City Plan Part Two Sustainability Appraisal/ Strategic Environmental Assessment Post Adoption Statement

1.1 Brighton & Hove City Council adopted the City Plan Part Two (CPP2) on 20 October 2022. This followed the Examination in Public in November 2021 and one round of modifications in 2022 that the Planning Inspector directed the city council to make in order to ensure the CPP2 was sound.  The Planning Inspector’s Report confirming the CPP2 was sound, subject to modifications, was received on 19 July 2022.  

1.2 In preparing the CPP2, the Council undertook a parallel process of Strategic Environmental Assessment and Sustainability Appraisal. Strategic Environmental Assessment (SEA) is required by the Environmental Assessment of Plans and Programmes Regulations 2004, amended in 2020 (the ‘SEA Regulations’). Sustainability Appraisal (SA) is required by the Planning and Compulsory Purchase Act (2004) in order to ensure that sustainability considerations are integrated into the plan making process. As with SEA, SA is concerned with the environmental impacts of implementing development plans, but it also carries a wider remit that includes social and economic considerations.  

1.3 Good practice guidance (National Planning Practice Guidance) advises that the requirements for both SEA and SA can be met through a single appraisal process. The Council has applied this approach in appraising the Brighton & Hove CPP2. Therefore, throughout the remainder of this statement, reference to Sustainability Appraisal implies both SA and SEA. 

1.4 This Sustainability Appraisal Post Adoption Statement has been prepared in accordance with Regulation 16 (4) of the SEA Regulations. It describes how environmental considerations have been integrated into the plan, how the environmental report has been taken into account, how consultation responses have been taken into account, and summarises the reasons the plan was chosen, in light of other reasonable alternatives considered. The statement also sets out the measures that will be used to monitor the effects of the CPP2.  

1.5 As the SA and SEA process have been integrated throughout the preparation of the plan process, this statement addresses not only environmental aspects but also the wider sustainability (social and economic) aspects.  

1.6 The remainder of this statement is set out by headings which reflect the requirements of the SEA Regulations.

2.1 City Plan Part 1 (CPP1), adopted in 2016, sets out the city’s planning framework up to 2030.  It provides the overall strategic and spatial vision for the future and plays an important role in ensuring other citywide plans and strategies achieve their objectives.  The main role of CPP2 is to support the implementation and delivery of CPP1.  Part Two builds upon and complements the Part One Plan and will ensure the delivery of high quality, sustainable place making development by setting out an up-to-date suite of detailed development management policies and additional site allocations.   

2.2 CPP2 has undergone various stages of preparation. These stages are described in more detail in section 3.  At each stage, the City Plan objectives, options and/or policies have been appraised against the Sustainability Appraisal Framework which has ensured environmental, economic and social considerations have been integrated into the plan.  

2.3 The first stage of the Sustainability Appraisal process was the production of the SA Scoping Report (2016) at scoping stage. Within this report, information on relevant plans, strategies and programmes, as well as baseline data covering social, economic and environmental issues was collated in order to identify key sustainability issues for the city. These issues were used to inform development of a series of sustainability appraisal objectives that formed the SA Framework against which the emerging plan was assessed. The SA Framework was initially set out in the Scoping Report and then was revised following consultation comments. The amended SA Framework was then applied throughout the subsequent plan preparation stages which included the draft, proposed submission and main modifications stages.   

2.4 The Sustainability Appraisal Objectives included environmental, social and economic objectives, ensuring a broad scope for sustainability considerations.  The SA Objectives are listed as follows: 

1. To protect, conserve and achieve a net gain in biodiversity 

2. To protect and improve open space and green infrastructure and improve sustainable access to it 

3. To protect, conserve and enhance the South Downs National Park and its setting, and improve sustainable access to it 

4. To protect and conserve the city’s historic built environment, heritage assets and their settings, townscapes, buildings and archaeological sites 

5. To reduce the need to travel by car, encourage travel by sustainable forms of transport and improve travel choice 

6. To improve air and noise quality 

7. To improve water quality (ecological, chemical and quantity status) 

8. To reduce the risk from all sources of flooding to and from development 

9. To reduce emissions of greenhouse gases that cause climate change 

10. To increase the city’s resilience and ability to adapt to climate change 

11. To improve soil quality 

12. To minimise and sustainably manage waste 

13. To make the best use of land available 

14. To provide housing, including affordable housing, to contribute towards meeting local needs 

15. To improve the range, quality and accessibility of services and facilities. 

16. To improve health and well-being, and reduce inequalities in health 

17. To improve community safety, and reduce crime and fear of crime 

18. To increase equality and social inclusion 

19. To contribute towards the growth of a sustainable and diverse economy, increase employment opportunities and meet local employment needs.   

