Babergh Core Strategy Sustainability Statement – February 2014 1

Babergh Core Strategy Sustainability Statement

Regulation 16 of the Environmental Assessment of Plans and Programmes Regulations, 2004

This Sustainability Statement is prepared in accordance with Regulation 16 of the
Environmental Assessment of Plans and Programmes Regulations , 2004. It
effectively tells the story of the Sustainability Appraisal environmental assessment
process and its relationship with the Babergh Core Strategy and is required upon
adoption of the document.

The statement is published following the adoption of the Babergh Local Plan
2011-2031 Part 1 – Core Strategy Development Plan Document on 25
th
February
2014.

The Plan and accompanying relevant documents are available to view at:

The Babergh District Council Office, Corks Lane, Hadleigh, Suffolk, IP7 6SJ

Background and context

A Sustainability Appraisal (SA) must be carried out for all Development Plan
Documents (DPDs). Section 19 of the Planning & Compulsory Purchase Act, 2004
(‘the 2004 Act’) requires that local authorities carry out SA which also comprises the
Strategic Environmental Assessment (SEA) required by European Directive
2001/42/EC and implementing regulations in England and Wales. Any further
reference to SA in this statement should be assumed to incorporate SEA
simultaneously. SA is an iterative process which assesses DPDs against
sustainability criteria covering social, economic and environmental objectives. SA
helps Local Planning Authorities (LPAs) identify the relevant predicted performance
of reasonable options and policies and evaluate which are the most sustainable. The
SA process has a key role in assisting the decision making process for DPD
production.

The Babergh Core Strategy and Development Management Policies document has
been prepared under the 2004 Act and will form the statutory development plan for
Babergh District. When work commenced on the plan, the 2004 Act required it to be
in general conformity with the adopted East of England Plan, the regional spatial
strategy for the area. In order to localise the planning system, section 109 of the
Localism Act provided for the abolition of the regional planning tier. The East of
England Plan was abolished on 3
rd
January 2013.

In developing local plans, local planning authorities must have regard to national
policies and advice contained in guidance issued by the Secretary of State for
Communities and Local Government. Significantly, during the Core Strategy
production process, the National Planning Policy Framework (NPPF) represented a
substantial change and was published in March 2012. This sets out the
Government’s planning policies for England and provides a framework within which
local communities can produce their own distinctive local and neighbourhood plans
reflective of the needs and priorities of their communities. Local planning authorities
will continue to determine the quantum and location of development, albeit without

Babergh Core Strategy Sustainability Statement – February 2014 2

the additional tier of regional direction. It includes Government’s expectation for
planning strategically across local boundaries and within that role of the planning
system in protecting the environment.

In addition, local councils need to comply with existing national and European
legislation in preparing their plans and the duty to co-operate, introduced in section
33A of the Act 2004 with effect from 15th November 2011, in order for their plan to
be found sound at examination.

Core Strategy Policies

The Core Strategy sets out the vision for Babergh to 2031. It shows how this strategy
has been developed to respond to the vision for Babergh and how it will be delivered
by working in partnership with everyone with an interest in the future of the district. It
covers the entire district of Babergh.

The production of the Core Strategy involved 5 formal consultation stages where the
public has had an input into the preferred policy approach taken. The SA process
has also been iterative as the Core Strategy has evolved. Due to the nature of the
district, it has also been necessary to carry out the relevant stages of a Habitats
Regulations Assessment (HRA) in accordance with Regulation 61 of the
Conservation of Habitats and Species Regulations 2010. The key stages of the Core
Strategy, SA and HRA document production are set out in Table 01 below.

Table 01 – key consultation stages in Core Strategy / SA / HRA production

September 2009

SA Scoping Report.
April – June 2009

“Core Strategy Issues & Options Report” & accompanying
SA document.

October – November
2010

“Core Strategy The Future Growth of Babergh
District to 2031” [Summer 2010] document and
accompanying SA [June 2010] document.

October – December
2011
“Core Strategy (2011- 2031) Submission Draft” document &
accompanying SA [September 2011] and HRA Screening
[September 2011] documents.

July – August 2012 “Schedule of Proposed Main Modifications to Core Strategy
(2011 – 2031) Submission Draft [July 2012] document” &
accompanying SA and HRA [June 2012] addendum
document.

May – July 2013 “Schedule of further Main Modifications to the Babergh
Core Strategy (2011 – 2031)” [April 2013] document &
accompanying SA addendum and HRA review [May 2013]
document.

Babergh Core Strategy Sustainability Statement – February 2014 3

The Submission draft Core Strategy was consulted upon in October 2011. A number
of proposed main modifications to the Submission draft Core Strategy were made
thereafter, and again consulted upon in July 2012 prior to Submission in November
2012. The proposed modifications (July 2012) can be viewed on the Council website
at: http://www.babergh.gov.uk/Babergh/CoreStrategy

The starting point for the Examination was the composite Core Strategy
(incorporating all modifications up to November 2012), and all subsequent comments
and modifications were taken into account by the Inspector through the Examination.

