4 Sustainability Appraisal
4.1 The Sustainability Appraisals are required to incorporate the statutorily required Strategic Environmental Assessments (SEAs) of policies and plans. As part of this, there is a requirement for reasonable alternatives to considered on a like-for-like basis, allowing the reader to compare the environmental effects and wider sustainability issues associated with different development scenarios.
4.2 The quantum of development is but one area that logically should be subject to reasonable alternatives, particularly where the evidence base (both the ELEDES and HER) set out a series of scenarios for the decision maker (in this case the GTSPT) to consider before selecting the most appropriate as a matter of planning judgement. It is surprising therefore that the SA accompanying the GCLP first proposals fails to identify any reasonable alternatives relating to the quantum of development.
4.3 The reasons given for this are self-defeating. Two potential alternative options are considered before being discounted:
“B. Alternative option - Planning for the higher jobs forecast and level of homes associated with it. This alternative has not been assessed as it is not considered to be reasonable. This is because the higher jobs forecast could be possible, but is not the most likely future scenario. As such we do not consider that it represents our objectively assessed need, and would therefore not be a reasonable alternative.
C. Alternative option - Planning for the government’s standard method local housing need figure. This alternative has not been assessed as it is not considered to be reasonable. This is because it would not support the most likely forecast for future jobs. As such, the Councils do not consider that it represents our objectively assessed need, and would therefore not be a reasonable alternative. Failure to reflect that likely level of growth, would lead to increased commuting into the area (with consequent impacts on quality of life, wellbeing and carbon emissions objectives for the plan).”
4.4 It is agreed that Option C would not be reasonable given the overwhelming evidence that both employment and housing need are far greater than yielded from the LHNSM. That is not to say that a lower level of growth than the preferred option (Option A, the 44,400 homes and 58,500 new jobs set out in the first consultation) would be unreasonable and certainly, it would likely be helpful in teasing out the relative sustainability issues related to the quantum of development.
4.5 The justification for discounting Option B however is clearly erroneous. If it was only necessary to assess the “most likely future scenario”, there would be no assessment of alternatives of any kind. This is contrary to the entire purpose of SA and SEA.
4.6 The ELEDES makes clear that, while it concludes that the Central Growth Scenario (58,500 jobs) is the most likely, the Higher Growth Scenario is entirely possible. Indeed, as set out in this report it is entirely plausible and therefore reasonable.
4.7 To withhold the full assessment of Option B alongside Option A effectively blinds the decision maker to the differences in environmental effect and sustainability between them. The decision maker cannot conclude that however less likely Option B might be compared to Option A, whether the possibility of success outweighs or reduces the environmental impact.
4.8 This approach has been noted as a concern during the examination of the Babergh and Mid Suffolk Joint Local Plan13, which has been suspended pending further work by the Councils.