Sustainability Appraisal of the Revised Proposed Submission Development Management Plan

Ended on the 22 April 2014

4.0 Stage 2 - Sustainability Appraisal

Overall assessment results

4.1 This section of the report summarises the outcomes of the appraisal of those significant changes to the Development Management Plan that were identified as requiring further assessment.

4.2 The full and detailed matrices of the assessment are shown in Appendix C, although a summary of outcomes and potential effects is provided in the tables below. The assessment matrices are split into two sections. The first set provide the sustainability appraisal of the policy elements of the significant changes, followed by a more specific ‘sites’ assessment, which uses the same criteria as shown in the earlier Sustainability Appraisal Report (November 2012). Specifically, the sites assessment looks at the impact on the sustainability objectives in respect of the following headline issues:

Proximity to a district or local centre
Proximity to outdoor facilities and open space
Supporting regeneration
Supporting a shift to more sustainable modes of travel
Protecting the historic environment
Protecting the natural environment
Making the best use of natural resources
Avoiding flood risk

4.3 Appendix D provides an extract from earlier Sustainability Appraisal Report by URS that explains the decision rules associated with these criteria in more detail. For the purposes of this sites assessment (and to ensure completeness), we have also looked at the following issues under the “protecting the natural environment” header, that weren’t included in the original Sustainability Appraisal report. These are:

Proximity to Local Nature Reserves
Proximity to Ancient Woodland

4.4 Local Green Spaces are now also included under the Proximity to Open Space criteria (as shown in Appendix D).

Summary assessment results

4.5 Table 5 below provides a summary of the full sustainability appraisal undertaken in respect of the significant policy changes. No negative sustainability effects were recorded during the appraisal of the significant changes, and where additions to policies are proposed; these either enhanced the original policies in sustainability terms, or had the same results.

4.6 This is followed by table 6, which provides a summary of the detailed sites assessment. It highlights potential significant effects as highlighted by the Sustainability Appraisal, and shows whether these have been addressed in the Revised Submission Development Management Plan. The assessment shows that in all cases, the site specific issues raised by the appraisal are addressed in the individual site policies, providing mitigation measures were appropriate.

