The Sustainability Appraisal

THE ‘SUSTAINABILTIY’ APPRAISAL
 

Please click here to read the Sustainability Appraisal that accompanies the West Cheshire/North East Wales sub-regional strategy.

Here are a couple of examples from the report published in 2005, to read a more detailed review please scroll down:

” Population growth more rapidly in North East Wales than for North West and the UK average. Flintshire and Wrexham and Denbighshire experiencing in-migration, largely from England – potential loss of identity and knock on effects in relation to Welsh language and culture – Opportunities and implications for sub regional strategy – Improve/maintain cross-border social relations”

“In terms of protection and enhancement of the Welsh language and cultural resources, economic growth and investment does have the potential to improve the provision of Welsh cultural facilities, although the extent of this will largely depend upon implementation through the local development plans. Conversely, economic growth may bring with it an influx of national businesses and chain retail services which could dilute existing Welsh culture. Furthermore, patterns of migration and commuting across the English-Welsh border between the principal strategic centres (e.g. Wrexham-Chester improvements, Wrexham-Bidston rail improvements) may also lead to a dilution of Welsh speaking. Increased housing development along North Wales coast may also result in similar effects.”

 ”adverse environmental impacts are anticipated with the level of growth envisaged, and particular mitigation measures will need to be imposed locally to counter these.”

The Sustainability Appraisal

The Sustainability Appraisal that accompanies the West Cheshire plan was commissioned by the North West Regional Assembly and the Welsh Development Agency. The inclusion of this document to accompany the West Cheshire plan was mandatory under UK law and was published in 2005 (a few months before the plan was officially adopted by Wrecsam, Denbighshire, Flintshire councils and the Welsh Assembly). The purpose of the Sustainability Appraisal was to ensure that the principles of ’sustainability’ were fully integrated into the West Cheshire plan.

However, it is shocking to discover that the clear warnings highlighted in the appraisal, as regards the damage the West Cheshire plan will cause to both the environment and Welsh identity, have been ignored. Even more worrying is the fact that the Sustainability Appraisal was reviewed a second time in order to merit the inclusion of  the West Cheshire plan as part of the Wales spatial plan, again clear warnings were brushed aside.

The following report intends to highlight these warnings through the use of direct quotes from the Sustainability Appraisal itself.

The Sustainability Appraisal uses a set of guiding principles to asses the West Cheshire plan. These include 11 Environmental guidelines, 8 social objective guidelines and 8 economic objectives. These principles essentially rate the plan in terms of the damage the strategy will do to:

a) The environment (i.e. climate change, air quality, carbon emissions, landfill rates, water quality, green space, built heritage etc.)

b) Socially (i.e. community cohesion, inequalities, reduce crime, access to quality affordable housing, protection of welsh identity, language and culture etc.)

c) Economically (i.e. economic performance, sustainable economic growth, marketing the sub-regions image).

So what were the results under each of these guiding principles?

The Environment

“Increased efficiency of transport links and therefore higher volumes of vehicles on roads could lead to increased air pollution, which in turn can contribute to adverse implications to human health and can indirectly affect the quality of biodiversity and habitats, the landscape/townscape and the setting of cultural heritage features”

“Increased industrialisation can lead to increased emissions and resources use. Increased transport emissions of greenhouse gases. Potential sea-level rise, increased incidence of flooding on the coast and in low lying areas and increased periodicity of rainfall. Potential impact on finite natural resources, for example water”

“Increased landtake noise and pollution resulting from transportation improvements could decrease biodiversity. Development pressures resulting from economic and population growth could affect biodiversity and increase ecological footprint”

“Commuting issues through traffic and increased number of vehicles in region can lead to congestion and capacity issues.”

“Cumulative health impacts as a result of poor air quality, social stresses and poor provision of health services”

“Lack of affordable housing, disparities in economic performance and pockets of locally poor environments lead to higher levels of deprivation”

The Sustainability Appraisal goes on to examine in detail the various growth options being considered by the strategy (the higher growth option was eventually chosen). It makes the following comments in terms of resources:

“It can be anticipated that where there is an increase in population there will be an increase in water supply demand and a corresponding increase in required capacity for wastewater. This can be offset to a degree through the promotion of more water efficient development within the LDF/LDP and through increasing awareness within the population for the need for water conservation.”

“Issues relating to energy efficiency and the uptake of renewable energy are not a spatial issue. The preferred spatial option is unlikely to result in a reduction in energy demand in the sub-region, and may actually result in an increase in those areas targeted by this development option.”

“Similarly, the SRSS is unlikely to result in a reduction in fossil fuel consumption. It is possible that the SRSS may help to promote alternatives to fossil fuel use by influencing policies to be implemented through the LDF/LDP and planning system. There are national statutory targets to reduce emissions and meet renewable energy production derived from international agreements (e.g. the Kyoto Protocol, TAN 8 in Wales etc.). Waste production is not specifically a spatial issue, although growth can be anticipated to result in higher rates of waste production. Waste management is also an issue outside the scope of the SRSS. However, the SRSS could reinforce the requirement for the provision of policies to minimise waste production and maximise recycling through the LDF/LDP as appropriate.”

