure they can be measured