SA ref	Significant change	Summary of potential sustainability effects	Is this the preferred alternative in SA terms?
RSD/2	New policy LP1 and supporting text	Results in positive sustainability effects, with some uncertainty over whether seeking to encourage the submission of planning applications that take account of all other policies in the plan will minimise delays in the planning system and to help to bring forward higher levels of development overall	Yes
RSD/3	Amendments to Policy DM1 and supporting text	Limited sustainability effects. The minor amendments proposed provide additional protection to heritage, landscape and visual amenity, resulting in a positive effect on this objective	Yes
RSD/4	Amendments to Policy DM2 and supporting text	Results in additional positive sustainability effects in respect of efficient use of land, and protecting greenspaces, historic environment/ townscape and landscape	Yes
RSD/6	Amendments to policy DM3	A new criterion highlights the issue of safety and amenity, together with issues associated with location of development. Results in some additional positive sustainability effects in terms of health and well being and creating safe and secure environments	Yes
RSD/8	Amendments to Policy DM4	New criteria considering safety in terms of access requirements and need for transport assessments results in additional positive sustainability effects when compared against the alternative, in respect of improving travel choice, reducing reliance on the car, and creating safe and secure environments	Yes
RSD/10	New paragraph highlighting importance of water quality	The new text results in only limited sustainability effects. Only one additional positive effect recorded in respect of minimising water pollution, although the lack of policy weight means that this is also uncertain	Yes
RSD/13	Amendment to Policy HC1 and supporting text	The proposed amendments result in an additional positive sustainability effect as a result of recognising the importance of heritage assets in the policy text, and have the potential for a positive effect in terms of ensuring an appropriate dwelling mix in the locality, although this is recorded as having some uncertainty.	Yes
RSD/14	Amendment to Policy HC2 and supporting text	These are minor amendments that are more for clarification purposes and as such, result in very limited sustainability effects. There is the potential for positive effects in terms of creating vibrant and distinctive communities.	Yes
RSD/16	Amendment to Policy HN2 and supporting text	The inclusion of roofs within policy context results in positive sustainability effects, although they are not additional to that in the original policy, in respect of the remaining sustainability objectives	Yes
RSD/19	Re-drafted policy HN7 and supporting text	This more comprehensive green infrastructure policy results in significant positive sustainability effects, particularly in terms of environmental objectives. The amended text also scores positively in terms of health and well being and access to services	Yes
RSD/20	New policy HN8 and supporting text	Including a specific policy on green space and biodiversity results in significant positive sustainability effects, particularly in terms of environmental objectives. It also scores positively in terms of health and well being and access to services	Yes
RSD/21	New Policy HN9 supporting text	The new policy relating to areas of landscape value results in some positive sustainability effects, most particularly in terms of protecting landscape and creating locally distinctive communities. No other effect were recorded	Yes
RSD/22	Re-drafted policy HN10 and supporting text	This policy combines earlier policies into one, more general policy that applies to different types of local green spaces. Whilst the appraisal has resulted in several positive sustainability effects, none of these are additional to what was appraised before	Yes
RSD/23	New paragraphs relating to street trading and markets	The promotion of street trading and markets in the town centre results in positive sustainability effects in terms of making the most efficient use of land and creating vibrant communities. Potential for positive effect on economic objectives although some uncertainty on the extent of this given the limited weight of supporting text and the restriction to town centres	Yes
RSD/28	Amendment to Policy CC1 and supporting text	The additional text has resulted in limited sustainability effects. Referring to the need to minimise impact on accessible greenspace positively impacts on objectives relating to the protection of natural environment. There is potential for positive impacts on economic objectives in terms of providing flexibility for the proportion of touring caravans and campervans allowed on a site although some uncertainty over how significant this will be	Yes