2.5 The SA Framework has been used as a basis to appraise CPP2 through its various iterations.  It has appraised the strategic objectives (set out in CPP1), options and policies and has enabled the identification of positive, negative and cumulative effects. The appraisals, using the SA Framework as a tool, have ensured the integration of sustainability considerations into CPP2.   

3.1 Production of CPP2 has been carried out as an iterative process, with the plan’s options for policies being subject to a comparative assessment and policies being further refined at various stages. 

3.2 The following table shows the various stages of the CPP2 that have been undertaken.  At each stage, there has been an equivalent stage of sustainability appraisal. At each stage, where appropriate, CPP2 was developed and modified to take into consideration the Sustainability Appraisal findings. 

Stages of plan making and associated stage of SA 

June 2016 

Plan-making stage 

CPP2 Scoping Paper 

SA stage 

SA Scoping Report 

June 2018 

Plan-making stage 

Draft City Plan Part Two 

Draft City Plan Part Two SA stage 

SA of Draft City Plan Part Two 

April 2020 

Plan-making stage 

Proposed Submission City Plan Part Two  

SA stage 

SA of Proposed Submission City Plan Part Two 

February 2022 

Plan-making stage 

City Plan Part 2 Main Modifications  

SA stage 

SA Addendum of Proposed Modifications to Proposed Submission City Plan Part Two 

3.3 The following paragraphs briefly summarise how the SA findings were taken into account. The summary is set out by plan preparation stage.  

Scoping Stage 

3.4 At this stage the SA Scoping Report was produced. The Scoping Report helped to identify the social, economic and environmental issues that needed to be addressed in CPP2 and helped to identify which other plans and programmes had a bearing on CPP2.  These issues fed into the CPP2 Scoping Paper.      

Draft CPP2 

3.5 At this stage, the SA assessed Strategic Objectives of CPP1, appraised alternative options for each policy to identify the most sustainable approach; undertook site assessments; and appraised each draft policy to identify whether impacts were likely to be beneficial or adverse. The SA process resulted in the following: 

• Amendments to text of 19 policies 

Proposed Submission City Plan 

3.6 At this stage, the SA re-assessed the Strategic Objectives, undertook revised site assessments including for omission sites; and re-assessed all the policies to ensure any changes had been reconsidered through the SA process. The SA process resulted in the following: 

• Amendments to text of 6 policies 

Proposed Modifications 

3.7 At this stage, the SA undertook a screening exercise of all the proposed main and additional modifications and re-assessed 9 policies which were found to have changed significantly since the Proposed Submission version due to Proposed Main Modifications.  As the Proposed Main Modifications were to ensure the Plan was legally compliant and sound, the role of the SA at this stage was purely to identify the sustainability implications of the Proposed Modifications. The SA process did not influence or make any further amendments at this stage.   

3.8 To summarise, the SA has been fully integrated into the process of plan production.  The SA has highlighted key issues and ensured they have been taken into account.  It has enabled a comparative assessment of options to be undertaken, helping to identify the most sustainable option, has made recommendations to enhance policies and has suggested mitigation to improve policy outcomes.   

4.1  There have been four stages of plan preparation, each of which has undergone widespread public and stakeholder consultation.  Consultation always included CPP2 including modifications to CPP2, the Sustainability Appraisal report and any other supporting documents relevant to each stage.

4.2 Consultation was always in accordance with the relevant Town & Country Planning Regulations and the council’s adopted Statement of Community Involvement.  Specifically, in accordance with Regulation 13 of the SEA Regulations, consultation always included the three statutory environmental bodies; Natural England, the Environment Agency and Historic England. 

4.3 Following each stage of consultation, a Consultation Statement was produced detailing what consultation was undertaken, where and with whom, and providing details of all representations received. In all stages of plan production, including Main Modifications stage, an officer response was provided for each of the main issues arising, showing how the representations were taken into account. 

4.4 In addition to the Consultation Statements, each SA report prior to the examination included details of the representations received on the SA at the previous stage of plan preparation and included a response to show how the comments were taken into account.  The following summaries indicate how some of the representations were taken into account, set out by the stage of plan preparation.

