Appendix B – Sustainability Appraisal (SA) of Housing Target

1.0 SA Introduction

1.1 The Planning and Compulsory Purchase Act 2004 requires Sustainability Appraisal (SA) to be undertaken in the preparation of the Local Development Documents making up the Local Development Framework (LDF). The purpose of the SA process is to ensure that plans and policies take into account the principles of Sustainable Development, and that the impact of these on defined social, environmental and economic objectives is fully considered.

1.2 This document is the Sustainability Appraisal of the amended housing target for inclusion in the Core Strategy. It sits alongside the proposed target on housing provision, details of which are provided in Appendix A of this document.

1.3 The LDF SA Framework was used to appraise the revised target. This is available to view or download from http://gov.uk/ldf/resources.aspx#sus

1.4 A full SA report will accompany the proposed submission version of the Core Strategy, due for publication during December 2011 – January 2012.

(2)2.0 Sustainability Appraisal (SA) of Scenarios

2.1 This paper assesses the sustainability effects of the 3 scenarios for housing provision set out in Appendix A. These options are:

Scenario 1 – High Growth: 7,840 net new dwellings (461 per annum) up to 2028
Scenario 2 – Lower Growth: 2,478 net new dwellings (146 per annum) up to 2028
Scenario 3 – Medium Growth: 3,418 net new dwellings (201 per annum) up to 2028

2.2 The appraisal uses the existing sustainability appraisal framework set out in the Revised Scoping Report, which provides a way in which the sustainability effects of each scenario can be described, analysed and compared.

2.3 Each scenario has been scored according to its impact on the sustainability of the town, using the following criteria:

Table 1: Sustainability criteria

Score	Effect
XX	The option will have a significant negative effect on the sustainability objective
X	The option will have a slight negative effect on the sustainability objective
?	The impact can not be predicted at this stage - potential/uncertain effect
-	No effect/direct link at this stage
	The option will have a slight positive effect on the sustainability objective
	The option will have a significant positive effect on the sustainability objective

2.4 They have also been assessed and scored against the short, medium and long term. The definitions used are as follows:

Short term (S) – 0-5 years
Medium term (M) – 5-15 years
Long term (L) – 15+ years

(3)2.5 The findings of the assessment are shown in table 2 below.

