SUSTAINABILITY APPRAISAL Sustainability Assessment Supplementary Planning Document

London Borough of Southwark Planning Policy Team May 2008

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CONTENTS PAGE Non technical summary 3 1. Introduction, consultation and policy context 8 2. Sustainability Appraisal Methodology and Timetable 10 3. Relationship to other Plans and Programmes 12 4. Social, Economic and Environmental Context 14 5. Key Sustainability Issues 15 6. Outcomes of the Sustainability Appraisal 18

APPENDICES Appendix 1 Legal and Policy Background for Sustainability Appraisal and SPD

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Appendix 2 Feedback on scoping report received from statutory consultees with officers’ response

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Appendix 3 Compatibility of Sustainability Objectives 36 Appendix 4 Appraisal of SPD Objectives 38 Appendix 5 Comparison of options 39 Appendix 6 Appraisal of Preferred Options (SPDs) 41 Appendix 7 Appropriate Assessment 42 Appendix 8 Glossary 57

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NON-TECHNICAL SUMMARY

The sustainability appraisal (SA) process allows us to predict the likely effects of the draft planning document on the environment, economy and community. In doing so, we can assess whether or not, and to what extent, draft planning policies and guidance will contribute towards the borough's objectives for achieving a sustainable community.

What planning documents are being appraised?

The council is preparing a supplementary planning document (SPD) about sustainability assessments. It will support and provide further guidance to policy 3.3 (Sustainability Assessments) in the Southwark Plan.

Section 1 of this report provides more detail on the draft SPD.

What process has been taken to appraise the likely effects of the plan? The SA process consisted of a series of steps: • The first stage involves deciding on the key issues that the appraisal will focus

on. It includes the preparation of a scoping report that highlights the key issues being considered early on in the SPD process.

• The next stages involve testing the likely impacts of the SPD on the environmental, economic and social issues set out in the scoping report. Usually there are a few different approaches that could be taken to guiding development. These are called options. The likely impacts of different options are tested and compared. The SPD is currently at this stage.

• Once the plan has been agreed (adopted), its social, economic and environmental impacts will then be monitored through the council’s annual monitoring report.

Section 2 of this report provides more detail on the appraisal process.

What sustainability issues are relevant to the area?

The key sustainability issues relevant to the borough, which the draft SPD needs to address are:

Relatively high levels of deprivation

Southwark is the 26th most deprived local authority district in England (out of 354).

Employment inequalities and Annual Population Statistics for 2005 employment opportunities show Southwark’s working age

employment rate (63.6%) to be lower than the London average (65.1%).

Statistics for the same period show that the Job seekers Claimant Count for Southwark (4.7%) is higher than the London average (4%).

Education, skills and training deprivation. The Indices of Multiple Deprivation suggest that there are high levels of education, skills and training deprivation within Southwark (refer to Appendix 5 of the SA Scoping Report).

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Health inequalities and noise nuisances The Indices of Multiple Deprivation show that that there are large areas in the borough where deprivation for health and disability is particularly high (refer to Appendix 6 of the SA Scoping Report).

High levels of crime and fear of crime In Southwark 45% feel safe at night, 89% in daytime.

Accessibility Little comprehensive data has been identified relating to this issue. A recent review of tenants halls in Southwark found that of the samples surveyed, none were fully compliant with the Disability and Discrimination Act.

Energy efficiency and use of renewables Recent research undertaken found that the average household in Southwark consumes 21% more energy and produces 12% more CO2 than a standard 3 bedroom semi-detached house built to 1995 Building Regulations.

Poor air quality The majority of Southwark is located within a designated Air Quality Management Area. This is a designation assigned by the London Borough of Southwark that means that UK air quality objectives for key pollutant gases are unlikely to be met.

Need to minimize waste arisings and increase recycling rates

Despite recent improvements in the borough’s recycling rate (7% in 2003/4 to just under 15% in 2005/6), Southwark has fallen short of its mandatory recycling targets for the past two years.

Need for sustainable use of water resources

Water scarcity is a particularly acute problem in the South East region. Research has estimated that the average daily water consumption in Southwark is 160litres per capita. OFWAT statistics demonstrate that this figure is higher than the national and western European average of (150litres).

Need to maintain and enhance open space and promote biodiversity.

Most of Southwark’s designated open spaces are located in the south of the borough.

Need to preserve and enhance built heritage and the archaeological environment

Southwark contains 5 archaeological priority zones – Kennington Road and Elephant and Castle, Walworth Village, Old Kent Road, Camberwell Green, Peckham Village, and Dulwich Village. There are also 39 designated Conservation Areas.

Need to improve accessibility by public transport and minimize the need to travel by car

Census data shows that between 1991-2001 there has been a shift in modes of transport use with more people now

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using train/tube (10%) buses/coaches (3%) and fewer people walking (-10%) and using their cars/motorcycles (-8%). Despite this, there is still a problem with congestion and pollution in large areas of the borough.

There are proposals to significantly improve public transport infrastructure, particularly the Cross Rail Tram, the East London Line and improvements to the transport interchange at Elephant and Castle.

Section 5 of this report provides more detail on the sustainability issues relevant to the borough, and how these were identified.

What sustainability objectives were used to appraise the draft SPD?

The likely impacts of the SPD are identified using a set of sustainability objectives. The objectives reflect the current social, economic and environmental issues affecting the area. These objectives are:

Sustainability objectives To tackle poverty and encourage wealth creation To improve the education and skill of the population To improve the health of the population To reduce the incidence of crime and the fear of crime To promote social inclusion, equality, diversity and community cohesion To reduce contributions to climate change To improve the air quality in Southwark To reduce waste and maximise use of waste arising as a resource To encourage sustainable use of water resources To maintain and enhance the quality of land and soils. To protect and enhance the quality of landscape and townscape To conserve and enhance the historic environment and cultural assets To protect and enhance open spaces, green corridors and biodiversity To reduce vulnerability to flooding To provide everyone with the opportunity to live in a decent home To promote sustainable transport and minimise the need to travel by car.

Section 6 of this report provides more information on the sustainability objectives used and how they were identified.

What are the likely significant effects of the draft SPD and what difference has the appraisal process made?

Overall, the appraisal indicated that the draft SPD is likely to make a positive contribution to sustainability. No negative impacts have been identified.

The draft SPD provides guidance on how to appraise the sustainability of planning proposals, and as one would expect, it should have mainly positive impacts. Part of the rationale of the SPD is encourage developers to consider the wider social,

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economic and environmental impacts of development from the outset when preparing planning applications. The SPD helps identify and measure key impacts early on and allows where necessary for measures to be put in place to mitigate any harmful or negative impacts.

It reinforces requirements already in the UDP and embedded in other planning guidance documents which will have positive impacts for sustainability. This includes a requirement to carry out flood risk and air quality assessments, the need to provide a range of housing tenures and sizes, the need to consider the accessibility of the development in the preparation of a design and access statement, and to incorporate features such as lifetime homes standards.

While the SPD covers much of the territory that is already set out in other documents, such as the Residential Design Standards SPD, the Transport SPD and the Design and Access Statements SPD, it also addresses several issues which currently do not have supplementary guidance, such as retail, town centres and business.

With regard to business, the SPD encourages developers to consider procuring a proportion of goods and services locally, which will assist small businesses. It also promotes the creation of small business space in new development and the provision of support services to businesses which may be displaced by development.

Measures such as these may have positive impacts particularly for BME groups in view of the fact that a high proportion of small and medium sized enterprises (SMEs) in Southwark are BME businesses.

The SPD also requires developers to consider carefully the impact of proposals on the health and vitality of town centres and to promote town centre locations over out of centre locations. The town centres frequently have concentrations of small businesses and the protection and enhancement of the town centres will contribute to strengthening economic prosperity and reducing the need to travel by car.

Given that the draft SPD is primarily about processes, ie it sets out the issues that developers will be expected to consider, rather than prescribing outcomes, few negative impacts have been identified. The SPD will help ensure that these issues are addressed more consistently and with a greater degree of transparency.

Section 6 of this report provides more detail on the likely significant effects of the draft SPD.

How to comment on this report

This report is being published for informal public consultation alongside the draft SPD from 27 May until 7 July 2008. Formal consultation will take place from 8 July 2008.

Submissions commenting on the SA are welcomed and should be addressed to:

By letter: Tim Cutts Planning Policy and Research Team Regeneration & Neighbourhoods Department London Borough of Southwark Chiltern, Portland Street, London SE17 2ES

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By email: planningpolicy@southwark.gov.uk By fax: 020 7525 5561

The closing date for comments is 19 August 2008.

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1. INTRODUCTION

What is this document?

This document reports on the Sustainability Appraisal of the draft Sustainability Assessment supplementary planning document (SPD). Sustainability assessments assess the social, economic and environmental impact of planning proposals and should be submitted with planning application.

Once adopted, the draft SPD will form part of the Southwark Local Development Framework, and will be a material consideration in decisions made by the council on planning applications in the borough. It will specifically provide further guidance on policy 3.3 of the Southwark Plan, which sets out the council’s requirement for sustainability assessments.