The final Inspector’s Report, including Main Modifications, can be viewed on the
Council’s website at: http://www.babergh.gov.uk/Babergh/CoreStrategy

Purpose of the Sustainability Statement

Babergh District Council adopted the Babergh Local Plan 2011-2031, Part 1 – Core
Strategy (the ‘Core Strategy’) on 25th February 2014. In accordance with Article 9 of
the Strategic Environmental Assessment Directive 2001, Regulation 36 of the Town
and Country Planning (Local Development) (England) Regulations 2004 and
Regulation 16 of the Environmental Assessment of Plans and Programmes
Regulations 2004, the District Council has prepared this statement that sets out:

(i) How environmental and sustainability considerations have been integrated
into the Core Strategy
(ii) How the environmental reports (sustainability appraisals) have been taken
into account
(iii) How opinions expressed during the consultation on the draft plan and
environmental reports have been taken into account within the plan as
adopted
(iv) The reasons for choosing the plan as adopted, in the light of the other
reasonable alternatives considered
(v) Measures that are to be taken to monitor the significant environmental
effects of the implementation of the plan.

The purpose of this Post Adoption Statement is to provide specific information
outlined under each of the points listed above and which is presented in the following
sections of this statement.

(i) How environmental and sustainability considerations have been integrated
into the Core Strategy

From the outset of the Core Strategy process, the Council has sought to gather
relevant baseline information regarding the social, economic and environmental
characteristics of the district. This was collected for the SA Scoping Reports and the
profile of information was used to inform the context for developing Objectives and
Policies within the Core Strategy document. The key characteristics and issues in
the district are also set out in section 1.3 of the Core Strategy and sections 4 and 5
of the SA documents. The key objective principles were established early in the
process in the Issues & Options Core Strategy, (section 3) and were developed into
the final 8 strategic objectives in the adopted Core Strategy (section 1.6). The Core

Babergh Core Strategy Sustainability Statement – February 2014 4

Strategy strategic objectives were tested against the SA objectives in order to ensure
they were generally consistent with sustainable development (see section 7 of SA
documents).

Each policy option was subsequently developed from the strategic objectives and the
reasonable alternatives were also subject to SA analysis. The SA has been used to
guide and inform the decision making process when developing the Core Strategy,
and has been considered by decision makers and members of the public. Regard
has been had to the NPPF, published in March 2012, which requires (para 14) that
local authorities ensure that the local plan is consistent with the ‘presumption in
favour of sustainable development’.

The adopted Core Strategy also includes two key policies ensuring that sustainable
development is at the heart of the plan – policy CS1: Applying the Presumption in
favour of Sustainable Development in Babergh, and policy CS15: Implementing
Sustainable Development in Babergh. The policies have been subject to SA which
confirms that they will help to ensure an overall positive environmental outcome.

(ii) How the environmental reports (sustainability appraisals) have been taken
into account

Table 01 above sets out the major stages of Core Strategy document production and
indicates the key accompanying SA and HRA iterations. Decision makers have
considered these documents during the production process as well as comments
obtained from public consultation. A detailed report setting out how consultation
comments have been taken into account is contained in the Council’s Core Strategy
Consultation Statement (September 2012).

The Council identified and considered the reasonable alternative policy options in
2009. The SA process has helped to refine the Core Strategy policies, including the
main modifications prior to adoption in 2014 and has therefore improved the
sustainability of the plan. The SA produced a number of recommendations and
mitigation requirements throughout the process and, where relevant, these have
been incorporated into the Core Strategy iterations. Other SA recommendations will
be pursued when looking at more detailed development plan documents.

(iii) How opinions expressed during the consultation on the draft plan and
environmental reports have been taken into account within the plan as
adopted

At each major stage in the production of the Core Strategy, consultation on the
relevant documents (see Table 01 above) has been undertaken with the statutory
and other specific consultation bodies. In addition, other organisations and
community groups known to be active within the district and anyone who had
previously contacted the Council requesting that they be kept informed of progress
on the Local Plan were also notified. This has been carried out in accordance with
the Council’s Statement of Community Involvement.

The process has been iterative and all comments provided have been considered. A
detailed report setting out how consultation comments have been taken into account

Babergh Core Strategy Sustainability Statement – February 2014 5

is contained in the Council’s Core Strategy Consultation Statement (September
2012). Comments made during 2009 – 2010 were considered by the Council during
the informal early plan production stages. Comments made on the Submission
version documents, (2011) and thereafter, were considered by the Planning
Inspector examining the Core Strategy.

(iv) The reasons for choosing the plan as adopted, in the light of the other
reasonable alternatives considered

The Council identified and consulted upon the reasonable alternatives in 2009, and
subsequently, further reasonable alternatives in 2010 resulting from the proposed
revocation of the East of England Plan.

As part of the iterative process, each policy / option was tested in the relevant SA
report for their likely performance in relation to sustainable development. The
policies were considered against the SA Framework objectives and the respective
advantages and disadvantages presented. This analysis helped to guide and inform
the decision making process and to select the most appropriate overall policy
framework for the Babergh district.

(v) Measures that are to be taken to monitor the significant environmental
effects of the implementation of the plan.

Most policies will require collaborative working between a wide range of bodies,
including: infrastructure providers, developers, service providers, government
agencies, parish and town councils. The Core Strategy contains a Delivery and
Monitoring Framework. It sets out a summary of what the intended outcomes are for
each policy, how they may be delivered, by whom and when. In addition it broadly
identifies the indicators for success, the risks, flexibilities and contingencies, in the
event that monitoring of these point to a failure to deliver.

The SA has also set out a series of monitoring recommendations in order to
measure any significant social, economic and environmental effects after the Core
Strategy adoption. This will allow the identification of any unforeseen adverse effects
and enable appropriate remedial action to be taken.

The Annual Monitoring Report process will be used to satisfy the relevant monitoring
recommendations and will normally collect and report data annually for the period
between 1
st
April and 31
st
March.