Sunderland City Council - Unitary Development Plan


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Chapter 17 - Impact on the Environment

17.1	In 1992, the adoption of Local Agenda 21 at the Rio Earth Summit emphasised the need for Local Government to become more involved as a custodian of the environment and to assist with promoting ‘sustainable development’. The Development Plans Regulations require that regard is given to environmental considerations and PPG12 (para. 5.52) suggests that an ‘Environmental Appraisal’ should be undertaken which ensures that the objectives of policy are clearly laid out, and the trade-offs between options assessed. This appraisal process helps identify, quantify, weigh-up and report on environmental and other costs and benefits of the UDP's proposed measures.
17.2	The process of appraisal was clarified by DoE guidance, ‘Environmental Appraisal of Development Plans - A Good Practice Guide’, published in 1993, after the UDP Draft for Consultation. Its methodology was used as a basis for appraising the Draft Plan and the results assisted in formulating amendments for inclusion in the Deposit version. Appraisal was focused on a comparison of
	the strategic objectives with a series of environmental criteria; checking that the scope of the Plan adequately encompasses the wide range of national Government planning advice; and an appraisal of the environmental impact of key policies.
17.3	As the objectives have remained generally consistent through the different stages of the Plan, apart from the addition of a new objective relating the development of the University, the original appraisal, as printed in Chapter 16 of the Deposit Version remains relevant. It is not considered necessary to reproduce the whole of that assessment in this final version of the Plan, but for the sake of continuity, the main conclusions of the appraisal are reprinted below. This chapter then goes on to highlight the environmental impact made by the modifications to the Plan arising out of the public consultations, the UDP Inquiry and the Inspector’s report.

	APPRAISAL OF DRAFT OBJECTIVES AND STRATEGY

	Draft objectives appraisal
17.4	Overall the objectives were consistent with each other (where they had a relationship), with only limited areas of possible conflict. The greatest level of inconsistency lay between objectives for urban regeneration and the environmental criteria. Certain objectives in the Draft Plan were not explicitly related to the need to minimise the creation of demand for new travel and the need for development of new land. The new housing objective of the Draft Plan was modified to emphasise the need to respect environmental constraints and to relate to existing and proposed infrastructure. The objective to build on the City's advanced manufacturing role and encourage the continued growth of local business could be considered to conflict with the need to reduce trip generation. However this aspect is minimised by ensuring that employment generating sites are well related to residential localities. Any adverse short-term impact could in the longer term bring about many environmental benefits through the alleviation of poverty by increased employment. Greater emphasis on the re-use of derelict and unused land was sought in the Deposit Plan to minimise the pressures on ‘greenfield’ sites. In relation to leisure objectives, care is needed in developing the recreational potential of the City, particularly its countryside, to minimise greater private vehicle use or damage to valued landscapes and wildlife habitats. The objective of protecting open breaks between settlements is not beneficial in terms of reducing travel demand, but helps to concentrate development within existing urban areas, thus enabling public transport and built development to relate to existing infrastructure and maintaining the local environmental quality and urban ‘liveability’.

	Compatibility with environmental objectives of national guidance
17.5	The next stage involved establishing whether the Plan adequately covered important advice related to environmental issues contained in Planning Policy Guidance (PPG's). Over 130 individual pieces of environmentally related advice were identified in PPG's, draft PPG's and MPG's (Minerals Planning Guidance). Several guidance notes have been published or drafted since finalising the Draft Plan in 1992. These were taken into account in the Deposit Plan policies and subsequent changes have been reflected at each of the succeeding stages.