Table 2 – Sustainability appraisal of housing scenarios

Sustainability Objective		Scenario 1 - High Growth		Scenario 2 - Lower Growth		Scenario 3 - Medium Growth
		7,840 net new dwellings (461 per annum) up to 2028		2,478 net new dwellings (146 per annum) up to 2028		3,418 net new dwellings (201 per annum) up to 2028
		Effect	Comments	Effect	Comments	Effect	Comments
1. More opportunities are provided for everyone to live in a decent, sustainably constructed and affordable home	S		The link between house building and affordable housing provision will lead to more opportunities being provided. This option will provide the most opportunities.		The link between house building and affordable housing provision will lead to more opportunities being provided.		The link between house building and affordable housing provision will lead to more opportunities being provided.
	M
	L
2. The health and well-being of the population is improved and inequalities in health are reduced	S	/?	Health and well being may improve if there are more opportunities for everyone to live in a decent home. This option will enable more affordable housing to be targeted at those in greatest need.	?	Health and well being may improve if there are more opportunities for everyone to live in a decent home.	?	Health and well being may improve if there are more opportunities for everyone to live in a decent home.
	M	/?		?		?
	L	/?		?		?
3. Levels of poverty and social exclusion are reduced and the deprivation gap is closed between the more deprived areas in Hastings and the rest of the town	S		May result in a more mixed community and greater investment in deprived areas		May result in a more mixed community and greater investment in deprived areas		May result in a more mixed community and greater investment in deprived areas
	M
	L
4. Education and skills of the population improve	S	-	No direct link	-	No direct link	-	No direct link
	M	-		-		-
	L	-		-		-
5. All sectors of the community have improved accessibility to services, facilities, jobs, and social, cultural and recreational opportunities	S	?	New housing does not have a direct link to accessibility. However, this level of growth will create significant demand but does not necessarily provide for improved accessibility. Impact will depend on levels of social infrastructure provided with new development.	?	New housing does not have a direct link to accessibility. However, this level of growth will create significant demand but does not necessarily provide for improved accessibility. Impact will depend on levels of social infrastructure provided with new development.	?	New housing does not have a direct link to accessibility. However, this level of growth will create significant demand but does not necessarily provide for improved accessibility. Impact will depend on levels of social infrastructure provided with new development.
	M	?		?		?
	L	?		?		?
6. Safe and secure environments are created and there is a reduction in crime and the fear of crime	S	-	No direct link, although design policies should incorporate 'Secure By Design Principles' for larger developments	-	No direct link, although design policies should incorporate 'Secure By Design Principles' for larger developments	-	No direct link, although design policies should incorporate 'Secure By Design Principles' for larger developments
	M	-		-		-
	L	-		-		-
7. Vibrant and locally distinctive communities are created and sustained	S	-	No direct link - dependent on design policies and type/mix of housing	-	No direct link - dependent on design policies and type/mix of housing	-	No direct link - dependent on design policies and type/mix of housing
	M	-		-		-
	L	-		-		-
8. Land and buildings are used more efficiently and urban renaissance encouraged	S		Will encourage the re-use of existing buildings and more efficient use of land through higher density development, although also dependent on location and type of new development. This option is likely to do this to the highest extent. This scenario will increase the pressure to build on more Greenfield land and in environmentally sensitive areas.		Will encourage the re-use of existing buildings and more efficient use of land through higher density development, although also dependent on location and type of new development.		Will encourage the re-use of existing buildings and more efficient use of land through higher density development, although also dependent on location and type of new development.
	M
	L
9. Biodiversity is protected, conserved and enhanced	S	X	Higher levels of development likely to have greater impact on biodiversity, as it will involve development of a greater number of sites, likely to comprise significant Greenfield development. Will need to encourage development in built up area first, although still has potential for effect on biodiversity. Require mitigation through policy.	?	Still potential for impact on biodiversity - require mitigation through policy	?/X	Higher levels of development likely to have greater impact on biodiversity, as it will involve development of a greater number of sites. Encourage development in built up area first, although still has potential for effect on biodiversity. Require mitigation through policy
	M	X		?		?/X
	L	X		?		X
10. The risk of flooding (fluvial & tidal) and coastal erosion is managed and reduced now and in the future	S	?/X	Risk mainly dependent on location of development. However, high levels of development more likely to increase flood risk from surface water run-off, regardless of mitigation measures.	?	Mitigation measures to reduce surface water run-off etc, and development located away from areas of risk - Use of Strategic Flood Risk Assessment (SFRA) and sequential test	?	Mitigation measures to reduce surface water run-off etc, and development located away from areas of risk - Use of Strategic Flood Risk Assessment (SFRA) and sequential test
	M	?/X		?		?
	L	?/X		?		?
11. Parks and gardens, countryside, coast and the historic environment/ townscape and landscape are protected, enhanced and made more accessible	S	X	May result in more pressure for development in these areas. An increasing population may also result in increased use of these areas	X	May result in more pressure for development in these areas. An increasing population may also result in increased use of these areas	X	May result in more pressure for development in these areas. An increasing population may also result in increased use of these areas
