Strategic Environmental Assessment and Sustainability Appraisal (includes Non-Technical Summary)

2. Methodology

   1. Stage A: Context, Objectives, Baseline and Scope
      1. The first part of a SA is the Scoping Report, which:

• Reviews other relevant programmes, plans and strategies that have an influence on sustainability (Task A1);
• Details the existing baseline (Task A2);
• Identifies key sustainability issues and opportunities of relevance to the plan (Task A3); and
• Sets out a SA Framework for assessing policy options and the overall effect of the plan (Task A4).
  2. The Scoping Report was prepared in March 2017 by the Council. It was then consulted on with the three statutory consultees of Natural England, the Environment Agency and Historic England (Task A5). The Scoping Report was finalised in light of responses received during the six-week consultation period.

A1: Identifying other relevant policies, plans and programmes and SA objectives

2.1.3 The SEA Directive requires:

"An outline of the contents, main objectives of the plan or programme and relationship with other relevant plans and programmes" to determine "the environmental protection objectives, established at international (European) 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" (Annex 1 (a), (e)).

2.1.4 It is therefore an essential requirement, as well as a necessary component of preparing a robust and accurate appraisal, to understand the policy context in which the SA is being prepared. A comprehensive review of other plans and programmes at a national, regional, county and local level was undertaken to identify implications for future Local Plan policies and the SA Objectives.

A2: Collecting baseline information

2.1.5 Baseline information refers to the existing economic, social and environmental characteristics of an area that may be affected by the LPR. It informs the development of a set of objectives, based on the data gathered, to inform the SA and therefore, plan preparation. Among the important decisions considered during the Scoping stage was with regards to the data, quantity of data and how should it be used in order to carry out SA. The Council compiled social, economic and baseline data for the Borough in order to provide the evidence base from which sustainability issues and opportunities could be identified (see Appendix B).

A3: Identifying sustainability issues and opportunities

2.1.6 The review of plans and programmes and the gathering of baseline data facilitates the identification of key sustainability issues and opportunities in the Borough. The key sustainability issues and opportunities were derived jointly between Ipswich and Suffolk Coastal as a number of these issues and opportunities are common across the two authorities. Their identification has informed the development of the objectives outlined in the SA Framework.

A4: Developing the SA Framework

2.1.7 The SA Framework presents 19 objectives relevant to the LPR and the scope of the SA across fifteen topic areas. It is important that the SA Objectives that are to be used are up to date, relevant for the district and can also provide a consistent approach between strategic level policies and site/area specific policies as part of the Local Plan Review. Baseline information is fundamentally linked to the SA Framework and the objectives act as a basis against which sites can be assessed. indicators are used to assess progress towards the objectives being achieved. The SA Framework enables the Council to consider the impacts and alternatives of plans, programmes and policies.

A5: Consulting on the scope of SA

2.1.8 The Scoping Report, including the various components satisfying Tasks A1- A4, was consulted on between 18^th August – 30^th October 2017. The updated Scoping Report was prepared in light of the comments received during consultation and was published in February 2018^[3].

2.2 Stage B: Developing and Defining Options

B1: Testing the plan objectives against the SA objectives

2.3 Assessment Requirements

2.3.1 Each proposal in the LPR, as well as their reasonable alternatives, will be assessed for their likely impacts against the revised SA Framework. This includes:

• Growth scenarios;
• Spatial options;
• Policies; and
• Sites.
  2. During the assessment of each proposal, it is a requirement of SA to consider the implications for the economic, social and environmental spheres of sustainability. In order to satisfy the SEA Directive and SEA Regulations, there are several factors that require consideration during the assessment process.

4. Strategic Options Assessment Method
   1. The phrase 'strategic options' is considered to include the various options for the quanta of growth and potential distribution strategies that were considered by the Council. Each strategic option was assessed for its likely impacts on each SA Objective. Given the high-level nature of these options, the assessments involve a lot of uncertainty and assumptions are made. A precautionary approach is adopted to ensure potential adverse impacts can be highlighted and avoided at an early stage. A score for each strategic option, as per Table 2-1, is provided for each SA Objective.

2.5 Sites and Policies Assessment Method

2.5.1 The assessment of policies and sites lends itself to a more quantified process. An individual assessment is provided in each case with the likely impacts on each SA Objective discussed. For site assessments, each site has been assessed against a wide range of criteria that align with the Objectives. Based on the outcomes of this, a score is provided for each site against each Objective, as per Table 2-1.