Issues and Options stage (Scoping Report)

4.5 The sections were amended as follows:

• Additional Plans, Programmes and Strategies included
• Baseline information section updated
• Sustainability issues section updated  
• Sustainability Appraisal Objectives revised
• Decision Making Criteria revised and added to SA Framework

Draft CPP2 stage

4.6       The sections were amended as follows:

• Site assessments updated
• Site assessment process clarified further
• Policies reappraised
• Source references added to sustainability issues section

Proposed Submission CPP2 stage

4.7       The sections were amended as follows:

• Revisions to assessment of DM37

Main modifications stage

4.8 No changes to the SA arose from any of the representations received on the SA at Main Modifications stage.

4.9 All comments were made publicly available in the relevant Consultation Statements.

As already described, CPP2 was prepared in an iterative way with the SA as well as other evidence and background studies, informing plan production at each stage. As part of plan preparation, there was assessment of reasonable alternatives for all policies including the Development Management and Site Allocations policies. This options assessment was published in the Draft Stage SA.  The adopted plan reflects the most sustainable approach to future development in the city that is in accordance with national policy requirements, when compared to other alternatives.

Policies

5.2 A number of policy options for each policy were subject to assessment against the sustainability appraisal framework at Draft CPP2 stage. Results of these assessments were used to inform emerging and preferred policy approaches. As the preferred policy approaches progressed throughout the plan production stages, they were refined as appropriate, taking into account emerging and revised national policy, consultation feedback, any new technical evidence and the sustainability appraisal findings. 

5.3 At Proposed Submission stage, a table was produced that set out the selection and rejection of alternatives. This shows the various options that had been identified over time and summarised the SA reasons for selection or rejection of that option or policy approach.  This table was updated as appropriate at Proposed Modification stage. In all cases, the preferred policy approach presented the most sustainable option.

Sites

5.4 The SA site appraisals were not used as part of the process to discount or reject sites, for example, where a site was found to be less sustainable when compared with other sites, as all sites on the short-list were considered to have potential for allocation. This reflects the high level of development needs in the city, the constrained nature of the city, and the lack of available sites which leads to the need to allocate all suitable sites. The site appraisals were used to identify any possible mitigation that may be required, as well as to form the basis of the appraisal of the site allocations policies.

Conclusions of the Sustainability Appraisal

5.5 Overall, CPP2 is considered to reflect the most sustainable approach within the current policy context, providing a balance between social, economic and environmental needs.

5.6 Some of the cumulative impacts of the Site Allocations policies are more mixed overall particularly for some of the environmental objectives. Some sites have the potential to have multiple site-based environmental effects around the site itself depending on the site, which together could combine to have cumulative adverse effects such as loss of biodiversity, landscape impacts, heritage impacts, increased congestion, reduced air/noise quality, risk of pollution to water, risk of surface water flooding, and loss of green infrastructure reducing the city’s ability to adapt to climate change.

5.8 With regards to the social and economic objectives, the Special Area and Site Allocation policies combine to provide an overall positive cumulative effect, through increasing housing provision, supporting delivery of the wider determinants of health, improving or increasing access to services, providing measures that could support community safety, supporting equalities and social inclusion and supporting economic growth. Some of the effects are likely to be significantly positive, including for housing, health, and economic development

5.9 When the DM and Site Allocation policies are considered together, the DM policies are considered to provide a policy framework which avoids, reduces and addresses the likelihood of potential adverse effects arising from development on individual sites allocated across the site allocation policies, or from development coming forward on unallocated sites within the city, having a combined cumulative positive or neutral effect overall. In addition, when considered against the wider planning framework of City Plan Part 1, effects should be more positive overall.

Some of the more significant impacts of CPP2 are considered to be:

5.7       Positive impacts:

• Making the best use of land, ensuring sites have their development potential maximised and through ensuring a balanced mix of uses.
• An increase in quality housing, including student accommodation, through site allocations and through policies which require a high quality and appropriate mix is delivered.
• Improved health and well-being through housing and employment opportunities, active lifestyles, access to services and through a healthy urban environment.
• An increase in the amount of flexible, quality space and land for employment uses.

6.1  he Environmental Assessment of Plans and Programmes Regulations 2004 require that local authorities “monitor the significant environmental effects of the implementation of each plan or programme with the purpose of identifying unforeseen adverse effects at an early stage and being able to undertake appropriate remedial action.”