	M	X		X		X
	L	X		X		X
12. Air pollution is reduced and air quality continues to improve	S	X	Construction of greater numbers of housing is likely to contribute to pollution. This option likely to have the most negative effect, particularly over longer term. Mitigate through other policy e.g. low emission development	X	Construction of greater numbers of housing is likely to contribute to pollution. Mitigate through other policy e.g. low emission development	X	Construction of greater numbers of housing is likely to contribute to pollution. Mitigate through other policy e.g. low emission development
	M	X		X		X
	L	XX		X		X
13. The causes of climate change are addressed through reducing emissions of greenhouse gases (mitigation) and ensuring the Borough is prepared for its impacts (adaptation)	S	X	All new development will result in additional pressure on resources, including water and energy. The greater number of homes will mean the most significant effect. However, locating development in accessible locations and ensuring sustainable design through design briefs will help to mitigate this.	X	All new development will result in additional pressure on resources, including water and energy. The greater number of homes will mean the most significant effect. However, locating development in accessible locations and ensuring sustainable design through design briefs will help to mitigate this.	X	All new development will result in additional pressure on resources, including water and energy. The greater number of homes will mean the most significant effect. However, locating development in accessible locations and ensuring sustainable design through design briefs will help to mitigate this.
	M	XX		X		X
	L	XX		X		XX
14. Water quality of freshwater bodies, waterways and the marine environment is maintained and improved and water consumption is reduced	S	X	More homes may lead to greater amounts of sewage, waste water and increased levels of water consumption. Mitigation as above.	X	More homes may lead to greater amounts of sewage, waste water and increased levels of water consumption. Mitigation as above.	X	More homes may lead to greater amounts of sewage, waste water and increased levels of water consumption. Mitigation as above.
	M	X		X		X
	L	X		X		X
15. Energy efficiency is increased, fuel poverty is reduced and the proportion of energy generated from renewable resources is increased	S		Higher levels of development will provide more opportunities for on site renewable energy generation and could facilitate stand alone schemes		All development will provide further opportunities for on site energy generation, although scenarios 2 and 3 to a lesser extent due to fewer housing numbers		All development will provide further opportunities for on site energy generation, although scenarios 2 and 3 to a lesser extent due to fewer housing numbers
	M
	L
16. Through waste re-use, recycling and minimisation the amount of waste for disposal is reduced	S	X	Construction of more dwellings is likely to result in an overall increase in the amount of waste. As this option provides the most housing, it is likely to have the most significant effect over the long term.	X	Construction of more dwellings is likely to result in an overall increase in the amount of waste.	X	Construction of more dwellings is likely to result in an overall increase in the amount of waste.
	M	X		X		X
	L	XX		X		X
17. Road congestion and pollution levels are reduced, and there is less car dependency and greater travel choice	S	/X	Higher levels of development will result in increased car use and congestion. However, new housing development could generate further sustainable transport options, depending on its size and location.	/X	Higher levels of development will result in increased car use and congestion. However, new housing development could generate further sustainable transport options, depending on its size and location.	/X	Higher levels of development will result in increased car use and congestion. However, new housing development could generate further sustainable transport options, depending on its size and location.
	M	/X		/X		/X
	L	/X		/X		/X
18. There are high and stable levels of employment and rewarding and satisfying employment opportunities for all	S	-	No direct link	-	No direct link	-	No direct link
	M	-		-		-
	L	-		-		-
19. Economic revival in the more deprived areas of the town is stimulated and successfully achieved	S		More better quality housing in these areas may increase business and investor confidence		More better quality housing in these areas may increase business and investor confidence		More better quality housing in these areas may increase business and investor confidence
	M
	L
20. The sustained economic growth of the borough is achieved and linked closely to social regeneration	S	/?	The provision of good quality housing may encourage more skilled workers to the area. In turn, this could attract business and investment, resulting in an expanding workforce and business growth. However, it could also lead to unsustainable levels of out-commuting.	/?	The provision of good quality housing to meet this option will still attract skilled workers, although it may not maintain a big enough workforce to attract new business or support existing growth		The provision of good quality housing may encourage more skilled workers to the area. In turn, this could attract business and investment. This level of growth is unlikely to have such an effect that could lead to significant out-commuting.
	M	/?		/?
	L	/?		/?
21. Indigenous and inward investment is encouraged and accommodated	S	/?	This option will not make more land available for employment related uses, but the provision of good quality homes could attract further investment to the area.	/?	This option will not make more land available for employment related uses, but the provision of good quality homes could attract further investment to the area.	/?	This option will not make more land available for employment related uses, but the provision of good quality homes could attract further investment to the area.
	M	/?		/?		/?
	L	/?		/?		/?