	Appraisal of policies
17.6	Key environmental and development policies of the Draft UDP were amended in the Deposit version to give greater emphasis to the protection of the environment. Even where reference was not explicitly made, it was intended that all development policies should operate in the context of the environmental policies of the Plan contained in the chapters on Environmental Framework (now Environmental Protection), Urban Character and Heritage (now Built Environment), Countryside and Nature Conservation and Minerals and Waste Disposal; Transportation policies also considered the need to reduce global pollution. (See revisions to chapter layout in para. 17.12).
17.7	The main additions to the Draft policies included in the Deposit version covered:-
	defining the coastal zone and protecting it from inappropriate development (EN10); criteria for judging proposals for energy production, and the development of schemes using renewable energy sources, in the interests of reducing global energy needs from fossil fuels (R4, EN2, EN3, EN4); protecting urban amenity and ‘liveability’ from the effects of noisy developments (EN5-7); aiming to ensure built development is not carried out on unstable or contaminated land (EN14); giving wildlife habitats and landscapes increased emphasis by protecting the countryside for its own sake (CN1); giving increased protection and opportunities for environmental enhancement of the urban fringe and safeguarding from development land between the Green Belt and the urban edge (Formerly CN6 but subsequently removed from the plan as it was considered to have an adverse impact (See para. 17.11)); considering the impact of minerals extraction on natural resources and local environmental quality by using an expanded list of fifteen criteria as well as clarifying statements of the wider national/regional context to be applied in considering the need for such extraction (M2, M8); introducing a new policy to minimise the regional and local need for extraction of aggregates by emphasising that major projects should seek to use recycled and secondary aggregates where possible (M4); increasing priority for road schemes and development which can assist in increasing the use of public transport to help contain the growth of private vehicular traffic (T1); additional consideration of the impact of new roads on sites of natural and archaeological interest, in order to protect biodiversity and cultural heritage (T13); more restraint on car parking where public transport is a feasible option, including provision for park-and-ride, with the aim of reducing commuting by car, assisting the local environment by reducing congestion, and overall helping to reduce global pollution (T21, T23).

	Conclusions of original appraisal
17.8	It was concluded that, in general, the strategy, objectives and policies of the Draft UDP assisted towards the achievement of 'sustainable development'. For example, the proposed Green Belt was drawn to allow new employment opportunities and community facilities to be well related to the workforce and residential areas they serve. It still protected much of Sunderland's rural area. Criteria were included in many policies to protect the urban heritage, rural areas, nature conservation sites and ecosystems.
17.9	The Environmental Appraisal also showed that the Draft UDP did not adequately cover certain points raised in recent environmental guidance. The majority were taken into account by the inclusion of amendments to the Deposit UDP which gave increased emphasis to:-
	the concept of sustainability in general, incorporated by the rewording of strategy/objectives and policy (R1 in particular); housing choice in relation to environmental constraints (by rewording of housing objective and primary policy); maximising the use of derelict land and vacant land; requirements for renewable energy technologies; enhanced policies to control pollution of water, air and particularly noise generating development; greater emphasis on public transport use and the development of the Metro extension.
17.10	Policies within the Deposit UDP sought to minimise the impact of future development on the environment. Even though there were continued pressures for growth and new building it was considered that the Plan struck a satisfactory balance between these pressures and made the maximum use of existing and proposed infrastructure whilst respecting the needs of the environment.

	APPRAISAL OF SUBSEQUENT CHANGES

17.11	Arising from representations made during the Deposit period, and their subsequent consideration, both at the Proposed Changes stage and through the Public Inquiry, further ways in which the Plan could emphasise its environmental objectives became apparent. The policy which provided for a safeguarded area between the urban areas and the green belt was deleted as it was considered that it identified land for future development rather than retaining it to allow options for its future to be determined in the light of circumstances which had not yet arisen. Furthermore, a number of policies were changed at the Modifications stage. An assessment of the environmental implications of the changes to the strategic policies was made. This indicated that out of a total of 86 policies, 23 were not changed, and in 28 cases the changes did not have any environmental implications. Of the remainder, 12 changes were assessed as having a positive environmental effect, 19 had a minor positive effect and only 4 changes were considered to have a minor detrimental impact. It can therefore be seen that the changes continued the trend of improving the environmental credibility of the Plan.
17.12	Another alteration has been made which highlights the increased emphasis now being placed on environmental considerations. Whilst not in itself changing any of the policies, a substantial section of the former Environmental Framework chapter has been relocated near the front of Part II of the Plan and renamed as the Resources for the Future chapter. This has been done to emphasise the significance of the issues covered and to demonstrate how they underpin the policies found in the subsequent chapters. Most of the remaining section of the Environmental Framework chapter now forms another chapter entitled Environmental Protection, which identifies more clearly its focus. The former Urban Character and Heritage chapter now has a broader remit under the title of Built Environment.

	CONCLUSION

17.13	The changes to the strategic policies of the Plan that have been introduced since the Deposit version was published, together with the revised chapter format, illustrate the Council’s continuing and growing commitment to measures which accord with the principles of Local Agenda 21 and with the Council’s corporate Environmental Strategy. The effect of the Plan’s policies, however, can only be judged in the light of the benefits which they actually achieve. It is therefore intended that monitoring of the Plan should include provision for the formal appraisal of the environmental impacts which can be attributed to its policies.




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