Why do we need to carry out a sustainability appraisal?

The Planning and Compulsory Purchase Act 2004 requires that a sustainability appraisal (SA) is carried out as part of the preparation of new plans, including SPDs. The purpose of a SA is to assess whether or not, and to what extent, a plan meets our objectives for achieving a sustainable community. In addition, the SPD falls within the definition of a ‘plan or programme’ under European Directive 2001/42. Because the SPD is likely to have significant environmental effects, it must also undergo a Strategic Environmental Assessment (SEA). The main purpose of an SEA is to predict what the likely significant effects of a draft plan will be on the environment and identify ways in which any negative effects can be overcome. Ways in which the actual effects of the plan will be measured and monitored, should it be adopted, are also identified as part of the SEA. The council has undertaken an SEA of the draft SPD as part of the sustainability appraisal. Taken together, the SA/SEA processes enable the social, environmental and economic implications of a plan to be assessed while it is being prepared, ensuring that sustainability is considered throughout the plan making process. For the purposes of simplicity, the term sustainability appraisal is used throughout this document to include both the SA and SEA processes.

What is the structure of this report?

This report is divided into 6 sections: − Section 1 - provides an overview of the need for and objectives of the draft SPD. − Section 2 - details the process used to undertake the SA. − Section 3 - outlines policies, plans and strategies relevant to the draft SPD and

presents baseline information, which will assist in assessing the effects of the draft SPD.

− Section 4 – outlines the social, economic and environmental context − Section 5 - presents a summary of sustainability issues relevant to the draft SPD. − Section 6 - presents the actual appraisal of the draft SPDs against relevant

sustainability objectives. This section also outlines the different alternatives that have been considered in preparing the draft SPD.

Why do we need a Sustainability Assessment SPD?

Policy 3.3 of the Southwark Plan requires sustainability assessment to be submitted with all major planning applications. And SPD is needed to provide additional guidance for applicants on the matters to be addressed in a sustainability

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assessment, the structure of an assessment and the council’s minimum and preferred standards.

What are the SPD objectives?

The purpose of this SPD is to provide guidance on how to carry out a sustainability assessment of planning applications. In particular it provides:

• A checklist which should be completed and submitted with planning applications

• Minimum standards which proposals will be expected to meet, as well as preferred standards

• Guidance on what evidence needs to be submitted along with the checklist

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2. APPRAISAL METHODOLOGY

The steps involved in undertaking a sustainability appraisal, which incorporates the requirements of the SEA Regulations, are outlined in Appendix 1 in Table AP1.3.

The council has undertaken the appraisal in accordance with the Department for Communities and Local Government (DCLG) advice in Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents (November 2005) and incorporates the requirements set out in the DCLG’s A Practical Guide to the Strategic Environmental Directive (September 2005).

The legal process and planning information is set out in Appendix 1. The components of this report which make up the Environmental Report for the purposes of a SEA are also indicated in Appendix 1.

Deciding the scope of the sustainability appraisal

Stage A of the SA process for the draft SPD involves setting the context and objectives, establishing the baseline and deciding on the scope of the appraisal. These were set out in a scoping report, which was prepared in December 2006.

The scoping involved the following: • Identifying policies, plans and programmes and sustainable development

objectives that are relevant to the draft SPD. • Collecting baseline information on the key environmental, social and economic

characteristics of the borough. • Identifying the sustainability issues and problems that need to be addressed by

the draft SPD. These were identified by analysing the key messages of the policies, plans and programmes relevant to the draft SPD as well as the baseline information.

• Developing the SA framework. This is made up of the sustainability objectives and indicators that will be used to appraise the draft SPD.

• Consulting on the draft scoping report.

Who was consulted on the scoping report?

The Environmental Assessment of Plans and Programmes Regulations 2004, requires the council to ask three key organisations to comment on the scoping report. These are the Environment Agency, Natural England1 and English Heritage. In addition, the Government Office for London and the Greater London Authority were asked to comment.

A copy of the draft scoping report was sent to these organisations in December 2006. A summary of the feedback received and how it has been taken into account by the council is given at Appendix 2.

Consultation on the draft SPD is being carried out in accordance with the Southwark Statement of Community Involvement (SCI). This sets out how individuals, community groups, developers and anyone else with an interest should be consulted on planning documents.

1 On 1 October 2006 the Countryside Agency and English Nature were formally amalgamated into Natural England.

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What followed after the scoping?

The second stage in the appraisal process involved the development of options for the draft SPD, based on the environmental and sustainability issues identified during scoping. These options represent alternative approaches that could be taken to preparing the draft SPD. Details of the options are given at Section 6. These options have been assessed against the SA framework developed at the scoping stage to identify their likely social, environmental and economic effects. The outcomes of this appraisal helped the council to decide on its preferred approach, which forms the basis of the draft SPD. The draft SPD was then subjected to a more detailed appraisal against the SA framework. The objectives of the draft SPD has also been appraised to ensure that it is consistent with the sustainability objectives. The detailed appraisal of the draft SPD highlighted potential significant negative effects of the preferred option that needed to be overcome, either through modifying the plan or the way it is implemented. Options for increasing the positive effects of the draft SPD were also identified, where relevant.

The Sustainability Report

This report represents stage C of the appraisal process. It documents the outcomes of each of the previous stages of the appraisal process. It also sets out: • the difficulties encountered in compiling information and carrying out the

assessment, including any assumptions that have been made in the appraisal process (Section 6); and

• proposals for monitoring the actual effects of the plan (Section 6).

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3. RELATIONSHIP TO OTHER PLANS AND PROGRAMMES

The review of plans and programmes of relevance to the draft SPD and the collection of baseline information helps identify the issues which the draft SPD needs to address and enables a robust appraisal of their significant effects.

A detailed schedule of relevant documents was set out in Appendix 2 of the scoping reports. A summary of the key messages of these documents is given at Table 3.1.

Table 3.1: Key messages of relevant plans and programmes

Key messages Key Documents Key Sustain ability Objective s

Meet the needs of UK: Sust. Dev. Strategy, PPS1, PPS3, PPS6, PPG17, Sust. SDO 3, all / tackle poverty Comm. Plan for London. Future of Higher Education Act 2004. SDO 5, social exclusion London: London Plan, Economic Development Strategy, SDO 13, and deprivation improve education

Accessible London. Local: Community Strategy, UDP, Employment Strategy, Children’s & Young People’s Plan, Open Spaces Strategy, Housing Strategy, Elephant and

SDO 15, SDO 16

Castle SPG Sustainable UK: Sust. Dev. Strategy, PPS1, PPS6. SDO 1, economy and London: Economic Development Strategy, Culture Strategy, SDO 16 town centres London Plan. Local: UDP, Enterprise Strategy, Tourism

Strategy, Elephant and Castle SPG High quality, safe UK: PPS1, PPG15, PPG16, PPG17, PPG24, PPS25, Sust. SDO 11, urban Comm. Plan for London. SDO 12, environments London: Accessible London, London Plan, Ambient Noise SDO 13,

Strategy. Local: Community Strategy, UDP, LIP, Crime and SDO 14,Drugs Strategy, Children & Young People’s Plan, Open Spaces Strategy, CABE By Design, CABE and English Heritage Tall Buildings guidance, Elephant and Castle SPG

SDO 16

Tackle congestion UK: DfT Transport Plan, PPS1, PPG13, PPS6, PPS10, Sust. SDO 7, and promote Comm. Plan for London. SDO 16 sustainable London: Transport Strategy, London Plan. transport Local: UDP, LIP, Elephant and Castle SPG

Reduce pollution UK: Sust. Dev. Strategy, PPS23, DfT Transport Plan, PPG24. SDO 7, London: London Plan, Air Quality Strategy, Local: UDP, Air SDO 9, Quality Management Plan, Contaminated Land Strategy, SDO 10,Elephant and Castle SPG SDO 16

Prudent use of UK: Sust. Dev. Strategy, PPS1, PPS10, PPS22, London: SDO 6, resources / Energy Strategy, London Plan, Waste Management Strategy, SDO 8, reduce/reuse London Remade Demolition Protocol. Local: Community SDO 9 waste Strategy, UDP, Climate Change Strategy, Waste Management

Strategy, Elephant and Castle SPG Reduce greenhouse Kyoto Protocol. UK: Climate Change Programme, PPS1, SDO 6

gas emissions PPS22. London: Energy Strategy, London Plan. Local: Community Strategy, UDP, Climate Change Strategy, Elephant and Castle SPG

Adapt to climate change

UK: PPS1, PPS25. London: London Plan. Local: Climate Change Strategy, Elephant and Castle SPG

SDO 14

Protect UK: Sust. Dev. Strategy, PPS1, PPS9, PPG17. London: SDO 13 biodiversity / Biodiversity Strategy, London Plan. improve access to Local: UDP, Biodiversity Action Plan, Open Spaces Strategy, natural Elephant and Castle SPG

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environment Housing supply and affordability

UK: Communities Plan, PPS 3 Housing, London: London Plan, Mayor’s Housing SPG, London Housing Strategy Local: UDP, Elephant and Castle SPG, Housing Needs Survey, , Draft Southwark Community Strategy: 2006-16, Southwark Housing Strategy 2005-2010, draft Affordable Housing SPG.

