Draft Sustainability Appraisal Scoping Report

Ended on the 15th January 2010
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2 Approach to the SA

2.1 Introduction

2.1.1 This chapter sets out the approach taken in preparing the Scoping Report including the proposed framework around which the appraisal will be organised.

2.2 SA process

2.2.1 SA is based on a five-stage approach – see Figure 1.

Figure 1: Five stage approach to SA

Figure 1

Stage A – Framework and evidence base

2.2.2 Stage A in the SA process involves developing the framework for undertaking the appraisal – in this case the identification of a series of spatial areas and topics on which the appraisal will focus – together with an evidence base to inform the appraisal. The framework and evidence base are presented in a Scoping Report – this report – for consultation with stakeholders including English Heritage, the Environment Agency and Natural England and the public. The evidence base presented in the Scoping Report should include an analysis of the relevant policy context; a description of the current baseline situation; an analysis of how the current situation might evolve in the absence of the plan; and the identification of any problems which the plan may need to address.

Stage B – Appraisal

2.2.3 Stage B in the SA process involves undertaking the appraisal itself. This involves identifying and evaluating the impacts of the different options to the plan makers as well as the preferred options / policies which together comprise the plan. The appraisal is organised around the framework identified in Stage A and informed by the evidence base assembled at Stage A. Mitigation measures for alleviating adverse impacts are also proposed at this stage together with potential indicators for monitoring the plan’s implementation. Mitigation measures are generally in the form of recommendations for changes to the plan in order to improve its sustainability performance. Crucially, the appraisal should be undertaken in parallel with development of the plan and the appraisal findings should be fed into the emerging plan. In practice, this means undertaking several rounds – or iterations – of appraisal at different stages in the plan-making process.

Stage C – Reporting

2.2.4 Stage C in the SA process involves documenting the appraisal findings and preparing an SA Report (this incorporates the material required for inclusion in the ‘Environmental Report’ under the ‘SEA Directive’). The full SA Report should be published for consultation alongside the ‘pre-submission’ version of the DPD in question; however, SA reports focusing on the emerging plan may be published earlier in the plan-making process (e.g. at the ‘issues and options’ stage).

Stage D – Consultation

2.2.5 Stage D in the SA process involves consulting on the ‘pre-submission’ version of the plan and the accompanying SA Report; however, as stated above, SA reports can be prepared to accompany consultation on earlier versions of the plan.

Stage E – Monitoring

2.2.6 Stage E in the SA process involves monitoring the adopted plan including its sustainability impacts; this is done through the LDF Annual Monitoring Report (AMR).

2.3 SA methodology

2.3.1 This Scoping Report has been structured around a series of spatial areas within Harlow district as well as a series of topics. Together, these spatial areas and topics provide the proposed framework for undertaking the SA.

2.3.2 For each spatial area and topic identified, we have asked a series of questions in order to complete the Scoping Report:

  • What’s the policy context?
  • What are the key sustainability objectives that we need to consider?
  • What’s the situation now (including any identified problems)?
  • What will be the situation without the plan2?
  • What issues should be a particular focus for the appraisal?

2.3.3 For future rounds of appraisal itself, we will also ask the following questions:

  • What will be the situation with the plan?
  • How can we mitigate / enhance effects (Scott Wilson’s recommendations to the Council)?
  • How can we best monitor the plan’s impacts?

2.3.4 These questions correspond to the key requirements of the SEA Directive, therefore clearly demonstrating compliance with the Directive’s requirements – see Table 1.

Table 1: Meeting the requirements of the SEA Directive

Key questions

Corresponding requirement of the SEA Directive (the ‘environmental report’ must include…)

What’s the policy context?

“an outline of the contents, main objectives of the plan or programme and relationship with other relevant plans and programmes" (Annex I(a))

What are the key sustainability objectives that we need to consider?

the environmental protection objectives, established at international, Community or Member State 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" (Annex I(e))

What’s the situation now (including any identified problems)?

the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme" (Annex 1(b)) “the environmental characteristics of areas likely to be significantly affected" (Annex I(c)) “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" [NB problems relating to European sites are addressed through Habitats Regulations Assessment] (Annex I(d))

What will be the situation without the plan?

“the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme" (Annex I(b))

What will be the situation with the plan?

the likely significant effects (1) 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 [our emphasis] (1) These effects should include secondary, cumulative, synergistic, short, medium and long-term permanent and temporary, positive and negative effects" (Annex I(f))

How can we mitigate / enhance effects (Scott Wilson’s recommendations to the Council)?

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" (Annex I(g))

How can we best monitor the plan’s impacts?

a description of the measures envisaged concerning monitoring…" (Annex I(i))

2.3.5 In relation to the question ‘What are the key sustainability objectives that we need to consider?’, we have focused in particular on the objectives set out in the Integrated Regional Sustainability Framework for the East of England – see Table 2.

