east cambridgeshire green party by lindash

VIEWS: 3 PAGES: 6

									East Cambridgeshire Green Party Response to consultation on the Initial Sustainability Appraisal June 2007 This response should be read in concert with Initial Sustainable Appraisal, as published on East Cambridgeshire District Council’s website
www.eastcambs.gov.uk/html/ldfpages.asp?servid=6&title=LDF++Current+Consultation&hier=LDF

Comments on Table 1 ECGP feels Table 1 lacks a substantial amount of essential supporting information: - workable definition - relationship between initial sustainability appraisal and LDF options - no attempt to look collectively at information in the initial sustainability appraisal - initial sustainability appraisal consultation structured in manner which is difficult to respond to East Cambridgeshire Green Party (ECGP) largely supports the sustainable development criteria identified. We believe they offer the potential for consideration of a good range of social, economic and environmental ends against which to consider the Local Development Framework options. However, ECGP regard the supporting information and interpretation to be lacking, and would highlight four areas where this needs to be rectified. 1. The appraisal should include a full definition as to what ECDC understands sustainability to mean, highlighting the following: The need for the Local Development Framework to move the district toward genuine sustainability, rather than providing a method of selecting least-worst development options Although equal significance is given to each criteria, certain impacts should be identified as unacceptable, even when they bring significant benefits in other areas. For example, we would regard development proposals that generate a significant increase in flood risk as being unacceptable. Where such overriding concerns exist, this should be identified in table 1. That sustainable development is not about balancing social, economic and environment objectives against each other. Rather, it requires an integration of the three. The sustainability appraisal must therefore give appropriate information to support preference for such options.

-

-

2. There is an absence of detail covering how the information gathered for the sustainability assessment will be used to influence the development of the LDF. This makes it difficult to ascertain the rationale behind the

assessment, and its strengths and weaknesses. Such information should be covered in an introduction. 3. There is no attempt to collectively interpret the information held in the tables supporting Qs 3-35. Significant information relating to the overall sustainability of development options is therefore not being considered or made available. For example, a number of sustainability objectives are regarded as being affected „neutrally‟ for all 28 questions posed in the draft sustainability assessment. These are: 2.3 Improve opportunities for people to access and appreciate wildlife and wild places 5.1 Maintain and enhance human health 6.2 Redress inequalities related to age, gender, disability, race, faith, location and income 6.4 Encourage and enable the active involvement of local people in community activities

This highlights either, that: - Criteria 2.3, 5.1, 6.2 and 6.4 are irrelevant to the development options and should be replaced with measures which are more meaningful - Measures of criteria 2.3, 5.1, 6.2 and 6.4 are not sensitive enough to produce meaningful results for the purposes of the sustainability appraisal Or None of the options is doing enough to promote issues covered under criteria 2.3, 5.1, 6.2 and 6.4. This raises questions about how the sustainability appraisal is informing the LDF development options

The appraisal needs to contain information as to which of these situations is the case, and what will be done to address the situation. 4. We would also highlight that the structure of the initial sustainability appraisal consultation makes it difficult to comment on such shortcomings. Comments on Table 2 ECGP feels that the definition of „neutral‟ used in Table 2 allows for inaccurate and misleading employment of the term later in the document. Table 2 sets out the level of impact each of the development options would have on the sustainability criteria. East Cambridgeshire Green Party wishes to question the level of use of the „neutral‟ symbol. The use of the „neutral‟ sign in tables implies no positive or negative impact. This is misleading. If there is an existing shortcoming in the provision a service (e.g. opportunities to access and appreciate

-

wildlife and wild places) than a failure of LDF options to address this should be considered a negative impact. Similarly, recording an issue as „neutral‟ appears to preclude it from being the focus of mitigation. If there is an existing shortcoming in the provision of a service, this again is misleading as it implies no consideration of investment is needed.

We would therefore wish to see enhanced reasoning concerning the meaning and use of the neutral symbol. Comments on Q3 ECGP believes the table supporting Q3 considers the relative impact of development options, rather than the contribution to sustainability. This relates to 4.1, 4.2 and 4.3 in particular. The objective of a sustainability appraisal is to measure the likely social, economic and environmental effects of proposals being considered. Indeed, paragraph 1.2 states “The Appraisal evaluates the sustainability of the proposed policy options against 22 „sustainability objectives‟, as identified in the Council‟s Scoping Report (2006).” ECGP‟s interpretation of the results presented in the Initial Sustainability Appraisal is that they often actually measure the relative merits of each of the Options, as compared with other options under consideration. This is demonstrated in the table supporting Q3. For example, objective 4.1 refers to “reducing emissions of greenhouse gasses and other pollutants”. The table supporting Q3 claims all options will be beneficial, varying from „Strong and significant beneficial impact‟ to „a minor beneficial impact‟. Given that all options refer to substantial increases population and housing, such a result is highly questionable. Indeed, ECGP would suggest that rather than reducing emissions of greenhouse gasses, traffic volumes, noise levels, light pollution, water pollution and air quality all options, no matter how efficiently carried out, will necessarily have varying degrees of negative effects. To present it as otherwise is misleading as it in no way reflects how „sustainable‟ each of the options is, but rather gives marks for the option that is the least worst. We believe similar criticism holds true for the way criteria 4.2 and 4.3 are presented in Q3. This needs to rectified by a re-examination of the effects of Options A, B and C on the climate change and pollution, rather than by comparison of the relative effects of options. Comments on Q4 In relation to Objective 4.1, ECGP‟s interpretation of the results presented in the Initial Sustainability Appraisal is that they actually measure the relative merits of each of the Options. It should actually be a measure of the impact proposals would have on sustainability.