SDO 12

Conservation and archaeology

UK: PPG15, PPG16, London: London Plan, Local: UDP, Elephant and Castle SPG, Southwark Council St George’s Circus CAA

SDO 15

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4. SOCIAL, ECONOMIC AND ENVIRONMENTAL CONTEXT

Data can be used to describe the current characteristics of an area and predict how it is likely to change in the future, with or without the SPD. We have collected data to describe the social, environmental and economic characteristics of the borough.

There is always a starting point that we use to describe an area, as it is now, and compare how it may change in the future. This is called the baseline. The baseline for this report was presented in Appendix 3 of the sustainability scoping report. The topics that this data covers are listed in table 4.1 below.

Table 4.1 - Baseline Topics

• Regeneration and employment opportunities • Health • Social Inclusion and Community Cohesion particularly equalities issues • Energy Efficiency and Renewable Energy • Air Quality • Waste management • Water resources • Quality in Design • Conservation of Historic Environment • Open Space and Biodiversity • Flood risk • Housing • Sustainable Transport

The appraisal process has sought to compile a comprehensive list of up to date data in order to establish the baseline and identify the likely future without the draft Plan. However, in certain cases information was not currently collected, or was out of date. Appendix 3 of the scoping report clearly identifies where data is missing or is out of date.

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5. KEY SUSTAINABILITY ISSUES

This section sets out the main sustainability issues that need to be taken into consideration. These have been identified based on the baseline data and the messages of the relevant plans and strategies. The key sustainability issues are set out in table 5.1:

Table 5.1 – Key sustainability issues relevant to the SPD

Sustainability issue Baseline and source of evidence

1. Relatively high levels of deprivation

Southwark is the 17th most deprived local authority district in England (out of 354).

Source: Index of Multiple Deprivation (2004)

2. Employment inequalities and employment opportunities

Annual Population Statistics for 2005 show Southwark’s working age employment rate (63.6%) to be lower than the London average (65.1%).

Statistics for the same period show that the Job seekers Claimant Count for Southwark (4.7%) is higher than the London average (4%).

Source: Annual Population Survey, 2005.

3. Education, skills and training deprivation.

Appendix 5 shows that there are high levels of education, skills and training deprivation within Southwark.

4.Health inequalities and noise Appendix 6 illustrates that that there are nuisances large areas in the borough where

deprivation for health and disability is particularly high.

5. Need to promote equality, diversity social cohesion.

Southwark sees the promotion of equality and social cohesion is a key aspect of delivering sustainability.

An Equality Impact Assessment is being prepared early in the plan making process to inform the sustainability appraisal of the SPD. The findings of the EQIA will form the baseline against which the effects of the SPD will be measured, particularly in relation to the following equality target groups: Age, Disability, Faith, Gender, Race and ethnicity, Sexual Orientation.

6. High levels of crime and fear of crime In Southwark 45% feel safe at night, 89% in daytime. Source: Southwark Residents Survey 2005

7. Accessibility Little comprehensive data has been

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identified relating to this issue. A recent review of tenants halls in Southwark found that of the samples surveyed, none were fully compliant with the Disability and Discrimination Act.

8. Energy efficiency and use of renewables

Recent research undertaken found that the average household in Southwark consumes 21% more energy and produces 12% more CO2 than a standard 3 bedroom semi-detached house built to 1995 Building Regulations.

9. Poor air quality The majority of Southwark is located within a designated Air Quality Management Area. This is a designation assigned by the London Borough of Southwark that means that UK air quality objectives for key pollutant gases are unlikely to be met.

10. Need to minimize waste arisings and increase recycling rates

Despite recent improvements in the borough’s recycling rate (7% in 2003/4 to just under 15% in 2005/6), Southwark has fallen short of its mandatory recycling targets for the past two years.

11. Need for sustainable use of water resources

Water scarcity is a particularly acute problem in the South East region. Research has estimated that the average daily water consumption in Southwark is 160litres per capita. OFWAT statistics demonstrate that this figure is higher than the national and western European average of (150litres).

12. Need to maintain and enhance open space and promote biodiversity.

Most of Southwark’s designated open spaces are located in the south of the borough.

13. Need to preserve and enhance built heritage and the archaeological environment

Southwark contains a 5 known archaeological priority zones – Kennington Road and Elephant and Castle, Walworth Village, Old Kent Road, Camberwell Green, Peckham Village, and Dulwich Village. There are also 39 designated Conservation Areas.

14. Need to improve accessibility by public transport and minimize the need to travel by car

Census data shows that between 1991-2001 there has been a shift in modes of transport use with more people now using train/tube (10%) buses/coaches (3%) and fewer people walking (-10%) and using their cars/motorcycles (-8%). Despite this, there is still a problem with congestion and pollution in large areas of the borough.

There are proposals to significantly improve public transport infrastructure,

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particularly the Cross Rail Tram, The East London Line and improvements to the transport interchange at Elephant and Castle.

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6. APPRAISAL OF DRAFT SPD

How have the likely impacts of the SPD been identified?

The likely impacts of the SPD are identified using a set of sustainability objectives and questions known as an “appraisal framework”. The objectives should be achieved by the SPD to make sure they benefit the environment, economy and community, such as whether emissions of greenhouse gases will be reduced. The questions help to guide the assessment. The objectives reflect the current social, economic and environmental issues affecting the area and were consulted on as part of the scoping report. The objectives and questions are set out in table 6.1:

Table 6.1 – Sustainability Appraisal Framework

The objectives have been compared to check if they are compatible with one another, or if there is the possibility that achieving one objective could affect how we can achieve another. A table illustrating this is included at Appendix 3.

Objective Criteria Questions

Regeneration and Employment Opportunities SDO 1. To tackle poverty and encourage wealth creation

Will it create job opportunities? Will it help remove barriers to employment? Will it encourage the retention and /or growth of local employment? Will it promote inward investment? Will it enhance enterprise opportunities in key business districts and town centres? Will it reduce the disparity with surrounding areas? Will it improve the range of employment opportunities?

Education SDO 2. To improve the education and skill of the population

Will it provide high quality educational facilities? Particularly in areas of demonstrated educational deficiency? Will it provide opportunities to improve the skills of the population, particularly for young people and adults? Will it help fill key skills gaps?

Health SDO 3. To improve the health of the population

Will it promote healthy living through e.g. provision of walking and cycling facilities or through provision of e.g. allotment space? Will it reduce health inequalities? Will it improve access to high quality health care facilities? Will it reduce the impact of noise nuisance and/or vibrations on the population?

Crime and Community Safety SDO 4. To reduce the incidence of crime and the fear of crime

Will it improve safety and security? Will it incorporate measures to reduce the fear of crime?

Social inclusion and Community Cohesion SDO 5. To promote social

Will it secure improved facilities and infrastructure within the public realm for people with disabilities? Will it encourage the retention of key services and amenity such as schools and green spaces? Will it provide high quality accessible community facilities within the vicinity of people’s homes and as an essential component of regeneration schemes?

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Objective Criteria Questions inclusion, equality, diversity and community cohesion

Will it improve the quality / extend the range of leisure and cultural facilities? Will it promote equality and diversity in the action area? Will it encourage people to meaningfully participate in local decisions?

Energy Efficiency and Renewable Energy SDO 6. To reduce contributions to climate change

Will it achieve high standards of energy efficiency? Will it encourage the generation and use of renewable energy?

Air Quality SDO 7. To improve the air quality in Southwark

Will it encourage a reduction in the journeys made by car? Will it help achieve the objectives of the Air Quality Management Plan? Will it encourage a reduction in the emission of key pollutants?

Waste Management SDO. 8 To reduce waste and maximise use of waste arising as a resource

Will it provide appropriate waste management infrastructure? e.g. integrated recycling facilities Will it promote the reduction of waste during construction / operation?

Water Resources SDO 9. To encourage sustainable use of water resources

Will it lead to a reduction in the quality of surface water/waterways? Will it reduce water consumption Will it adopt technologies / infrastructure that will encourage the reuse of water / maximise water efficiency?

Soil and Land Quality SDO 10. To maintain and enhance the quality of land and soils.

Will it lead to a reduction in the quality of soils?

Will it encourage the remediation of land identified as potentially contaminated?

Quality in Design SDO 11. To protect and enhance the quality of landscape and townscape

Will it enhance the quality and attractiveness of the built environment? Will improve the relationship between different buildings, streets, squares, parks and waterways and other spaces that make up the pubic domain? Will it have a negative impact on important strategic / local views?

Conservation of Historic Environment SDO 12. To conserve and enhance the historic environment and cultural assets

Will it conserve and where appropriate enhance the historic environment and cultural assets? Will it involve the loss of existing traditional features of interest that positively contribute to the character of the area?