(2)3.0 SA - Analysis of Scenarios

Scenario 1

3.1 Scenario 1 provides for the highest number of new homes – an additional 7,840 new dwellings up to 2028 (461 per annum), based on population growth. This exceeds the former South East Plan target of 4,200 dwellings up to 2026.

3.2 Work on the Strategic Housing Land Availability Assessment (SHLAA) has indicated that this level of development cannot be accommodated on sites currently available within the town.

3.3 Performance against the social objectives is broadly positive as the provision of this level of housing will meet identified housing need and maximise the opportunity to provide affordable housing in the town. However, creating this volume of new housing will undoubtedly put significant pressure on the town’s existing services, including health provision, and the likely impact is heavily dependent on the scale, design and location of developments that will take place, as well as adequate provision of supporting infrastructure.

(1)3.4 The effect of Scenario 1 on the environmental objectives is inevitably negative as such quantities of development result in potentially significant impacts on the towns natural resources, including biodiversity, water and energy, as well as contributing to increased congestion, air pollution and waste. In addition, this option could result in a significantly increased risk of flooding from surface water run-off, despite mitigation measures and locating development away from high risk areas.

3.5 New development on this scale will, however, provide the most opportunities for on-site renewable energy generation. It will also increase the likelihood of viable standalone schemes and the provision of sustainable transport options to serve larger developments.

3.6 Whilst the Future Housing Provision in Hastings paper is not concerned with the provision of new employment floorspace, there is a relationship between the provision of good quality housing, and the retention and attraction of skilled workers to the area, which will support existing businesses, and could in turn encourage additional businesses and investment. The provision of this number of new homes will positively affect this, but also poses the risk of increasing out commuting, since population growth is likely to outstrip the growth in job opportunities locally, leading to uncertain effect in terms of the sustainability objectives.

(5)Scenario 2

3.7 This scenario proposes the fewest dwellings up to 2028 – 2,478 (net), which amounts to 146 per annum. This figure is based on existing allocations and planning permissions, and would not necessarily involve the allocation of any new sites.

3.8 Performance against the social objectives is positive as it still provides housing that will contribute to the towns housing needs. However, of the 3 scenarios, this level of housing development will make the smallest contribution to meeting both the demand for general market housing and identified affordable housing needs, as it proposes the fewest dwellings.

(1)3.9 Any level of development has a negative effect on the environmental objectives as a whole, due to the impact on the town’s resources and the increase in congestion, pollution and waste. However, as this scenario provides the fewest number of dwellings, the negative effects are the least in comparison. Providing fewer dwellings will also reduce the ability to generate as much on site renewable energy, or support stand alone schemes. The risk of surface water flooding still remains, although fewer dwellings should have a lesser effect.

(1)3.10 The provision of good quality housing to meet this scenario will still help to attract and retain skilled workers to the area, having a positive effect on the employment related objectives, but to a lesser degree than scenarios 1 and 3. As this scenario will provide the fewest new homes, it is expected to result in a smaller workforce, reducing the town’s ability to attract new business or support existing growth.

(1)Scenario 3

3.11 Scenario 3 is broadly based on the level of new homes previously required by the South East Plan. The SHLAA has indicated that the majority of these homes can be accommodated on identifiable sites in the town, although some windfall allowance would still be needed. This scenario therefore, provides for a greater certainty of delivery between now and 2028.

3.12 Scenario 3 performs positively against social objectives as it also supports the provision of new homes to meet housing need, including affordable homes. However, owing to capacity issues the full identified need for affordable homes cannot be met. Development to this level will put pressure on existing services, although to a lesser extent than scenario 1.

3.13 The effect on environmental objectives is generally negative due to the impact of development on the town’s resources and the increase in congestion, pollution and waste. However, as research has suggested that this level of development can be accommodated on sites already assessed through the SHLAA, providing suitable mitigation measures are provided, the effect on the environment is likely to be less than it would be for scenario 1.

3.14Scenario 3 performs more positively against the economic objectives, as it is expected that pursuing this level of housing growth will help support the wider regeneration agenda. Both the quantity and mix of new homes within Hastings will be important to the local economy in terms of (i) existing businesses and their ability to attract employees; and (ii) new businesses setting up or locating in the town. The right type of housing may help to retain/attract more skilled workers to the town. A more skilled workforce should enhance the ability of Hastings to attract mobile business investment and thus contribute to economic development. Unlike scenario 1, this level of development is unlikely to have such an effect that could lead to significant unsustainable levels of out commuting.

4.0 SA - Conclusion and Recommendations

4.1 Analysis of these scenarios has shown that scenario 1 whilst providing the most new homes scores poorly in meeting environmental objectives. Scenario 3, and scenario 2 have broadly similar impacts – the main difference being that scenario 2 (the lowest amount of housing) will not provide as many opportunities for everyone to have access to a decent home. Whilst scenario 3 (medium growth) may achieve slightly more in terms of stimulating economic revival in the more deprived parts on the town; and will go further in meeting housing need.

(2)4.2 Given the regeneration vision of the Plan, scenario 3 is the preferred way forward. Mitigation measures for this level of development will be achieved through policies in the Core Strategy which aim to protect the environment, ensure good design and provide the necessary infrastructure to support development.