Table 5: Summary of significant policy changes – assessment results

Site assessment results

SA ref	Site ref	Site name	Significant constraints	Other potential issues	Have constraints or other issues been reflected in Plan?
RSD/31	LRA10	Land North of Downey Close	Distance to a district or local centre Distance to a cycle route Distance to an amenity footpath Use of previously developed land	Not within the most deprived Super Output Areas	N/A - Given the site size, the distance to a district or local centre is not significant in this instance, and shops are available in the wider Harrow Lane and Little Ridge Area. The distance to amenity footpaths and cycle routes will be considered as part of the wider green infrastructure network. It has been necessary to allocate both greenfield and brownfield sites in the Local Plan, although bringing forward brownfield sites first is still a priority in accordance with the National Planning Policy Framework
RSD/35	GH12	63 Wishing Tree Road North (Former Wishing Tree Public House)	Distance to a district or local centre Distance to an amenity footpath	None	N/A - Given the site size, the distance to a district or local centre is not significant in this instance, and shops are available in nearby Blackman Avenue and the Tesco Superstore. The distance to amenity footpaths will be considered as part of the wider green infrastructure network
RSD/36	GH13	133 Battle Road (Former Tivoli Tavern)	Distance to a cycle route	Distance from a playground	N/A - The distance from a cycle route will be considered as part of the wider green infrastructure network, and the site is still located within 200m of a playground. The site capacity of just 11 units does not justify inclusion of additional play facilities
RSD/37	FB2	Former West St Leonards Primary School	Distance to an amenity footpath Proximity to a Local Wildlife Site Within flood risk zones 2 and 3	Distance to district or local centre Distance from a playground Distance from cycle route Within an area of shallow surface water flood risk, or flood hotspot	Yes. Site requirements now included in policy to address ecological and flood risk (fluvial, tidal and surface) issues, together with the requirements for new green space. The extent of flood risk has now reduced, and as such, the increase in capacity can be adequately accommodated, subject to the necessary Flood Risk Assessment requirements. This has necessitated a decrease in the amount of open space provided, although the proportion is still adequate in relation to the size of the site Please also see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)
RSD/38	FB6	Cinque Ports Way, Former Stamco Timber Yard and TA Centre	Distance to an amenity footpath Proximity to a Local Wildlife Site Within flood risk zone 3 Within area deep surface water flood risk	None	Yes. Site requirements are now included in policy to address ecological and flood risk (fluvial, tidal and surface) issues, together with walking and cycling links to improve accessibility. Reduction in capacity is reflective of reducing the site boundary area. Please also see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)
RSD/40	FB13	Hastings Garden Centre, Bexhill Road	Distance to district/local centre Distance from playground Within flood risk zone 3	Not within the most deprived SOAs Distance to cycle route Within or adjacent an ANA Proximity to Local Wildlife Site Within an area of shallow surface water flood risk, or within Flood Hotspot	Yes. Site requirements are now included in policy to address flood risk (fluvial, tidal and surface) issues, together with acknowledgement of the sites location within an Archaeological Notification Area and adjacent to a Local Wildlife Site. Only a small part of the site is within area of flood risk The distance from a cycle route will be considered as part of the wider green infrastructure network
RSD/41	FB14	Land north of 31 Fern Road	Distance to district/local centre Distance from playground Distance to a cycle route Proximity to a Local Nature Reserve Proximity to a Local Wildlife Site Use of previously developed land	Not within the most deprived SOAs	Yes. Site requirements are now included in policy to address ecological issues. Given the site size, the distance to a district or local centre is not significant in this instance, and shops are available in nearby Fernside Avenue. Similarly, play provision is not required due to the size of the site and other available facilities in the vicinity. The distance to cycle routes will be considered as part of the wider green infrastructure network. It has been necessary to allocate both greenfield and brownfield sites in the Local Plan, although bringing forward brownfield sites first is still a priority in accordance with the National Planning Policy Framework.
RSD/42	FB15	Land north of 14 Fern Road	Distance to district/local centre Distance from playground Distance to a cycle route Use of previously developed land	Not within the most deprived SOAs Proximity to a Local Wildlife Site	Yes. Site requirements are now included in policy to address ecological issues. Given the site size, the distance to a district or local centre is not significant in this instance, and shops are available in nearby Fernside Avenue. Similarly, play provision is not required due to the size of the site and other available facilities in the vicinity. The distance to cycle routes will be considered as part of the wider green infrastructure network. It has been necessary to allocate both greenfield and brownfield sites in the Local Plan, although bringing forward brownfield sites first is still a priority in accordance with the National Planning Policy Framework.
RSD/44	SH3	Hurst Court	Distance to district/local centre Distance from playground Distance to cycle route Distance to amenity footpath	Not within the most deprived SOAs Within or adjacent an Archaeological Notification Area	N/A As part of the original site area has already been developed, the remaining site capacity and site boundary have been reduced. It does not affect the previous appraisal, although the inclusion of site policies does ensure that the site specific requirements such as ecological assessments and a Historic Environment Record will be given more weight Please also see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)
RSD/47	SH7	191 The Ridge	Distance to district/local centre Distance from playground Distance to cycle route Distance to amenity footpath	Not within the most deprived SOAs Distance from open space Within or adjacent an ANA Use previously developed land	N/A – This is a minimal decrease in capacity reflective of a more recent planning consent, and doesn’t affect the previous sustainability appraisal Please see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)
RSD/48	SAP4	347-349 London Road	Distance to amenity footpath	Not within the most deprived SOAs Distance to cycle route	N/A – This is a decrease in capacity reflective of updated planning application, and doesn’t affect the previous sustainability appraisal Please see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)
RSD/50	SAP7	Bilmore Corner, Battle Road	Distance to cycle route	Not within the most deprived SOAs Distance from playground Distance from open space Distance to amenity footpath	N/A - The distance from a cycle route will be considered as part of the wider green infrastructure network. Given the site size and other opportunities in the vicinity, it is not necessary to provide play facilities or additional open space; although it is important to note that the site is still located between 200-400m away from existing facilities
RSD/51	SAP8	4 Wykeham Road	Distance from playground Distance to cycle route Distance to amenity footpath	Not within the most deprived SOAs Distance to district/local centre	N/A - The distance from a cycle route and amenity footpath will be considered as part of the wider green infrastructure network. Given the site size and other facilities in the vicinity, it is not necessary to provide additional play facilities
RSD/55	MBL8	Caple Ne Ferne, 2 Albany Road	Distance to district/local centre Distance from playground Distance to cycle route Distance to amenity footpath	None	N/A - The distance from a cycle route and amenity footpath will be considered as part of the wider green infrastructure network. Given the site size and other facilities in the vicinity, it is not necessary to provide additional play facilities, or additional shops on site
RSD/56	CLB3	Sorting Office, Kings Road	Distance to cycle route Distance to amenity footpath Within conservation area	Within an area of shallow surface water flood risk, or within Flood Hotspot	N/A – The increase in capacity is reflective of a more recent planning consent and doesn’t affect the previous sustainability appraisal Please see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)
RSD/61	HOV4	The Cheviots/Cotswold Close	Distance to district/local centre Distance to amenity footpath		N/A – The increase in capacity is reflective of a more recent planning consent, and doesn’t affect the previous sustainability appraisal Please see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)
RSD/62	HOV5	87-221 (odds) Farley Bank reduced	Distance to amenity footpath	Distance to district/local centre	N/A – The decrease in capacity is reflective of a more recent planning consent, and doesn’t affect the previous sustainability appraisal Please see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)
RSD/63	HOV6	Ore Business Park, Farley Bank	Distance to amenity footpath	Distance to district/local centre Proximity to Local Wildlife Site	N/A – The decrease in capacity is reflective of updated planning application, and doesn’t affect the previous sustainability appraisal Please see earlier assessment in Sustainability Appraisal Report of the Development Management Plan (Nov 2012)