Open Space and Biodiversity SDO 13. To protect and enhance

Will it encourage development on previously developed land? Will it encourage the appropriate management or enhancement of existing open spaces or the creation of open spaces? Will it enhance public access to open space?

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Objective Criteria Questions open spaces, green corridors and biodiversity

Will it promote the provision of high quality open space that caters for a variety of needs? Particularly in areas of regeneration? Will it help achieve the goals of the Biodiversity Action Plan?

Flood Risk Will it minimise the risk of flooding to the development area? SDO 14. To reduce vulnerability to flooding

Will it adopt the principles of Sustainable Urban Drainage Systems?

Housing SDO 15. To provide

Will it contribute towards meeting the need for affordable housing?

everyone with the opportunity to live in a decent home

Will it provide a range of housing tenure? Will it increase access homes with three or more bedrooms? Will encourage the re-use of vacant dwellings?

Sustainable Transport SDO. 16 To promote sustainable transport and minimise the need to travel by car

Will it encourage development near key transport/ public transport locations? Will it improve accessibility in and around the borough by public transport; walking and cycling? Will it improve accessibility to key amenities and services by public transport; walking and cycling? Will it improve safety for pedestrians and cyclists? Will it encourage the use of alternatively fuelled vehicles? Will it promote protection of existing water/rail facilities such as wharves and sidings?

The objectives have also been examined to ensure they evenly cover environmental, social and economic issues. A table illustrating the coverage of the objectives is included at Appendix 3.

Are the objectives of the draft SPD compatible with the sustainability objectives?

As a first step, the objectives of the draft SPD were compared with the sustainability objectives. This found that what the draft SPD is aiming for is consistent with the sustainability objectives, in particular those relating to transport. See table A4.1 in Appendix 4.

What are the alternatives to the draft SPD and how do these compare in sustainability terms?

The next step involved identifying different planning options for the areas. These were then appraised and the potential significant effects of each compared. This process assisted in identifying the preferred planning option for the areas, which formed the basis of the draft SPDs.

The following options were appraised:

• Option A Prepare the guidance to achieve the objectives through a prescriptive framework;

• Option B Do not prepare the guidance dealing with planning applications on a case by case basis.

More detail on each option is provided in table AP5.1 in Appendix 5.

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Appraisal of the options

The SPD largely deals with procedure, ie. it sets out the information which the council will need to assess the sustainability of planning applications. The chief benefit of preparing the SPD lies in the fact that it can help ensure that applications are dealt with more consistently and transparently. It also encourages developers to consider the sustainability impacts of their proposals from the outset of preparing an application, to identify sustainability issues and to find ways of avoiding or mitigating the impacts.

In the absence of an SPD, developers are often uncertain about council requirements and propose their own methodologies for undertaking sustainability appraisals. This introduces inconsistency which makes it more difficult to both assess applications and also to monitor the affects of schemes post implementation.

Outcomes of the appraisal – what are the likely impacts of the SPDs?

The final stage in the appraisal process involved a detailed testing of the guidance in the draft SPD against the sustainability framework. The matrices which show the appraisal are set out in Table AP6.1 in Appendix 6.

The draft SPD provides guidance on how to appraise the sustainability of planning proposals, and as one would expect, it should have mainly positive impacts. Part of the rationale of the SPD is encourage developers to consider the wider social, economic and environmental impacts of development from the outset when preparing planning applications. The SPD helps identify and measure key impacts early on and allows where necessary for measures to be put in place to mitigate any harmful or negative impacts.

It reinforces requirements already in the UDP and embedded in other planning guidance documents which will have positive impacts for sustainability. This includes a requirement to carry out flood risk and air quality assessments, the need to provide a range of housing tenures and sizes, the need to consider the accessibility of the development in the preparation of a design and access statement, and to incorporate features such as lifetime homes standards.

While the SPD covers much of the territory that is already set out in other documents, such as the Residential Design Standards SPD, the Transport SPD and the Design and Access Statements SPD, it also addresses several issues which currently do not have supplementary guidance, such as retail, town centres and business.

With regard to business, the SPD encourages developers to consider procuring a proportion of goods and services locally, which will assist small businesses. It also promotes the creation of small business space in new development and the provision of support services to businesses which may be displaced by development. Measures such as these may have positive impacts particularly for BME groups in view of the fact that a high proportion of small and medium sized enterprises (SMEs) in Southwark are BME businesses.

With regard to retail, the SPD encourages developers to consider allocating a percentage of new retail floorspace to independent traders, rather then multiples. Again, this has the potential to support locally based SMEs. The SPD also requires developers to consider carefully the impact of proposals on the health and vitality of town centres and to promote town centre locations over out of centre locations. The

21

protection and enhancement of the town centres is important, particularly to those groups who are less likely to have access to a car, such as the elderly.

Given that the draft SPD is primarily about processes, ie it sets out the issues that developers will be expected to consider, rather than prescribing outcomes, few negative impacts have been identified. The SPD will help ensure that these issues are addressed more consistently and with a greater degree of transparency.

The council has also assessed any impacts of the draft SPDs on habitats which are protected by European Habitats Directive. The results of this are set out in Appendix 7.

How have likely negative effects been mitigated?

Because the document largely deals with process, no negative impacts have been identified.

How should the draft SPD be implemented?

The draft SPD will be used together with the Southwark Plan and the London Plan to help assess planning applications. It is important however that they are not viewed in isolation. The council has other planning policy guidance documents relating to issues such as affordable housing, residential design standards, sustainable design and construction, and s106 planning obligations. It is important that these documents are also considered in the assessment of planning applications and the implementation of schemes.

Monitoring

This appraisal has identified the potential significant effects of the draft SPD. It is important that the implementation of the SPD is monitored in order to determine what the actual affects are. The most appropriate mechanism with which to monitor the draft SPD is the Local Development Framework Annual Monitoring Report (AMR). The AMR monitors the type of development that is occurring as a result of the council’s planning policy and guidance and what effects this development is having in terms of sustainability.

The monitoring framework used for the AMR includes indicators that measure the significant effects of development in the borough, such the provision of education space, open space provision and modes of travel. The draft SPD will help the council monitor proposals by ensuring that the council is provided with a consistent set of data when planning applications are submitted.

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APPENDIX 1 - LEGAL AND POLICY BACKGROUND FOR SUSTAINABILITY APPRAISAL AND SUPPLEMENTARY PLANNING DOCUMENTS

The 2004 Planning and Compulsory Purchase Act introduced a number of significant changes to the planning system in England. Under the 2004 Act, existing unitary development plans are to be replaced by a local development framework (LDF). The LDF will include supplementary planning documents. An outline of the contents of the Local Development Framework is illustrated in Figure AP1.1.

Figure AP1.1 Local Development Framework Contents

The regional spatial strategy (the London Plan), and the core strategy comprise (are) the development plan and they are the primary (most important) consideration in determining (deciding) planning applications. The core strategy in Southwark is the adopted Southwark Unitary Development Plan 2007 called the Southwark Plan. Supplementary Planning Documents (SPD) are guidance notes, additional to the Southwark Unitary Development Plan, that provide more information about how to implement the policies. They also contain background information that applicants may find useful when preparing their planning applications. The SPD will be adopted to the Southwark Plan 2007 policy 3.3 Sustainability Assessment. The stages in preparing a supplementary planning document are set out in Figure AP1.2 below:

Figure AP1.2 Stages in the preparation of a supplementary planning document

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Section 39 of the Planning and Compulsory Purchase Act 2004 requires that Sustainability Appraisals are prepared for all local development documents, including SPDs.

Strategic Environmental Assessment and Sustainability Appraisal The SPDs fall within the definition of a ‘plan or programme’ under European Directive 2001/42 (the SEA Directive). As they are likely to have significant environmental effects, they must also undergo a Strategic Environmental Assessment (SEA), as part of a sustainability appraisal. The SEA directive is transposed (made) into UK law by the Environmental Assessment of Plans and Programmes Regulations 2004. Guidance on the implementation of the 2004 Regulations and the Planning and Compulsory Purchase Act is set out in the ODPM’s Practical Guide to the Strategic Environmental Assessment Directive (September 2005) and Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents (November 2005) respectively. These guidance documents set out a similar methodology to be used in the preparation of both SAs and SEAs. This is a standard Scoping Report for the SA/SEA process, as defined in current then-ODPM guidelines, ‘Practical Guide to the Strategic Environmental Assessment Directive’ (September 2005) and ‘Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents’ (November 2005). It is common practice that SAs incorporate an SEA. In the case of the SPDs, all reference to SA should be understood as referring to both the SA and SEA process. The stages in the preparation of SA and their relationship to the stages in the preparation of an SPD are set out in Table AP1.3 below.

The components of this report which make up the environmental report for the purposes of SEA are indicated in Table AP1.4 below.