The objective of a sustainability appraisal is to measure the likely social, economic and environmental effects of proposals being considered. Indeed, paragraph 1.2 states “The Appraisal evaluates the sustainability of the proposed policy options against 22 „sustainability objectives‟, as identified in the Council‟s Scoping Report (2006).” In relation to Objective 4.1, ECGP‟s interpretation of the results presented in the Initial Sustainability Appraisal is that it actually measures the relative merits of each of the Options, as compared with other options under consideration. Objective 4.1 refers to “reducing emissions of greenhouse gasses and other pollutants”. The table supporting Q4 claims the impacts of options will range from „potential significant benefit‟ to „neutral‟. Given that all options refer to substantial increases population and housing, such a result is highly questionable. Indeed, ECGP would suggest that rather than reducing emissions of greenhouse gasses, traffic volumes, noise levels, light pollution, water pollution and air quality all options, no matter how efficiently carried out, will necessarily have varying degrees of negative effect. To present it as otherwise is misleading as it in no way reflects how „sustainable‟ each of the options is. This needs to rectified by a reexamination of the effects of Options A, B and C on the objectives set out in 4.1, rather than by comparison of the relative effects of the other options. The objective of the initial sustainability assessment is to help decision making over the preferred options for the LDF. The table supporting Q4 also raises issues about the usefulness of information that can be derived from the initial sustainability assessment for this purpose. Of the 22 criteria, there is currently insufficient information available about more than a quarter of them (six in all). As significantly, 11 of the remaining 16 criteria report the same level of impact for options A, B and C. ECGP would suggest that the sensitivity and calibration of these 11 criteria should be re-assessed to ensure that this is an accurate and meaningful result. Comments on Q6 ECGP feel that the table supporting Q6 includes misleading use of the „neutral‟ symbol East Cambridgeshire Green Party would question the number of sustainability criteria listed as „neutral‟ in the supporting table. That 13 of the 22 variables are listed as neutral implies that the majority of the impacts of economic growth on the region are neither positive nor negative. In fact, impacts on issues such as biodiversity, landscape and health may be substantial, and will be directly related to the levels and type of growth patterned followed. As such, they should wherever possible be a material consideration in decisions over economic objectives. Rather than listing such impacts as neutral, we would argue that the table supporting Q6 should include them as „uncertain‟. Comments on Q9

ECGP feel that the table supporting Q6 includes misleading use of the „neutral‟ symbol East Cambridgeshire Green Party would question the number of sustainability criteria listed as „neutral‟ in the supporting table. That 13 of the 22 variables are listed as neutral implies that the majority of the impacts of economic growth on the region are neither positive nor negative. In fact, impacts on issues such as biodiversity, landscape and health may be substantial, and will be directly related to the levels and type of growth patterned followed. As such, they should wherever possible be a material consideration in decisions over economic objectives. Rather than listing such impacts as neutral, we would argue that the table supporting Q9 should include them as „uncertain‟. Comments on Q10 ECGP feel that the table supporting Q10 includes misleading use of the „neutral‟ symbol East Cambridgeshire Green Party would question the number of sustainability criteria listed as „neutral‟ in the supporting table. That 13 of the 22 variables are listed as neutral implies that the majority of the impacts of economic growth on the region are neither positive nor negative. In fact, impacts on issues such as biodiversity, landscape and health may be substantial, and will be directly related to the levels and type of growth patterned followed. As such, they should wherever possible be a material consideration in decisions over economic objectives. Rather than listing such impacts as neutral, we would argue that the table supporting Q10 should include them as „uncertain‟. Comments on Q11 ECGP feel that the table supporting Q11 includes misleading use of the „neutral‟ symbol East Cambridgeshire Green Party would question the number of sustainability criteria listed as „neutral‟ in the supporting table. That 13 of the 22 variables are listed as neutral implies that the majority of the impacts of economic growth on the region are neither positive nor negative. In fact, impacts on issues such as biodiversity, landscape and health may be substantial, and will be directly related to the levels and type of growth patterned followed. As such, they should wherever possible be a material consideration in decisions over economic objectives. Rather than listing such impacts as neutral, we would argue that the table supporting Q11 should include them as „uncertain‟. Comments on Q28 ECGP feel that the table supporting Q28 includes misleading use of the „neutral‟ symbol East Cambridgeshire Green Party would question the number of sustainability criteria listed as „neutral‟ in the supporting table. That 16 of the 22 variables are listed as neutral implies that the majority of the impacts of non-food retail floor space growth on the region are neither

positive nor negative. In fact, impacts on issues such as biodiversity, landscape and health may be substantial, and will be directly related to the levels and type of growth patterned followed. As such, they should wherever possible be a material consideration in decisions over economic objectives. Rather than listing such impacts as neutral, we would argue that the table supporting Q28 should include them as „uncertain‟. Comments on Q30 ECGP feel that the table supporting Q30 includes misleading use of the „neutral‟ symbol East Cambridgeshire Green Party would question the number of sustainability criteria listed as „neutral‟ in the supporting table. That 12 of the 22 variables are listed as neutral implies that the majority of the impacts of non-food retail floor space growth on the region are neither positive nor negative. In fact, impacts on issues such as biodiversity, landscape and health may be substantial, and will be directly related to the levels and type of growth patterned followed. As such, they should wherever possible be a material consideration in decisions over economic objectives. Rather than listing such impacts as neutral, we would argue that the table supporting Q30 should include them as „uncertain‟.


								
To top