Table 2: Integrated Regional Sustainability Framework objectives

East of England Integrated Regional Sustainability Framework Objectives


Promote sustainable growth within environmental limits


Reduce poverty and inequality and promote social inclusion


Reduce greenhouse gas emissions


Adapt to the impacts of climate change


Promote employment, learning, skills and innovation


Increase resource efficiency and reduce resource use and waste


Conserve, restore and enhance the region’s natural and built environment


Move goods and people sustainably


Meet the needs of the changing regional demographic


Provide decent, affordable and safe homes for all

(3) 2.4 Proposed SA framework

2.4.1 In identifying the spatial areas and topics that will provide the basis for the appraisal, we have considered:

  • The topics addressed in the SA of the East of England Plan3
  • The topics suggested in the SEA Directive (see Table 1 above)
  • The likely significant effects of the Core Strategy
  • The views of the Council

2.4.2 As shown in Figure 2 the proposed spatial areas are:

  • Town Centre
  • Eastern growth area
  • Neighbourhoods
  • Industrial and employment areas

Figure 2: Harlow District Spatial Function Areas

Figure 2

2.4.3 The proposed topics are:

  • Air quality
  • Biodiversity and green infrastructure
  • Climate change (mitigation and adaptation)
  • Community and wellbeing
  • Economy and employment
  • Historic environment
  • Housing
  • Land
  • Landscape
  • Transport
  • Water
  • European sites

2.5 Integration of SA with other assessment and proofing exercises

2.5.1 The previous section sets out our approach to undertaking the SA. This section provides the methodology for the integration of SA with other assessment and proofing exercises (which should, as appropriate, include Equality Impact Assessment (EqIA), Health Impact Assessment and Rural Proofing). This section will also describe how this integrated approach will be applied at the Scoping and Assessment stages, as well as describing how the Scoping and SA Reports will be structured.

Habitats Regulations Assessment / Appropriate Assessment (HRA / AA)

2.5.2 Our methodology is consistent with the requirements of the Planning and Compulsory Purchase Act 2004, the European Directive 2001/42/EC (the “SEA Directive") and the Conservation (Natural Habitats, &c) (Amendment) (England and Wales) Regulations 2006 (Habitats Regulations). In practice there will be little integration between the SA and HRA / AA processes beyond the evidence gathering stage. In this Scoping Report we have included a European Sites Topic Paper that provides the methodology, evidence base and scope for the HRA / AA. See Chapter 18: European Sites.

Equality Impact Assessment (EqIA) and Health Impact Assessment (HIA)

2.5.3 Methodologies promoted for stand-alone processes of EqIA and HIA tend to be closely comparable to the process set out in government guidance on SA. As a result, these assessment exercises can be relatively easily incorporated into the SA process.

2.5.4 The new PPS12 states that: “Where authorities are required by law or encouraged by government policy to undertake assessments of their plans, such assessments should feed into and be summarised in the sustainability appraisal".

2.5.5 Although SA can consider the full range of topics, the premise for integrating topic specific assessment exercises is to ensure that some topics receive the attention and prominence in the appraisal process that they warrant (given the plan context) and are given an appropriate level of consideration.

2.5.6 We propose that incorporation of the other assessment exercises, where appropriate, in the SA is through:

  • The focus on collecting topic specific evidence, for example, the incorporation of EqIA and HIA evidence base in a Community and Wellbeing Topic Paper in this Scoping Report. See Boxes 1 and 2.

Box 1: Equality Impact Assessment (EqIA)

EqIA aims to anticipate the effects of a plan on different groups within the community (equality target groups). A key driver for EqIA is the Equality Act 2006, which places statutory obligations on public sector organisations to ensure that all equality groups are not discriminated against within public sector service delivery and employment. The forthcoming Single Equality Bill 2009, a new streamlined public sector equality duty, is due to replace existing race, disability and gender equality duties and will be extended to cover all strands of discrimination, including measures to tackle socio-economic disadvantage.

Guidance on EqIA suggests a six-stage process of screening, scoping / defining, information gathering, making a judgement, action planning, and publication and review4. This very closely matches the SA process, but focuses on the needs of, and impacts on, specific groups and the differential nature and proportionality of impacts. This very closely matches the SA process, but focuses on the needs of, and impacts on, specific groups and the differential nature and proportionality of impacts.

There are eight identified equality target groups, or equality strands, that are central to the equality agenda:

  • race
  • gender
  • disability
  • sexual orientation
  • gender reassignmen
  • tage
  • religion and or belief
  • socio-economic disadvantage.

We will follow the same process for the EqIA as we follow for the SA, i.e. we will prepare a topic paper ‘Community and Well-being’ that will include equality and diversity for inclusion in the Scoping Report and later ask how the options and preferred options / policies will impact on equality issues. The EqIA component in the topic paper in the Scoping Report will be organised around the eight equality target groups (and any others identified in discussion with the Council). The Council may decide to involve consultees and groups associated with EqIA in the Scoping Report consultation.

Box 2: Health Impact Assessment (HIA)

Health Impact Assessment (HIA) is an approach that ensures decision making at all levels considers the potential impacts of decisions on health and health inequalities. It identifies actions that can enhance positive effects and reduce or eliminate negative effects. HIA is a relatively new tool, and although there is no single agreed national approach or methodology, the value of HIA is increasingly being recognised, both nationally and internationally5.

Basic sequential steps involved in carrying out HIA can include:

  • Screening
  • Scoping
  • Appraisal of the potential health effects/impacts
  • Decision-making
  • Monitoring and evaluation

HIA has been successfully integrated into the statutory process of SA and SEA undertaken for regional, sub-regional and local planning policy. In these instances the health input into policies has been strengthened.

2 Note that the situation without the plan equates to the current plan for the District together with other future changes and trends.

3 Scott Wilson and Levett-Therivel Sustainability Consultants (2009). Regional Spatial Strategy for the South East: Sustainability Appraisal and Habitats Regulations Assessment/ Appropriate Assessment of the Secretary of State’s Final Revisions [online] available at:
http://www.gos.gov.uk/497648/docs/171301/815607/fSA_and_HRA_Assessment.pdf (accessed 21 July 2009).

4 Improvement and Development Agency (2008). The EqIA process: six-step guide [online] available at:
http://www.idea.gov.uk/idk/core/page.do?pageId=8017502 (accessed 16 September 2009).

5 London Health Commission (no date). Health Impact Assessment [online] available at:
http://www.london.gov.uk/lhc/hia/ (accessed 4 June 2009).

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