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Environmental Assessment of Development Plans: Interim Planning Advice

Appendix D

Example of an assessment of a plan's strategy/vision

The consultation draft Midlothian local plan 1998

Introduction

D.1 The general scale and location of new development in Midlothian was set out by policies in the approved Lothian Structure Plan. The Local Plan generally had to conform to the requirements of the Structure Plan and had to identify locations for the provision of:

4,000 dwellings in part of the South East wedge (excluded from this local plan but see Appendix F below);
2,000 dwellings at Gorebridge/Mayfield/Newtongrange;
1,000 dwellings at Bonnyrigg/Lasswade;
1,000 dwellings at Dalkeith;
500 dwellings at Penicuick/Auchendinny;
Up to 40 hectares of industry/business land in the North Midlothian towns;
Up to 30 hectares of industry/business land in part of the South East wedge (excluded from this local plan);

D.2 As these requirements are outwith the direct control of the Local Plan process, any environmental assessment of these provisions would amount to an assessment of the Lothian Structure Plan, rather than the Midlothian Local Plan. Consequently, the environmental assessment of the Local Plan strategy is best focused on the overall policy objectives which are intended to guide the locational strategy which will identify the more precise locations of these major developments in the Local Plan and which set the overall context for the more detailed development and conservation policies in the plan. These overall policy objectives were found at paragraph 1.2.10 of the Local Plan under the title of "Strategy Objectives". Eleven such objectives were listed as follows:

The Strategy Objectives

D.3 The strategy objectives were:

1. Protecting and enhancing Midlothian's countryside and rural environment.
2. Protecting and enhancing the built environment of Midlothian's towns and villages.
3. Protecting and enhancing the high quality landscape of the Green Belt.
4. Attracting economic investment for the benefit of all Midlothian's communities.
5. Reducing traffic congestion in and around Midlothian by measures such as improved public transport and traffic management.
6. Identifying locations for new development which minimise environmental impact and which can be well served by public transport.
7. Identifying new economic and commercial opportunities locally to help reduce the levels of out-commuting from Midlothian.
8. Applying the principles of quality design and energy efficiency to all new developments.
9. Seeking agreements and partnerships with developers and agencies to ensure the delivery of infrastructure and environmental enhancement.
10. Ensuring efficient use is made of existing and new infrastructure.
11. Identifying measures to regenerate rundown urban areas and revitalise rural communities.

Strategic Environmental Assessment Criteria

D.4 For the purposes of the assessment, a set of criteria was developed by the consultants and agreed with the Council. These criteria represent all the key aspects of environmental sustainability objectives, whilst keeping a manageable number of understandable and generally accepted criteria, derived from Government policy objectives. It should be emphasised that in this part of an environmental assessment, only the effects of the overall strategy objectives are being assessed, and only environmental effects that are significant at a strategic level are included. The detailed effects of the policies and the proposals of the local plan are appraised in later stages of the process. The more detailed assessment in these later stages will also highlight whether the objectives of the strategy are actually applied in practice, in the policies and proposals of the plan. This step is to test the likely effects of the strategy objectives themselves, their potential for policy conflict and their reliance on cross compliance with other policy objectives, to provide a framework for the more detailed assessment of policies and proposals. The seven criteria were as follows:

1. Energy Efficiency
Will the strategy objective be likely significantly to encourage greater energy efficiency?

2. Pollution
Will the strategy objective be likely significantly to minimise pollution?

3. Non-Renewable Resources
Will the strategy objective be likely significantly to reduce consumption of non-renewable resources?

4. Renewable Resources
Will the strategy objective be likely significantly to encourage the development and use of renewable resources within the limits of their replenishment?

5. Biodiversity
Will the strategy objective be likely significantly to conserve/enhance biodiversity?

6. Environmental Quality and Distinctiveness
Will the strategy objective be likely significantly to restore, conserve or enhance local environmental quality and distinctiveness?

7. Environmental Equity
Will the strategy objective be likely significantly to contribute towards greater environmental equity?

D.5 The 7 environmental sustainability criteria were applied to the Local Plan's 11 strategy objectives in the matrix presented below, the paragraphs following it summarise the matrix assessment.

Key to matrix symbols

Likelihood of significant beneficial effect(s)
Blank Criterion not relevant, or likelihood of no significant or only neutral effect(s)
X Likelihood of significant adverse effect(s) and/or likelihood of policy divergence with environmental objectives in the Local Plan, or likelihood of conflict with other environmental sustainability aims.
? Uncertain or unpredictable effect(s) and/or some potential for policy divergence with environmental objectives in the Local Plan, or potential for conflict with other environmental sustainability aims. High reliance on cross compliance in the application of the objective.

Summary of the Assessment Conclusions

D.6 In summary, it will be seen that, assuming cross-compliance between all policy objectives, the strategy is likely to have significant environmental benefits and is certainly driving Midlothian towards sustainable development rather than away from it. The only strategic objective likely to generate some adverse environmental effects is that of protecting the green belt. This may appear to be a strange conclusion, bearing in mind the environmental benefits of protecting the countryside around towns and of preventing urban sprawl and the coalescence of settlements. Nevertheless, green belts can have some significant environmental disadvantages by increasing the need to travel, and travel distances, from growth areas beyond the green belt into the main urban centres of a region for employment, education, shopping, leisure, entertainment and other journeys. Green belts can also increase pressure for development on countryside and natural heritage resources beyond the green belt and on urban open spaces. Clearly, the recognised benefits of green belts and the Plan's policies encouraging the use of public transport and the reduction of out-commuting are all relevant and help to offset these potential disadvantages of the green belt.

D.7 Uncertain effects and/or potential for policy divergence with environmental objectives in the Local Plan, or potential for conflict with other environmental sustainability aims arises primarily from the high dependence on cross compliance of objectives 4 and 7. Some green-field development, and therefore some potential for policy conflicts with strategy objective 1, is inevitable. Similarly, pressure to develop brown-field sites in urban areas is high so there is potential for policy conflict with environmental sustainability aims if objectives 4 and 7 are not applied in a way that is consistent with objective 2, which includes protection of both the natural and built environmental qualities of urban areas. Cross compliance is not specifically referred to in these two development objectives in the way that it is in objective 6.

D.8 The best use of infrastructure can have significant environmental benefits, but strategy objectives 9 and 10 have the potential to require developments to provide new infrastructure in the form of road improvements or new roads and to use them to maximum effect, which may generate more private car trips or longer journeys, albeit with reductions in congestion or reduction of environmental impacts of through traffic in existing settlements.

D.9 Consequently, the detailed assessment of the Plan's proposals should concentrate on ensuring cross compliance with the Plan's environmental policies in respect of all the Plan's allocations for development and major infrastructure proposals. If full policy convergence can be established, and overall environmental benefits can be shown to offset environmental disadvantages, then these uncertainties will be removed.

D.10 Finally, it will be seen from the matrix that none of the strategic objectives are likely directly to encourage the development and use of renewable resources, within the limits of their replenishment. This may be regarded as a gap in the overall scope of the Local Plan's strategy.

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