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AP1.3: The different stages of SA and SEA, showing their relationship. (The SEA stages were taken from A Practical Guide to the Strategic Environmental Directive (Figure 5, page 24, DCLG, September 2005) and the SA stages and SPD stages from Sustainability Appraisal of Regional Spatial Strategies and Local Development Documents (Figure 2, page 19, DCLG, November 2005)).

SEA Stage Sustainability Appraisal (SA) Stage that meets the requirements of the SEA Stage

SPD Stage

Stage A: Setting the context and objectives, establishing the baseline and deciding on the scope

Stage A: Setting the context and objectives, establishing the baseline and deciding on the scope

SPD Stage 1: Pre-production – Evidence gathering

Identifying other relevant plans, programmes and environmental protection objectives

A1: Identifying other relevant policies, plans and programmes and sustainable development objectives

Collecting baseline information

A2: Collecting baseline information

Identifying environmental problems

A3: Identifying sustainability issues and problems

Developing SEA objectives

A4: Developing the SA framework

Consulting on the scope of the SEA

A5: Consulting on the scope of the SA

Stage B: Developing and refining alternatives and assessing effects

Stage B: Developing and refining options and assessing effects

SPD Stage 2: Production – Prepare draft SPD

Testing the plan or programme objectives against the SEA objectives

B1: Testing the SPD objectives against the SA framework

Developing strategic alternatives

B2: Developing the SPD options

Predicting the effects of the plan or programme, including alternatives

B3: Predicting the effects of the draft SPD

Evaluating the effects of the plan or programme, including alternatives

B4: Evaluating the effects of the draft SPD

Mitigating the adverse effects

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

Proposing measures to monitor the environmental effects of the plan or programme implementation

B6: Proposing measures to monitor the significant effects of implementing the SPD

Stage C: Preparing the Environmental Report

Stage C: Preparing the Sustainability Appraisal Report

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SEA Stage Sustainability Appraisal (SA) Stage that meets the requirements of the SEA Stage

SPD Stage

Preparing the Environmental Report

C1: Preparing the Sustainability Appraisal Report

Stage D: Consulting on the draft plan or programme and the Environmental Report

Stage D: Consulting on the SPD and the Sustainability Appraisal Report

Consulting the public and Consultation Bodies on the draft plan or programme and the Environmental Report

D1: Public participation on the SA Report and the draft SPD

Making decisions and providing information

D3: Making decisions and providing information

SPD Stage 3: Adoption

Stage E: Monitoring the significant effects of implementing the plan or programme on the environment

Stage E: Monitoring the significant effects of implementing the SPD

Developing aims and methods for monitoring

E1: Finalising aims and methods for monitoring

Responding to adverse effects

E2: Responding to adverse effects

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Table AP1.4 The components of the SA Report which make up the Environmental Report for the purposes of the Strategic Environmental Assessment

Information Required in Environment Report Where covered in SA Report

Outline of the contents, main objectives of the plan or programme, and relationship with other relevant plans and programmes

Section 2.

The relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme

Section 4, Appendix 3 Scoping Report.

The environmental characteristics of areas likely to be significantly affected Section 4, Scoping Report Appendix 3.

Any existing environmental problems which are relevant to the plan or programme Section 5

The environmental protection objectives 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

Scoping Report Appendix 2, Section 5, Section 6

The likely significant effects on the environment. Section 6, Appendix 4

The measures envisaged to prevent, reduce and offset any significant adverse effects on the environment of implementing the plan or programme

Section 6, Appendix 5

An outline of the reasons for selecting the alternatives dealt with Section 6

A description of how the assessment was undertaken including any difficulties encountered in compiling the required information

Section 3

A description of measures envisaged concerning monitoring Section 6

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A non-technical summary of the information provided under the above. Section 1

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APPENDIX 2 – FEEDBACK ON SCOPING REPORT RECEIVED FROM STATUTORY CONSULTEES WITH OFFICERS’ RESPONSE

Natural England Comment Officer response No comments received.

English Heritage Comment Officer response No comments received

Environment Agency Comment Officer response The key environmental issues, which we would like to see addressed more strongly in the SPD are:

• Strategic Flood Risk Assessment • Baseline Data • Infrastructure and Development • Land Contamination

Noted.

Strategic Flood Risk Assessment Noted. The council has completed a strategic flood risk assessment, which We do advice the council to start SFRA as early as possible in the the EA have confirmed is satisfactory. The recommendations within the preparation of all its Local Development Documents. Without such an SFRA have been included in the draft SPD. assessment, any sustainability appraisal would be considered incomplete.

PPS25 makes the requirement of SFRA very clear. Annex E, E5 states:

…’ The SFRA should be used to inform the Sustainability Appraisal (incorporating the SEA Directive) of the Local Development Documents (LDDs), and will provide the basis from which to apply the Sequential Test and Exception Test in the development allocation and development control process (see Annex D).’

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Comment Officer response

Para 12 states: …’ A SFRA should be carried out by the local planning authority to inform the preparation of its LDDs, having regard to catchment-wide flooding issues which affect the area. The SFRA will provide the information needed to apply the sequential approach (see paras. 14–17). Policies in LDDs should set out requirements for site-specific Flood Risk Assessments (FRAs) to be carried out by developers and submitted with planning applications in areas of flood risk identified in the plan, under circumstances set out in this PPS’

Other than provide a framework at local/strategic level to help apply the sequential test and inform site allocations, SFRA is also used to identify sustainability objectives and test policy options in SA/SEA.

In addition SFRA will allow the Council to:

• prepare appropriate policies for the management of flood risk • identify the level of detail required for site specific Flood Risk

Assessments in particular locations, and, • determine the acceptability of flood risk in relation to emergency planning

capability. • determine the potential increase from flood risk due to increase in surface

water run off and the identification of opportunities for the sustainable management of surface water

• determine the effect of flood risk management failure and particularly the risk of rapid inundation.

A SFRA should ensure that future development does not add to and state opportunities for reducing flood risk through reallocating land to areas of lower risk and utilising existing and new green spaces for flood management

Baseline Data All references to PPG25 should now change to PPS25. The section on PPG25 (Appendix 2) (now PPS25) is inadequate because it

Noted. Any references to PPG 25 have been updated. As mentioned above, the council has completed a strategic flood risk assessment, which has informed the preparation of the draft SPD. Guidance on the sequential test

30

Comment Officer response does not highlight the need for a strategic flood risk assessment (SFRA). This is needed for the sequential test to be fully applied. It may not be possible to complete this document within the stated time-scale if the needed SFRA has not been begun

Appendix 3: -Baseline data needs to be compiled for flood risk issues. This is needed to allow the assessment of change and policy performance against key indicators. Examples include: -the number of dwellings in Flood Zone 3, the number of new or replacement dwellings permitted in Flood Zone 3 and the number of highly vulnerable premises within flood Zone 3 (as per PPS25 Annex D). It may be possible to compile some baseline data using the flood zones.

We recommend paragraph 1.9 be amended to include flood risk as a separate key objective. A great proportion of the borough falls in flood zone 2 and 3 as recognised by SD0 14. Whilst Flood Risk is one of the Baseline Topics listed in Table 5 there are no Key Sustainability issues highlighted in Table 6. Given the weight afforded these issues in PPS25 and the areas of the Borough defended by the Tidal Defences in Flood Zone 3, Table 6 should include Flood Risk Issues.

Table 7 includes SDO 14 on reduction of vulnerability to flooding. However, PPS25 creates a duty to first demonstrate whether a development is being sited in the lowest flood risk zone. The Sequential Test and where appropriate the Exceptions Test are prerequisites and reducing the vulnerability to the development area is not a substitute for this.

and exception test is included in the draft SPD.

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Comment Officer response Waste Water Treatment Although Table 7 objective SDO 8 mentions waste management, it does not include waste water treatment, which is a significant sustainability issue. Adequate sewer capacity and treatment facilities must be provided alongside all new development. Housing development should only take place on a scale and in locations where waterbodies can be protected from damage caused by the discharge of increased quantities of treated sewage effluent.

Paragraphs B3 to B 8 of PPS12 places specific emphasis on the need to take account of infrastructure such as water supply and sewerage in preparing Local Development Documents. Paragraph B3 in particular states:

‘The provision of infrastructure is important in all major new developments. The capacity of existing infrastructure and the need for additional facilities should be taken into account in the preparation of all local development documents. Infrastructure here includes water supply and sewers, waste facilities…’

The Water Framework Directive will introduce new environmental water quality standards. We are unsure, at the moment, how these will affect the water environment’s ability to absorb growth.

The combined drainage system of London has limited capacity. Moderate rainfall (as low as 2 mm per hour) frequently overloads the system resulting in 50-60 days per year when sewer overflows operate.

Therefore there is need to ensure that: • The rate of development is in line with the capacity of sewerage and

sewage treatment systems. Where increased capacity is required, the sewerage and sewage treatment infrastructure must be provided before development proceeds.