“All options have potential to adversely affect the environment, particularly through cumulative effects”

“Cumulative impacts may be realised upon: landscape, townscape and heritage; biodiversity; and climatic factors. A combination of incremental increases in development, pollution and traffic vibration across localised urban areas of the sub-region may combine to cause a greater overall impact upon the sub-region’s landscapes, townscapes and heritage resource in the form of effects on the setting of a resource.”

“Climatic factors relate to a cumulative increase in energy use from a variety of growth related sources. This may result in an increase in demand for energy production and consequently use of fossil fuels. This failing in adapting to climate change could be exacerbated by a cumulative increase in development pressure in and around floodplains.”

Social Impacts

“In terms of protection and enhancement of the Welsh language and cultural resources, economic growth and investment does have the potential to improve the provision of Welsh cultural facilities, although the extent of this will largely depend upon implementation through the local development plans. Conversely, economic growth may bring with it an influx of national businesses and chain retail services which could dilute existing Welsh culture. Furthermore, patterns of migration and commuting across the English-Welsh border between the principal strategic centres (e.g. Wrexham-Chester improvements, Wrexham-Bidston rail improvements) may also lead to a dilution of Welsh speaking. Increased housing development along North Wales coast may also result in similar effects.”

“It is unlikely that the spatial strategy will have a great impact upon engaging communities with decision-making, as this is an issue that is very dependent upon local implementation. However, economic growth can bring with it increased affluence and improved educational opportunities and aspirations in the long term, both of which can be related to community empowerment. Outside these areas there is potential for a feeling of greater exclusion to be fostered. The magnitude of the two effects might be
expected to increase over the duration of the strategy if not appropriately addressed through the implementation process.”

“The improvements to the sub-region’s image as a place to do business would attract more investment and also potentially in migration, although the latter may not necessarily be desirable.”

“The increase in employment brought about by this option has the potential to attract workers from neighbouring areas, having negative effects on employment in those areas.”

Economic Impacts

“In all cases, growth across the sub-region could have positive benefits in terms of reducing the disparities in economic performance between the sub-region and neighbouring areas such as Liverpool and Manchester. In contrast, this may increase polarisation between the sub-region and neighbouring areas of lower growth such as Denbighshire. The effects are likely to increase over time and this issue would benefit from monitoring in the future.

“Although strategic mixed-use sites may contribute to reduced travel to work distances, increased walking, cycling and public transport, and hence traffic congestion, the likely overall outcome of promoting strategic sites development, is likely to result in traffic growth in targeted areas of the sub-region. This would have implications for local air quality and greenhouse gas emissions. This policy potentially both contributes to and goes against traffic, air quality and climate change objectives, depending upon the sites in question. These problems would be exacerbated if people commute daily to and from areas outside of the sub-region to take the employment opportunities offered at these sites.

“The focus of such sites on financial, business, research and development and other professional services has implications for social and economic inclusion and community cohesion. The targeted sector of high skilled jobs has the potential to attract migrant workers as opposed to local labour and may increase the skills gap between actual and required skills. Furthermore, a potential growth in migrants to the area may have implications in terms of community integration and cohesion and the development of a sense of belonging for all members of local communities.”

Conclusion

The Sustainability Appraisal highlights many damaging impacts as the result of the economic growth proposed in the West Cheshire plan. The results of high housing and economic growth are fairly obvious in any case but the damage that will be caused is specified in this document, it is not simply our interpretation. It’s solutions to these problems are vague, delegating responsibility to mitigate the impacts to local authorities. The only changes to the plan itself based on the conclusions of the Sustainability Appraisal were the inclusion of a few extra sentences.

 In truth it is impossible for either the plan or local authorities to ‘mitigate’ for such high levels of growth, the damage is inevitable. From a Welsh perspective, the failure of local authorities and the Welsh Assembly to acknowledge the damage to welsh identity, language and culture as highlighted in the report, is completely unacceptable and highlights systematic failure. In the review of the Wales Spatial Plan (which can be viewed via the link at the top of this page), this issue is not even referred to, although it is mentioned repeatedly in the Sustainability Appraisal for the West Cheshire plan.

With policies across Wales in relation to sustainability, reducing carbon emissions and reducing the amount of waste going to landfill, the adoption of this plan is mind blowing. As a basic concept, deliberately planning for large increases in population exasperates all these problems, with the subsequent demographic changes and social impacts only receiving fleeting references.

Although outlining the obvious environmental and social damage that will be caused by the west Cheshire plan, the Sustainability Appraisal and West Cheshire plan miss one key concept, the existence of a national border. The border dividing the new ’sub region’ brings with it a host of cultural and historical issues that are simply ignored. There is a failure by all those involved to recognise the bigger picture, although considering many of the issues are repeatedly highlighted in the Sustainability Appraisal, it is difficult to believe that this failure is accidental.

To conclude, The People’s Council for North Wales are both alarmed and amazed that this plan has already been adopted given the serious implications outlined in the Sustainability Appraisal.