6.2 A monitoring framework has been developed for CPP2 which identifies a clear method for managing and monitoring implementation of the Plan.  This framework is set out in the Implementation and Monitoring Indicators and Targets. For each policy, the implementation and monitoring plan sets out the issue to be addressed, an indicator, target and timescale, and triggers and actions to show what will be done if targets are not achieved.  The indicators developed for each policy are to ensure that key issues are addressed and more broadly will enable progress in plan delivery to be evaluated.  

6.3 At each stage the SA has stated that a number of SA monitoring indicators were proposed to monitor the effects of CPP1, with indictors identified for each of the SA objectives that formed the SA Framework for CPP1. As CPP2 builds upon and is intrinsically linked to CPP1, no additional SA monitoring indicators have been put forward. The indicators identified for CPP1 will therefore also be used to monitor the sustainability effects of CPP2. It is recognised that some of these SA indicators may not be influenced directly by the City Plan but will be useful in providing an overall picture of how the city is evolving. Monitoring against some of the SA indicators also helps to provide baseline data for the next SA.

6.4 The full set of SA monitoring indicators is set out as follows.

Monitoring indicators for the CPP2

SA Objective (CPP1)

1. To prevent harm to and achieve a net gain in biodiversity

SA Objective (CPP2)

1. To protect, conserve and achieve a net gain in biodiversity

Indicator

• Number and area of designated sites (SAC, SSSI, SNCI, LNR, AONB, RIGS)
• Percentage of area of SSSI land in

1. favourable condition
2. unfavourable recovering condition
3. unfavourable no change condition
4. unfavourable declining condition
5. area part destroyed / destroyed

• SQM of habitat or biodiversity features added or lost (citywide) as a result of development

SA Objective (CPP1)

2. To improve air quality

SA Objective (CPP2)

6. To improve air and noise quality

Indicator

• The area of the city in km2 where the annual mean for nitrogen dioxide (calendar year) exceeds the national legal limit of >40 µg/m3 (monitored and modelled NO2).
• Improvement in levels of air quality in London Road, Lewes Road and Rottingdean areas.

SA Objective (CPP1)

3. To maintain local distinctiveness

SA Objective (CPP2)

2. To protect and improve open space and green infrastructure and improve sustainable access to it

4. To protect and conserve the city’s historic built environment, heritage assets and their settings, townscapes, buildings and archaeological sites

Indicator

• Number and % of Listed Buildings that are Grade 1 and 2*

1. on at risk register
2. subject to demolition

• Amount of open space created or lost (citywide) as a result of development

SA Objective (CPP1)

4. To protect, conserve and enhance the South Downs

SA Objective (CPP2)

3. To protect, conserve and enhance the South Downs National Park and its setting, and improve sustainable access to it

Indicator

• Number of bus services that operate to the South Downs from Brighton & Hove
• Amount of land under:

1. Entry level
2. High level environmental stewardship schemes

SA Objective (CPP1)

5. To meet the essential need for decent housing

SA Objective (CPP2)

14. To provide housing, including affordable housing, to contribute towards meeting local needs

Indicator

• Net additional housing completions
• Gross affordable housing completions
• House price to income ratio
• % of households considered to be suffering from over-crowding (having one less bedroom than required)

SA Objective (CPP1)

6. To reduce the amount of private car journeys

SA Objective (CPP2)

5. To reduce the need to travel by car, encourage travel by sustainable forms of transport and improve travel choice

Indicator

• Car ownership per household
• Annual average daily traffic flow:

(a) Outer cordon sites: 5, 22, 608 and 620

(b) City centre cordon sites: 74, 800, 809, 813

• Annual average daily cycle flow:

1. National Cycle Route 2 sites: 951, 967
2. National Cycle Route 90 sites: 960, 961

• Percentage of development where parking is provided for bicycles.
• Percentage of residential units delivered that are car-free
• CO2 emissions per capita from road transport (kt)

SA Objective (CPP1)

7. Minimise the risk of pollution to water resources

8. Minimise water use in all development

SA Objective (CPP2)

7. To improve water quality (ecological, chemical and quantity status)

Indicator

• Status of the groundwater resource as measured by the requirements of the Water Framework Directive.
• Quality of bathing water
• Percentage of new development incorporating SUDS within the development or beyond the development area.
• Domestic consumption of water (litre of water per day per household)

SA Objective (CPP1)

9. Promote the sustainable development of land affected by contamination

SA Objective (CPP2)

11. To improve soil quality

Indicator

• Number of sites of previously developed land that have been identified as having potential for contamination under Part 2A of the Environment Protection Act. 