• Development must not occur in locations where sewage treatment facilities are inadequate to treat the sewage to the standards required to protect the quality of the receiving watercourse

Noted. The draft SPD provides guidance on the need to reduce run-off water. The council has consulted Thames Water with respect to those local development documents which propose a significant amount of development, such as the Aylesbury Area Action Plan, the Elephant and Castle SPG, the Canada Water Area Action Plan and the Peckham Area Plan. The council will work with Thames Water to ensure adequate provision is made for sewerage.

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Comment Officer response

Water efficiency standards Noted. The draft SPD requires that minimum standards are met with regard SDO 9 should place more emphasise on water efficiency standards. The to water efficiency. In the case of residential development, this is 105l per requirement to achieve high levels of water efficiency is critical to all new and person per day (Code for Sustainable Homes level 3). existing development. Lack of progress on demand management will place too much emphasis on resource development solutions, which are inflexible and planning approval can not be guaranteed. However, further assessments of water supply may be necessary in specified locations before definitive-housing numbers can be set.

Land Contamination Noted. A requirement that contaminated land is mediated is incoprorated PPS23: Planning and Pollution Control, (Nov 2004) has changed the basis for within the draft SPD. dealing with land affected by contamination. It rests firmly on the precautionary principle. Objective SDO 10 should be tailored to reflect the precautionary principle because most of the housing development will occur on previously developed land.

The precautionary principle should be invoked when:

-there is good reason to believe that harmful effects may occur to human, animal or plant health or to the environment; and the level of scientific uncertainty about the consequences or likelihood of the risk is such that best available scientific advice cannot assess the risk with sufficient confidence to inform decision-making. The precautionary action requires assessment of costs and benefits of action, and transparency in decision-making.

Sites are to be investigated before planning permission is granted. Remediation must reduce the risk to acceptable levels, and make the site fit for proposed development. We would request the council to invoke this approach wherever it considers there might be a risk.

Developers should take note of this requirement to know the potential for contamination and the need for initial site investigations and reassurance that the site will not cause pollution to water and soil.

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Comment Officer response

Paras 23 and 24: 'The LPA should satisfy itself that the potential for contamination and any risks arising are properly assessed and that the development incorporates any necessary remediation and subsequent management measures to deal with unacceptable risks. Intending developers should be able to assure LPAs they have the expertise, or access to it, to make such assessments.

It should normally require at least a desk study of the readily available records assessing the previous uses of the site and their potential for contamination in relation to the proposed development. If potential for contamination is confirmed, further studies by the intending developer to assess the risks and identify and appraise the options for remediation should be required'

Conclusion We do recognise that other SPDs may cover some of the issues we have raised. However it offers the opportunity to produce development with the highest environmental standards. We would like to work with you on the best ways to manage and improve the green infrastructure and on achieving significantly improved water and energy efficiency.

Noted.

Greater London Authority Comment Officer response Only comment on strategic SPD

Government Office for London Comment Officer response Only comment on strategic SPD

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35

APPENDIX 3 COMPATIBILITY AND COVERAGE OF SUSTAINABILITY OBJECTIVES

Objective SDO

19 Compatible

SDO 2 9 SDO

2

SDO 3 9 0 SDO

30 No sig. link

SDO 4 9 0 9

SDO

4

SDO 5 9 9 9 9

SDO

5

? Depends on implementation SDO 6 9 0 9 0 0 SD

O 6

SDO 7 9 0 9 0 0 9

SDO

7

SDO 8 9 0 0 0 0 9 0 SDO

8

SDO 9 9 0 9 0 0 9 0 0 SDO

9

SDO 10 9 0 9 0 0 0 0 9 0 SDO

10

SDO 11 9 0 0 0 0 ? 0 ? 0 0 SDO

11

SDO 12 9 0 0 0 0 ? 0 ? 0 0 9 SDO

12

SDO 13 9 0 9 0 0 9 9 0 9 9 9 9 SDO

13

SDO 14 9 0 9 0 0 9 0 0 9 0 0 0 9 SDO

14

SDO 15 9 0 9 0 9 9 9 0 9 0 9 9 9 9 SDO

15

SDO 16 9 9 9 0 9 9 9 9 0 0 9 0 9 9 9

Most of the objectives are either compatible with one another, or there is no direct link between achieving them.

36

Coverage of SA Objectives

Objective Environmental Social Economic

SDO 1 9 9

SDO 2 9 9

SDO 3 9 9 9

SDO 4 9 9 9

SDO 5 9

SDO 6 9 9 9

SDO 7 9 9 9

SDO 8 9 9

SDO 9 9 9 9

SDO 10 9 9 9

SDO 11 9 9 9

SDO 12 9 9 9

SDO 13 9 9 9

SDO 14 9 9 9

SDO 15 9 9

SDO 16 9 9 9

Most of the objectives cover environmental, social and economic issues, either directly or indirectly. For example, Sustainability Objective 6 (Energy Efficiency and Renewable Energy) is directly aimed at reducing the impact of carbon dioxide emissions on the environment. However, there will also be social and economic benefits as more sustainable transport choices being encouraged to encourage energy efficiency may also improve the health of the population.

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APPENDIX 4 – APPRAISAL OF SPD OBJECTIVES

Objectives of draft SPD:

• A checklist which should be completed and submitted with planning applications • Minimum standards which proposals will be expected to meet, as well as

preferred standards • Guidance on what evidence needs to be submitted along with the checklist

A4.1 - Compatibility of objectives of draft SPDs with sustainability objectives

Draft SPD Objective

Sustainability Objectives

SDO

1

SDO

2

SDO

3

SD0

4

SDO

5

SDO

6

SDO

7

SDO

8

SDO

9

SDO

10

SDO

11

SDO

12

SDO

13

SDO

14

SDO

15

SDO

16

1 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 92 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 93 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9

Legend 9 Compatible - No relationship ? Depends on implementation X Incompatible

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APPENDIX 5 – COMPARISON OF OPTIONS

Table AP 5.1. Appraisal matrix: Comparison of impacts of an SPD versus not preparing an SPD (relying on Development Plan without any guidance)

+ Positive – +/- Minor Negative +++/--- Major 0 Neutral ? Uncertain

SDO Option A – SPD Option B – No SPD

Effect Commentary Effect Commentary S M L S M L 1 ++

+ ++ +

++ +

The SPD will encourage to consider the impact of proposals on employment and enterprise from the outset of the process of preparing a development proposal

+ +

+ +

+ +

In the absence of an SPD, proposals may fail to take full advantage of opportunities to strengthen the local economy.

2 ++ ++ ++ The SPD will help raise awareness of the need to consider the impacts of development on formal education and assess opportunities to incorporate proposals within development which may have benefits for education.

+ +

+ +

+ +

.

3 ++ ++ ++ The SPD will help raise awareness of issues which affect the determinants of health, such as access to open space, good quality living environments etc.

+ + +

4 ++ ++ ++ The SPD highlights the importance of ensuring the new development meets secured by design standards.

+ + +

5 ++ ++ ++ The SPD flags the need to take equalities issues into account. It also introduces guidance on carrying out Equalities Impacts Assessments for EIA scale development.

+ + +

6 ++ +

++ +

++ +

The SPD supports policy in the Southwark Plan and London Plan and should help ensure that energy assessments are prepared in a more consistent and transparent way.

+ +

+ +

+ +

While the SPD does not change policy, it should help ensure that the policy is implemented more consistently.

7 ++ +

++ +

++ +

The SPD should help ensure that Air Quality Assessments are consistent and that air quality is considered in the preparation of

+ +

+ +

+ +

While the SPD does not introduce new policy, it should help ensure that air quality assessments follow a more consistent methodology.

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SDO Option A – SPD Option B – No SPD

Effect Commentary Effect Commentary S M L S M L proposals.

8 ++ +

++ +

++ +

The SPD provides guidance on how to prepare an operational waste management plan. It also highlights the need to prepare site waste management plans.

+ +

+ +

+ +

In the absence of an SPD, the content and methodology of operational waste management plans tend to vary.

9 ++ +

++ +

++ +

The SPD reinforces the need to meet Code for Sustainable Homes targets, and to measure water usage against BREEAM tests.

+ +

+ +

+ +

10 ++ ++ ++ The SPD seeks to ensure that land is decontaminated where necessary.

+ +

+ +

+ +

The SPD does not provide additional guidance on this issue.

11 ++ ++ ++ The SPD highlights the need to prepare design and access statements.

+ +

+ +

+ +

The SPD does not provide additional guidance on this issue.

12 ++ ++ ++ The SPD highlights the need to prepare design and access statements.

+ +

+ +

+ +

The SPD does not provide additional guidance on this issue.

13 ++ +

++ +

++ +

The SPD reinforces the need to consider open spaces, particularly in areas of deficiency and incorporates new GLA standards on children’s play space.

+ +

+ +

+ +

14 ++ +

++ +

++ +

The SPD provides guidance on how to undertake a flood risk assessments, and incorporates the recommendations which emerged from the council’s recent strategic flood risk assessment.

+ +

+ +

+ +

15 ++ ++ ++ The SPD highlights UDP policy requirements for affordable housing and the need to provide a good quality living environment.