Table 6: Summary of site assessment results

Cumulative and synergistic effects

4.7 An assessment of the cumulative and synergistic effects is required to ensure that the significant changes to the Development Management Plan are considered in the wider context of their ‘in-combination’ effect on the sustainability objectives. It is also important to consider these changes in light of the existing Development Management Plan policies that remain unchanged. As such, this report should be read in conjunction with the earlier Sustainability Appraisal of the Development Management Plan report (November 2012), published in January 2013.

4.8 The assessment in Appendix C provides a brief commentary on potential cumulative or synergistic effects. However, the appraisal itself shows only positive effects on the sustainability objectives as a result of the significant changes to the Development Management Plan, which means that there is not considered to be any conflict between the changes themselves and that the in-combination effects will enhance the remainder of the Plan, particularly in terms of its environmental objectives.

4.9 Cumulative impacts of the site allocations have been considered in detail as part of the strategic, Planning Strategy process, where the impact of the overall level of development was assessed in detail. However, there is still be potential for more localised cumulative impacts to arise from development, for example in relation to traffic impacts, play provision, impacts on protected green space and provision of new open space. The new site policies ensure that requirements such as those listed below will prevent harm or mitigation measures will be put in place to minimise harm and ensure overall sustainability. Potential requirements include:

Transport assessments
Ecological assessments
Financial contributions to the enhancement or management of protected greenspace, open space or play provision
Safeguarding of land/contributions to the green infrastructure network (including pedestrian and cycle routes)

4.10 It is not considered that the cumulative and synergistic effects of the significant changes to the Development Management Plan require further action, or the identification of additional mitigation measures.

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