Professional Documents
Culture Documents
EIA Guide to Procedures (CLG, 2000) Towards a more efficient and effective SA/SEA in spatial planning (CLG, 2010) 3 Healthy Lives, Healthy People: Our strategy for Public Health in England (HM Govt, 2010) 4 Fair Society, Healthy People: The Marmot Review (Marmot, 2010)
PRE-APPLICATION CONSULTATION Fundamental to effective stakeholder engagement is ensuring that relevant stakeholders (or representatives if of unmanageable number) are involved. Yet under question 5 of Pre- application Consultation, the guidance provides a very limited and exclusive list of consultees. Your new guidance should make it clear that the list provided is not comprehensive and that consultation must always strive to include a fully representative body of stakeholders. CLIMATE CHANGE Under questions 3 and 7, you specify the use of Sustainability Appraisal, and state specifically that: "Sustainability appraisal should be used to test different spatial options in plans on emissions." See second paragraph above, which quotes from a 2010 CLG report stating the lack of clear spatial focus in most SA/SEAs. Your new guidance should make it clear that SA/SEA on its own is insufficient and requires both additional spatial planning and broader stakeholder consultation e.g. SA/SEA when used in spatial/masterplanning, should be integrated fully with the support of spatial planners/designers within a broader stakeholder engagement that starts early on in the plan-making process, continues throughout and includes local experts in health and sustainability. EIA Under question 7, you set out the publicity requirements for an EIA, which to paraphrase are that the Environmental Statement should be made public at the end of the process. This goes against your policy on consultation, which states that it should start early. See above comment on Climate Change and SA/SEA with regards to consultation. When applied on mixed-use housing developments, it is crucial that the broader consultation include both planners and designers as well as relevant experts in health and sustainability. NEIGHBOURHOOD PLANNING Under question 3, you explain very clearly when Neighbourhood Plans might require an SA or SEA, yet fail to address how sustainability appraisal is to be incorporated when there are differences of opinion as to what is sustainable and what is not, a situation that is likely to be common due to the interpretation of the legal wording significant environmental effect. Take, for example, the many hundreds of mixed-use housing developments of between 100- 500 homes. While the resource is generally not available for neighbourhood groups to undertake or commission formal sustainability appraisal, there are more cost-effective options available, which fit well with the Governments Red-tape Challenge. Your new guidance should encourage strong consideration of social and environmental issues as well as the use of innovative and bespoke sustainability appraisal processes where possible by inserting "such as" in front of SA/SEA in those instances when SEA is not a legal requirement. Daniel Black Marcus Grant Director, db+a Associate Professor, Healthy Urban Environments 07725 998 550 Deputy Director, WHO Collaborating Centre info@db-associates.co.uk Institute for Sustainability, Health and Environment (ISHE) University West of England