+ +

+ +

+ +

The SPD does not provide additional guidance on this issue.

16 ++ +

++ +

++ +

In tandem with the Transport SPD, the draft SPD seeks to enure that transport impacts are mitigated and that proposals support sustainable travel.

+ +

+ +

+ +

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APPENDIX 6 – APPRAISAL OF PREFERRED OPTION Table A6.1 - Appraisal of preferred option (draft SPD)

Refer to Table 2.1 for details of topic areas covered .

+ Positive +/- Minor – Negative +++/--- Major 0 Neutral ? Uncertain

Checklist questions SDO Effect Commentary

1 +++ The SPD will encourage to consider the impact of proposals on employment and enterprise from the outset of the process of preparing a development proposal

2 ++ The SPD will help raise awareness of the need to consider the impacts of development on formal education and assess opportunities to incorporate proposals within development which may have benefits for education.

3 ++ The SPD will help raise awareness of issues which affect the determinants of health, such as access to open space, good quality living environments etc.

4 ++ The SPD highlights the importance of ensuring the new development meets secured by design standards.

5 ++ The SPD flags the need to take equalities issues into account. It also introduces guidance on carrying out Equalities Impacts Assessments for EIA scale development.

6 +++ The SPD supports policy in the Southwark Plan and London Plan and should help ensure that energy assessments are prepared in a more consistent and transparent way.

7 +++ The SPD should help ensure that Air Quality Assessments are consistent and that air quality is considered in the preparation of proposals.

8 +++ The SPD provides guidance on how to prepare an operational waste management plan. It also highlights the need to prepare site waste management plans.

9 +++ The SPD reinforces the need to meet Code for Sustainable Homes targets, and to measure water usage against BREEAM tests.

10 ++ The SPD seeks to ensure that land is decontaminated where necessary. 11 ++ The SPD highlights the need to prepare design and access statements. 12 ++ The SPD highlights the need to prepare design and access statements. 13 +++ The SPD reinforces the need to consider open spaces, particularly in areas of deficiency

and incorporates new GLA standards on children’s play space. 14 +++ The SPD provides guidance on how to undertake a flood risk assessments, and

incorporates the recommendations which emerged from the council’s recent strategic flood risk assessment.

15 ++ The SPD highlights UDP policy requirements for affordable housing and the need to provide a good quality living environment.

16 +++ In tandem with the Transport SPD, the draft SPD seeks to enure that transport impacts are mitigated and that proposals support sustainable travel.

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APPENDIX 7 – APPROPRIATE ASSESSMENT

Appropriate Assessment Screening for the draft Sustainability Assessments SPD

May 2008

42

CONTENTS

1 Introduction 88

2 The Need for Appropriate Assessment 89

3 Identifying Likely Significant Effects 90

4 Methodology 91

5 Identification of Relevant Sites 92

6 Analysis of the draft Sustainability Assessment SPD for potential adverse 96 impacts

7 Screening analysis of the draft Sustainability Assessment SPD 98

8 Conclusion 100

References 101

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1 INTRODUCTION

1.1 This report presents the findings of a screening exercise undertaken to determine whether stages 2 and 3 of the Appropriate Assessment (AA) process are needed for the draft Sustainability Assessment SPD. The council has also undertaken a separate Sustainability Appraisal (incorporating Strategic Environmental Assessment) for the SPD.

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2 The need for Appropriate Assessment (AA)

2.1 In October 2005, the European Court of Justice ruled that appropriate assessment (AA) must be carried out on all planning policy documents in the UK. The purpose of AA of planning policies is to ensure that the protection and integrity of European sites (also known as the Natura 2000 network) is part of the planning process at the regional and local level. It is the responsibility of the Local Planning Authority (LPA) to ensure that the AA process is carried out in accordance with the Habitat Directive which is in force and the amended Habitat Regulations which are yet to come into force.

2.2 The Natura 2000 network is a network of sites which are of exceptional importance in respect of rare, endangered or vulnerable natural habitats and species within the European Community and which must be protected. These sites, which are also referred to as ‘European sites’, consist of Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Offshore Marine Site (OMS). There are no OMS designated at present.

2.3 Draft Guidance1 from the DCLG on Appropriate Assessment2 states that: ‘The purpose of Appropriate Assessment (AA) of land use plans is to ensure that protection of the integrity of ‘European sites’ is a part of the planning process at a regional and local level. The requirement for AA of plans or projects is outlined in Article 6(3) and (4) of the European Communities (1992) Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (“Habitats Directive”).’

2.4 The DCLG guidance summarises the AA process prescribed in Article 6(3) and (4) of the Habitats Directive into three main stages: 1. likely significant effects (AA task 1); 2. appropriate assessment and ascertaining the effect on site integrity (AA task 2); 3. mitigation and alternative solutions (AA task 3); and *imperative reasons of overriding public interest.

2.5 The test to identify whether a plan option is ‘likely to have a significant effect’ on a European site is also referred to as ‘screening’. This determines whether stages 2 and 3 of the AA are required.

2 Planning for the Protection of European Sites: Appropriate Assessment Guidance For Regional Spatial Strategies and Local Development Documents, DCLG, August 2006

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3 Identifying likely significant effects

3.1 Screening for AA will determine if planning policy documents are likely to have a significant effect on the conservation objectives of the Natura sites. This will determine whether stages 2 and 3 of the AA are required. In considering whether the plan policy or site allocation is likely to have a significant effect on a Natura site, it should be noted that a site may be located either within or outside the area covered by the plan as significant effects may be incurred in cases where the area of the plan is some distance away.

3.2 If, following screening, significant adverse impacts are anticipated, a ‘full’ AA considers the potential for impacts in more detail and whether alternative measures can be adopted. If there are no viable alternatives, the planning policy can only be implemented if there are ‘imperative reasons of overriding public interest’.

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4 Methodology

4.1 The legal requirement to undertake AAs is set out in the Habitats Directive. However, there is no standardised method for undertaking an AA. The council has followed the screening method used on the Appropriate Assessment of the Draft Further Alterations to the London Plan by ‘Forum for the Future’. This methodology is based primarily on the draft guidance by Tydesley and Associates prepared for Natural England - 'The Assessment of Regional Spatial Strategies and Sub Regional Strategies under the Provisions of the Habitats Regulations' (2006). Although it has been written for the assessment of Regional Spatial Strategies the council considers that all but two of the criteria this method employs are also suitable for the assessment of local development documents. Using the same methodology also helps ensure consistency between the AAs of regional and local plan making.

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5 Identification of relevant sites

5.1 Using the Joint Nature Conservation Committee (JNCC) website3, and in line with the methodology employed in the AA of Further Alterations to the London Plan, the council identified those Natura 2000 sites within a 10km zone extending from the boundary of the Borough. SACs, SPAs, and RAMSARS were included. European sites were scoped into the study if they occurred either wholly or partially within this geographical area. The council identified that there are no Natura 2000 sites in Southwark. Three sites are partially within 10km of Southwark are set out below:

Identified conservation sites of EC importance Sites at least partially in Southwark None

Sites at least partially within 10km of Southwark Wimbledon Common (SAC)

Richmond Park (SAC)

Lee Valley (SPA)

5.2 The information for these sites concerning the rationale for EU conservation has been taken from the ‘Appropriate Assessment of the Draft Further Alterations to the London Plan’ undertaken by ‘Forum for the Future’ which also includes supplementary information in order to assist in considering the vulnerability of sites to potential adverse impacts. This is presented in the table on the following pages.

3 www.jncc.gov.uk

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Site Description Table This information has been sourced from the Appropriate Assessment Screening report: ‘Draft Further Alterations to the London Plan’, by ‘Forum for the Future’, September 2006. The contents of the table were compiled with reference to the sources listed below, and also informed by consultation with Natural England.

Site name + Designation and code. Obtained from Natural England ‘Natura 2000 Forms’ and RAMSAR forms from the JNCC website.

Qualifying features. Denotes the habitats and species for which the sites have been awarded EU conservation status. It is these qualifying features which the AA must safeguard. Obtained from ‘Natura 2000’ and RAMSAR forms. The qualifying features form the basis of Natural England’s ‘conservation objectives for the European interest on SSSIs’, which were drawn upon for pertinent additional information.

Current condition and threats Information pertaining to the current status of sites, recognised trends, and potential threats. From Natura 2000, RAMSAR, and Conservation Objectives forms.

Result of July 2006 SSSI condition survey Further information on European sites which are also SSSI’s - from Natural England’s 2006 review of SSSI condition.

Key ecosystem factors Denotes general ecological parameters of importance to maintaining site integrity. Summarised from the ‘attributes’ in the Conservation Objectives forms.

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Site Name Designation and code

Habitat Species Current Condition and Threats

Result of July 2006 SSSI condition survey

Key ecosystem factors

Wimbledon SAC To maintain To maintain The site is Area Population Common UK0030301 in

favourable condition the: European dry heath, for which the area is considered to support a significant presence.