Table 2-1: SA scoring for sites assessments

++	Major positive effect (significant)
+	Minor positive effect
0	Neutral effect
?	Uncertain effect
-	Minor adverse effect
--	Major adverse effect (significant)

B2: Developing the plan options

2.5.2 It is important to note that SA is not the only evidence base informing the Council's decision-making process. During the SA, each strategic option, site and policy has been assessed for their likely sustainability effects and the results of this process are provided to the Council to help inform their decision-making process, alongside various other evidence documents, during the preparation of the Plan. In each case, the SA provides recommendations for avoiding or mitigating potential adverse impacts of options being considered in the Plan, such as by rewording policies or including requirements for potential developers. Overall, during the SA process, the SA plays an essential role in helping the Council decide how much and what type of development to allocate where and how to sustainably manage this development.

B3: Predicting the effects of the plan, including options

2.5.3 The assessment of growth options and spatial scenarios is inherently a more qualitative procedure than the assessment of policies and sites. Chapters 4 and 5 present the outcome of the assessment of growth options and spatial options, with the likely impacts of each separated into social, environmental and economic sections. These assessments involve a large degree of uncertainty, in large part due to the length of time the LPR covers (18 years), and assumptions have to be made to reach meaningful conclusions. Assessments have been provided, and quantified where feasible, based on the best-available evidence with consideration given to the baseline, key issues in Ipswich as well as local, national and international trends (such as the reducing carbon footprint per capita).

2.5.4 Firstly, careful consideration is given to the significance of effect, as based on:

1. the probability, duration, frequency and reversibility of the effects;
2. the cumulative nature of the effects;
3. the transboundary nature of the effects;
4. the risks to human health or the environment (for example, due to accidents);
5. the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected);
6. the value and vulnerability of the area likely to be affected due to:
7. special natural characteristics or cultural heritage;
   1. exceeded environmental quality standards or limit values; or
   2. intensive land-use; and
8. the effects on areas or landscapes which have a recognised national, Community or international protection status.

B4: Evaluating the effects of the plan, including options

2.5.5 Careful consideration is also given to the uncertainty of effect and the likelihood of it occurring. Site-level baseline data used in this assessment is also highly changeable – for example, any given community facility can close down or move within a period of months, and thus an assessment which considers a site to have good access to this facility pre-development, may not do so by the time construction begins, even if this is only within a few years. These circumstances are impossible to predict and are an inherent part of the SA and indeed the planning process. The planning system is generally robust enough to deal with such changes by re-assessing the needs of sites/communities at the time applications are made. Uncertainties are dealt with in the SA process by a adopting a precautionary approach, wherein the worst-case scenario is assumed (unless reliable evidence suggests otherwise).

2.5.6 The permanence and timescale of effects are also determined. This is generally presented in the form of short-term, medium-term, long-term or permanent. In many cases, effects of LPR proposals are likely to be multiple terms (e.g. arise in the short-term and reside in the long-term).

2.5.7 The SEA Directive also requires the consideration of cumulative, synergistic and secondary effects, which we define as:

• Secondary effects are effects that are not a direct result but occur away from the original effect or as a result of a complex pathway;
• Cumulative effects arise, for instance, where several developments each have insignificant effects but together have a significant effect, or where several individual effects have a combined effect; and
• Synergistic effects interact to produce a total effect greater than the sum of the individual effects, so that the nature of the final impact is different to the nature of the individual impacts.
  8. The appraisals of options in the appendices of this document account for both direct and secondary effects. Chapter 8 in this report provides an appraisal of the cumulative and synergistic effects of options.

B5: Consider ways of mitigating adverse effects and maximising beneficial effects

2.5.9 Where appropriate, measures have been recommended to help mitigate adverse effects or to help enhance the extent to which likely effects are positive.

B6: Proposing measures to monitor the significant effects of the plan's implementation

2.5.10 As stated, uncertainty and assumptions are inherent features of the SA process. A precautionary approach is necessitated in order to identify potential significant effects at an early stage, either so adverse effects can be avoided or mitigated, or so positive effects can be maximised. The SA also proposes a monitoring framework which, if followed, would enable the Council to ensure that the LPR is having the impacts identified in the SA and that avoidance or mitigation measures are working effectively – if not, they can be amended as necessary.

2.6 Stage C: Prepare the SA Report

2.6.1 During Stage C of the SA process, and Environmental Report will be prepared to accompany the publication version of the LPR. At this stage, the SA report will satisfy all requirements of an 'Environmental Report' as per Annex 1 of the SEA Directive, including:

1. an outline of the contents, main objectives of the plan or programme and relationship with other relevant plans and programmes;
2. the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme;
3. the environmental characteristics of areas likely to be significantly affected;
4. 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;
5. 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;
6. the likely significant effects (including secondary, cumulative, synergistic, short, medium and long-term permanent and temporary, positive and negative 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;
7. 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;
8. 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;
9. a description of the measures envisaged concerning monitoring in accordance with Article 10;
10. a non-technical summary of the information provided under the above headings.
    

^[3] LPR evidence library available online at: https://www.ipswich.gov.uk/content/new-evidence-base-documents-ipswich-local-plan-review-2036