Sustainability Appraisal (SA) practice has evolved considerably in recent years. Perhaps most notably, practitioners increasingly recognise the ability, and indeed need, to make an informed judgement regarding precisely what should be a focus of the appraisal.
Practitioners increasingly focus on the regulatory requirement, as understood from the SEA Directive (2001) / SEA Regulations (2004), which is simply to appraise “the plan and reasonable alternatives”.
With regards to “the plan”, the requirement is clear. There is simply a need to appraise the plan as a whole under the SA framework. There is no requirement to appraise individual policies, although it will usually make sense to examine individual components of the plan (perhaps sections rather than policies) as an informal, interim step, feeding into the formal whole plan appraisal.
With regards to “and reasonable alternatives”, the requirement is not clear. Read at face-value, the requirement seems to be to appraise alternative plans, which is clearly a practical impossibility in the case of today’s local plans. At the other end of the spectrum, a default setting involves examining alternatives for each and every policy area - an approach that invariably proves unhelpful in practice.
A sensible approach, increasingly followed by practitioners, is to discharge the “and reasonable alternatives” requirement by focusing on the matter(s) at the heart of the plan, which for most local plans means the approach to allocating land, i.e. the ‘spatial strategy’.
This approach is in accordance with the only other guidance from the SEA Directive/Regulations, namely that ‘reasonableness’ should be determined taking account of the plan objectives. Whilst rarely explicitly stated by plans, it is understood implicitly that land supply is the central objective.
What does this mean in practice for planners?
Developing, appraising and consulting on spatial strategy alternatives is a valuable exercise for all involved, not least the public; hence SA work is increasingly interesting, engaging and well-regarded.
Whilst every SA Report must include at least one appraisal matrix - namely that which appraises the reasonable alternatives against the SA framework - SA Reports need not be matrix-heavy.
Other traditionally held views of SA practice are also being questioned; notably, the necessity of SA being ‘iterative’. In actual fact, there is a requirement for just two iterative steps:
1) Appraisal of alternatives to inform draft plan preparation; and then
2) Consultation on the SA Report, alongside the draft plan, to inform plan finalisation.
Advice for planning policy team leaders
As well as using the appraisal of spatial strategy alternatives as a tool for effective and efficient consultation and decision-making, also use it as a means of engaging all members of staff within the Policy team, including junior staff. There can otherwise be a tendency for some senior team members to ‘own’ this most central and interesting aspect of the plan, to the exclusion of others.
Advice for junior team members
If you work in a local authority planning policy team, it could help you obtain useful knowledge and experience if you consider getting involved in SA so that you can better understand the spatial strategy. Also, as a career move, you could consider working in SA consultancy as a means of gaining further valuable experience. SA consultancy can in practice equate to: supporting authorities with complex matters of spatial strategy / site selection; communicating matters in a succinct report; and then defending the process at Examination.
Mark Fessey is principal consultant at consultancy AECOM