SA Objective (CPP1)

10. Manage coastal defences and minimise coastal erosion and flooding

SA Objective (CPP2)

8. To reduce the risk from all sources of flooding to and from development

Indicator

• Number of developments in a flood risk area granted contrary to the advice of the Environment Agency

SA Objective (CPP1)

11. To balance the need for employment creation

12. To support initiatives that combine economic development with environment protection

SA Objective (CPP2)

19. To contribute towards the growth of a sustainable and diverse economy, increase employment opportunities and meet local employment needs.

Indicator

• Amount (£) of developer contributions secured for training for local residents, through the Local Employment Scheme
• Number and percentage of in-commuters compared to out-commuters
• Level of GVA per head
• Proportion of VAT registered businesses per 10,000 population
• Percentage population that are in employment

SA Objective (CPP1)

13. To improve the health of all communities

SA Objective (CPP2)

16. To improve health and well-being, and reduce inequalities in health

Indicator

• Life expectancy at birth (males, females - years)
• Obesity among primary school in year 6 (percentage)
• Adults achieving more than 150 minutes physical activity a week
• Percentage of population living in 20% most deprived Super Output Areas (health domain)

SA Objective (CPP1)

14. To integrate health and safety considerations

SA Objective (CPP2)

17. To improve community safety, and reduce crime and fear of crime

Indicator

• Number of total police recorded crimes
• People killed or seriously injured in road traffic accidents

SA Objective (CPP1)

15. To narrow the gap between the most deprived areas and the rest of the city

SA Objective (CPP2)

18. To increase equality and social inclusion

Indicator

• Percentage of population living in the 20% most deprived super output areas in the country
• Percentage of population over 60 who live in households that are income deprived
• Tackling fuel poverty - Percentage of people living in fuel poverty
• Percentage of young people who are not in employment, education or training (NEET)
• Percentage of non-decent council homes

SA Objective (CPP1)

16. To engage local communities in the planning process

SA Objective (CPP2)

No relevant CPP2 SA Objective

Indicator

• Number of adopted DPDs or SPDs that have incorporated periods of public consultation

SA Objective (CPP1)

17. To make the best use of previously developed land

SA Objective (CPP2)

13. To make the best use of land available

Indicator

• Percentage of new and converted dwellings on Previously Developed Land
• Percentage of new employment land on Previously Developed Land
• Percentage of development situated on Greenfield land.

SA Objective (CPP1)

18. To maximise sustainable energy use

SA Objective (CPP2)

9. To reduce emissions of greenhouse gases that cause climate change

Indicator

• Kt of CO2 per capita emitted from domestic sources for energy provision
• Average annual domestic consumption of gas and electricity
• Average annual commercial and industrial consumption of gas and electricity
• % of new residential development achieving the 19% carbon reduction improvement over Part L as required by CP8
• % of development with low/zero carbon energy proposed

SA Objective (CPP1)

19. To ensure developments have taken into account the changing climate

SA Objective (CPP2)

10. To increase the city’s resilience and ability to adapt to climate change

Indicator

• Percentage of new development incorporating green infrastructure such as green walls/roofs.

SA Objective (CPP1)

20. To encourage new non-residential developments to meet BREEAM standards

SA Objective (CPP2)

No relevant CPP2 SA Objective

Indicator

% of new non-residential development meeting the minimum standards as required by BH.

SA Objective (CPP1)

21. To promote and improve integrated transport links and accessibility

SA Objective (CPP2)

15. To improve the range, quality and accessibility of services and facilities.

Indicator

• Percentage of development that is within 500 m of the following:  Doctors, accessible open space, bus stop/rail station, infant junior or primary school, retail provision.

SA Objective (CPP1)

22. To reduce waste generation

SA Objective (CPP2)

12. To minimise and sustainably manage waste

Indicator

• Residual household waste per household
• Percentage of household waste:

1. recycled
2. composted
3. used to recover heat, power, and other energy sources

• Percentage of development providing facilities for recycling.

6.5 Progress against the Implementation and Monitoring Plan and the SA Framework will be published annually in the Authorities Monitoring Report as required by planning legislation.

Head of City Planning, Brighton & Hove City Council