Northern Atlantic wet heath with Erica tetralix, for which the area is considered to support a significant presence.

in favourable condition the habitats for the population of: Stag beetle, for which this is one of only 4 known outstanding localities in the UK.

located in an urban area and therefore experiences intensive recreational pressure which can result in damage to the sensitive heathland areas.

Air pollution is also thought to be having an impact on the quality of the heathland habitat.

favourable 40%

Area unfavourable but recovering 59%

size of species Number of old broadleaved trees Population structure of broadleaved trees Condition of old broadleaved trees

– state of decay Quantity and size of fallen broadleaved dead wood Position and degree of exposure of old broadleaved dead trees and stumps. Condition and position of available dead timber.

Richmond SAC To maintain The site is Area Population Park UK0030246 in

favourable condition the habitats for the population of: Stag beetle, for which this is one of only 4 known outstanding

surrounded by urban area and therefore experiences high levels of recreational pressure. This does not directly affect the European interest

favourable 6%

Area unfavourable recovering 8%

Area unfavourable no change 86%

size of species Number of old broadleaved trees Population structure of broadleaved trees Condition of old broadleaved trees

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localities in feature. The – state of the UK. whole site

has been declared an NNR.

decay Quantity and size of fallen broadleaved dead wood Position and degree of exposure of old broadleaved trees and stumps. Condition and position of available dead timber.

Lee Valley SPA UK9012111 RAMSAR UK 11034

To maintain in favourable condition the habitats for the populations of an Annex I species* and populations of migratory bird species**, of European importance with particular reference to: Open water and surrounding marginal habitats.

*bittern ** gadwall shoveler

Under Ramsar criteria 2, the site also supports a nationally scarce plant species and a rare invertebrate.

Most of the site is in favourable condition. There are currently no factors having a significant adverse effect on the site’s ecological character. However, a significant increase in recreational pressure could impact upon wintering wildfowl numbers

There are a number of SSSI’s contained within the Lee Valley Ramsar site of which Walthamstow Reservoirs, Waltham Abbey and Turnford and Cheshunt Pits are 100% favourable. Walthamstow Marshes are 36% favourable and 63% unfavourable but recovering.

Disturbance Extent and distribution of habitat Landscape Landform Vegetation characteristics Water area Water depth Food availability

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6 Analysis of the draft Sustainability Assessment SPD for potential adverse impacts

6.1 The draft Sustainability Assessment SPD has been analysed to assess whether it would be likely to result in significant adverse impacts on European sites. The draft Natural England guidance defines 'likely' as meaning 'probably, not merely a fanciful possibility'. The potentially adverse impacts were screened according to the approach set out in Appendix A and Figure 3 of the guidance. However criteria 2 and 3 were not considered because these are applicable to the assessment of Regional Spatial Strategies not Development Plan Documents.

6.2 A precautionary approach was adopted so that the assessment also considered cumulative impacts therefore all potentially significant adverse impacts were assessed.

Coding used for recording effects / impacts on European Sites (from Tydesley and Associates, 2006, Annex 2)

Coding used for recording effects/impacts on European Sites Reason why policy will have no effect on a European Site 1. The policy will not itself lead to development (e.g. it relates to design or other qualitative criteria for development, or it is not a land use planning policy)

4. Concentration of development in urban areas will not affect European Site and will help to steer development and land use change away from a European Site and associated sensitive areas.

5. The policy will help to steer development away from a European Site and associated sensitive areas, e.g. not developing in areas of flood risk or areas otherwise likely to be affected by climate change.

6. The policy is intended to protect the natural environment, including biodiversity.

7. The policy is intended to conserve or enhance the natural, built or historic environment, and enhancement measures will not be likely to have any effect on a European Site.

Reason why policy could have a potential effect 8. The DPD steers a quantum or type of development towards, or encourages development in, an area that includes a European Site or an area where development may indirectly affect a European Site.

Reason why policy would be likely to have a significant effect 9. The policy makes provision for a quantum, or kind of development that in the location(s) proposed would be likely to have a significant effect on a European Site. The proposal must be subject to appropriate assessment to establish, in light of the site’s conservation objectives, whether it can be ascertained that the proposal would not adversely affect the integrity of the site.

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6.3 Every policy was assessed and the relevant criterion/criteria determined for each. Policies and sites considered likely to have no significant adverse effect on European sites were deemed to require no further AA (stages 2 and 3).

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7 Screening analysis of the draft Sustainability Assessment SPD

7.1 This section considers the draft Sustainability Assessment SPD. Each policy has been assessed against the criteria provided in paragraph 6.2 and adapted from the Appropriate Assessment Screening report: ‘Draft Further Alterations to the London Plan’, Forum for the Future, September 2006 which itself is based on draft guidance prepared by Tydesley and Associates for Natural England titled, ‘The Assessment of Regional Spatial Strategies and Sub Regional Strategies under the Provisions of the Habitats Regulations 2006.’

Policy Analysis

Policy Why policy will have no impact on Natura 2000 sites

Likely to have an impact

Essential recommendations to avoid potential negative effects on European sites

SPD Part 1 1 No None Checklist: social sustainability

1 No None

Checklist: economic sustainability

1 No None

Checklist: environmental sustainability

1 No None

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8 Conclusion

8.1 None of the policies in the draft SPD were found likely to have any significant discernible adverse impact on European sites therefore task 2 (appropriate assessment and ascertaining the effect on site integrity) and task 3 (mitigation and alternative solutions) of the Appropriate Assessment process not considered necessary.

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References

Appropriate Assessment Screening report: ‘Draft Further Alterations to the London Plan’, Forum for the Future, September 2006.

Planning for the Protection of European Sites: Appropriate Assessment Guidance For Regional Spatial Strategies and Local Development Documents, DCLG, August 2006.

The Conservation (Natural Habitats, &c.) (Amendment) (England and Wales) Regulations 2006 Consultation Document, DEFRA 2006.

Tyldesley and Associates - prepared for Natural England Draft Guidance - The Assessment of Regional Spatial Strategies and Sub Regional Strategies under the Provisions of the Habitats Regulations 2006.

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APPENDIX 9 GLOSSARY

Air Quality Management Area (AQMA) An area designated for action where it is predicted that the Air Quality Objectives in the Council’s AQMA Plan will be exceeded.

Archaeological Priority Zones The boundaries of Archaeological Priority Zones are designated on the Proposals Map. These are areas where there is potential for significant archaeological remains, and planning applications within these areas must accompanied by an archaeological assessment and evaluation of the site, including the impact of the proposed development.

Biodiversity The diversity or variety of plants and animals and other living things in a particular area or region. It encompasses landscape diversity, eco-system diversity, species diversity, habitat diversity and genetic diversity.

Conservation Areas An area of special architectural or historic interest designated by the local planning authority under the provisions of the Planning (Listed Buildings and Conservation areas) Act 1990, the character or appearance of which it is desirable to preserve or enhance.

Greenhouse gases are those gases that contribute to climate change. In the UK, the most common greenhouse gas is carbon dioxide, which contributed around 77% of the UK’s total emissions of greenhouses gases in 1990. Other greenhouse gases are methane (12% of total UK emissions), nitrous oxide (9%) and fluorinated gases (2.4%).

Local development framework (LDF) is a portfolio of local development documents, which will provide the framework for delivering the spatial planning strategy for the area.

London Plan A strategic plan for the whole of London produced by the Mayor of London. The main purpose of the London Plan is to ensure that all the individual plans produced by the London boroughs work together to meet the priorities that are agreed for the whole London region. The Local Development Framework cannot contain strategies or policies that are not in general conformity with the London Plan.

Proposals maps illustrate the geographical extent of planning policies and designations

Regional Spatial Strategy (RSS) is a spatial framework for a region over a 15 to 20 year period including policies for housing, environmental protection, transport and waste management. The London Plan is the Regional Spatial Strategy that Southwark Plan Policies should be consistent with.

Renewable Energy Energy derived from a source which is continually replenished, such as wind, wave, solar, hydroelectric and energy from plant material. Although not strictly renewable, geothermal energy is generally included.

Renewable Sources See “Renewable Energy”

Supplementary Planning Documents (SPD) or Guidance (SPG) Guidance notes, additional and supplementary to the Unitary Development Plan, on how to implement

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the policies. They also contain background information applicants may find useful when preparing their planning applications.

Sustainability Appraisal/ Strategic Environmental Assessment A systematic and interactive process undertaken during the preparation of a plan or strategy, which identifies and reports on the extent to which the implementation of the plan or strategy would achieve environmental, economic and social objectives by which sustainable development can be defined, in order that the performance of the strategy and policies is improved.

Sustainable Development Development that contributes towards the principles of sustainabililty. That is, development that does not cause environmental damage, contributes to the local economy and meets the needs of the local community.

Unitary Development Plans (UDPs) Statutory plans produced by each borough which integrate strategic and local planning responsibilities through policies and proposals for the development and use of land in their area.

Southwark Plan See “Unitary Development Plans”

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