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Generation of options
PPS12 paragraph 4.36 states that a core strategy (or other development plan document):
"Must be the most appropriate strategy when considered against the reasonable alternatives."
PPS12 Policy, paragraph 4.43, states:
"Sustainability assessment should inform the evaluation of alternatives. It should provide a powerful means of proving to decision makers, and the public, that the plan is the most appropriate given reasonable alternatives."
Planning Policy Statement 12 - on the Communities and Local Government website
The process of early involvement, for example through the community strategy process, should identify the issues that the development plan document needs to consider. The regional context and national policy is likely to show the direction in which many of these issues should be addressed.
The local authority can then commence discussions with key stakeholders regarding finding solutions to these issues. For example, a key issue in many areas is how to balance social objectives with competing demands – such as planning for future identified housing needs – in a way which fulfils other goals, like environmental sustainability. Key stakeholders have a major role here in ensuring that the options pursued are practical.
Paragraph 4.26 of PPS12 discusses the need to involve the community in the process of refining and improving the options. This will help demonstrate the justification of the development plan document.
At this stage, it should be clear to consultees that it remains open for them to express a preference for any option, including those the local authority suggest be rejected and that such a response may lead the local authority to re-think the options put forward at publication.
Consultees should have sufficient detail about the various options to have a reasonably clear understanding of the different outcomes of those options. This approach will also mean that when the draft final plan is published, you are less likely to get representations that stop the plan in its tracks.
There is no point in producing unrealistic options. There may be special circumstances where there is only one reasonable option available. However, this will still need to be assessed against the ‘do nothing’ option as required by the SEA Directive. If a local authority is of the view that there are no alternative options the reasons for this view will need to be fully explained and justified.
This might be where the strategy or key decisions have already been decided by a higher level document such as the core strategy or the regional spatial strategy. Options should try to focus on how the development plan document will implement the wider strategy, and the tactical, timing, location or delivery options available.
The role of the sustainability appraisal
The role of the sustainability appraisal is not to determine the option(s) to be chosen – it is to assist with the selection of the appropriate option(s), by highlighting the sustainability implications of each. The assessment of options should be a continual process, starting from the options put forward at scoping stages, all the way through to the options being worked into the draft development plan document for publication. ).
Setting objectives and developing the baseline - more information on options and alternatives in the manual.
To make it easier for the public to understand, the local authority should try to simplify its comments on options by indicating the performance of different options in the sustainability appraisal. People can then see (with the benefit of technical evidence) how different options fare. This will, assist their feedback on the options.
Further options may be generated from stakeholder and community engagement as part of Regulation 25 activities, and they too should be subject to sustainability appraisal, where they are reasonable and the local authority is seriously considering them. In preparing a development plan document, a large number of options could be generated. It is recommended however that you consider broad strategic options as opposed to detailed policy wording variants.
Options need to be sufficiently distinct to highlight the different sustainability implications of each, so that meaningful comparisons can be made.
To meet SEA Directive requirements they need to be compared with each other and with the current social, environmental and economic characteristics of the area and the likely future situation without a development plan document. In doing so they need to be tested against the sustainability appraisal objectives.
The outcome of the process should be a limited set of ‘selected options’ for which there is a clear sustainability appraisal audit showing how they perform in sustainability terms - a commentary on the key sustainability issues and problems arising, with recommendations on how each of the options could be improved e.g. through mitigation measures and monitoring (see task B6 of the SEA Practical Guide). Click here to view further information on ‘Identifying the sustainability issues’ and ‘Monitoring the significant effects’.
To help establish the soundness of the development plan document, local authorities will need to show a clear trail of:
- options generation
- selection or rejection
the role that sustainability appraisal and community engagement have played in this process.
Government office involvement
It is important to remain in close contact with your government office. You should consult them regularly on emerging plans during the plan preparation process, especially at the generation and discounting of options stage. This will help to ensure that any fundamental issues of soundness are identified and resolved early on.
Generation of options: challenge questions
Ask yourself some key questions about your approach and practice to generation of options.