Skip to main content
Belfast Local Development Plan May 2022

Addendum to draft Plan Strategy Sustainability Appraisal Report

Published online: May 2022 


Executive Summary

This document comprises an Addendum to the Sustainability Appraisal Report August 2018, one of the plan documents prepared for Belfast City Council’s draft Plan Strategy for the Local Development Plan 2035.

Following an independent examination in 2020/2021, the Planning Appeals Commission concluded that, subject to modifications, the draft Plan Strategy was considered to meet the relevant tests of soundness.  In February 2022 the Department for Infrastructure issued a direction to the Council.  This directs the council to address the required modifications, along with any necessary engagement and consultation, prior to formal adoption of the Plan Strategy.  These modifications are detailed in Schedule 1 of the direction made by the Department, which is published alongside this document.

This addendum should be read in conjunction with the Sustainability Appraisal Report August 2018.  It provides a full appraisal of the modifications set out in Schedule 1 of the direction through the sustainability appraisal process and highlights the effects that the modifications had in regard to the initial sustainability appraisal of the draft Plan Strategy.  This has been done by:

  1. Screening out modifications which do not need to be subject to sustainability appraisal, as they do not have the potential to lead to significant sustainability effects; and
  2. Undertaking a sustainability appraisal of modifications which have been screened in as they do have the potential to lead to significant sustainability effects.

The findings are set out in sections 2 and 3 of this document. 

This addendum highlights the effects that the required modifications are likely to have with regards to the original Sustainability Appraisal published in August 2018.  It demonstrates that the modifications to the draft Plan Strategy can be made without impacting or changing how the plan as a whole would perform against the SA Objectives.


Contents

1. Introduction
Independent examination of the draft Plan Strategy
Post-examination modifications
Sustainability appraisal of modifications
Statutory Requirements
Consultation

2. Screening of required modifications
Screened out modifications
Screened in modifications

3 Detailed assessment of required modifications
Table 1: Summary of ‘screened in’ modifications
Appraisal of new Strategic Policy SP1A.

Table 2: Summary of detailed Sustainability Appraisal of new policy SP1A
Summary

4 Conclusions and recommendations
Screening process
Detailed appraisal
Summary

5 Next stages
What happens next?
Consultation arrangements

6 Appendices


1 Introduction

Independent examination of the draft Plan Strategy

1.1 In December 2019 the Department for Infrastructure (DfI) appointed the Planning Appeals Commission (PAC) to conduct an Independent Examination (IE) of Belfast City Council’s draft Plan Strategy (dPS), which was held over two sessions between November 2020 and March 2021.

1.2 In September 2021 the PAC made its recommendations under section 10(8) of the Planning Act Northern Ireland 2011, which concluded that, subject to recommended amendments, the dPS satisfies all the legislative requirements as well as the procedural, consistency, coherence and effectiveness tests of soundness set out in Development Plan Practice Note 6 (DPPN 6) and that the dPS was considered sound on that basis.

Post-examination modifications

1.3 In February 2022, following consideration of the PAC report, the DfI in exercise of the powers conferred on it by section 12(1)(b) of the Planning Act (Northern Ireland) 2011, issued a direction to the Council.  This directs the Council to address the PAC’s requirements (set out through 78 required modifications in Schedule 1), along with any necessary engagement and consultation, prior to formal adoption of the Plan Strategy.  The direction, including Schedule 1 which sets out the required modifications to the plan, is published alongside this document.

1.4 To fulfil the obligations set out in the direction the Council will be required to modify the dPS to include all modifications detailed in Schedule 1, and to engage with the appropriate consultation bodies prior to undertaking public consultation in relation to any changes considered necessary.

Sustainability appraisal of modifications

1.5 Any modifications to the dPS have the potential to change the appraisal of likely effects on social, economic and environmental interests. They therefore require consideration through the Sustainability Appraisal (SA) and Strategic Environmental Assessment (SEA) process in order to determine if they alter the ‘likely significant effects’ predicted in the 2018 SA Report, or if they may result in new likely significant effects.

1.6 This document forms an addendum to the SA Report August 2018 and looks to identify whether, as a result of the required modifications, the outcomes of that report should be varied from those originally reported.  As such, whilst this addendum is a full SA of the required modifications, it should still be read in conjunction with the 2018 SA Report.

1.7 This addendum incorporates the following:

  • Screening of all the required modifications to identify whether they materially change what the SA assessed (i.e., if they change what actions the LDP might inevitably lead to), or what the SA assumed about how the LDP would be implemented,
  • A detailed assessment of the required modifications ‘screened in’ and identified as requiring further appraisal; and
  • Conclusions & recommendations

Statutory Requirements

1.8 The SA must assess the social and economic effects of the LDP as well as the environmental effects.  It therefore must comply with EU SEA Directive 2001/42/EC on the assessment of effects of certain plans and programmes on the environment (SEA Directive).  The SEA Directive is transposed into Northern Ireland legislation through the Environmental Assessment of Plans and Programmes Regulations (Northern Ireland) 2004 (the EAPP(NI) Regulations).

1.9 This addendum to the SA Report August 2018 has been prepared by Belfast City Council in accordance with:

  • Sections 8(6) and 9(7) of the Planning Act (Northern Ireland) 2011,
  • Regulation 15 and 16 of the Planning (Local Development Plan) Regulations (Northern Ireland) 2015, and
  • The Environmental Assessment of Plans & Programmes Regulations (Northern Ireland) 2004 (EAPP).

Consultation

1.10 Consultation plays a hugely important role in the preparation of the LDP and informing the way in which we undertake the SA.  We have actively consulted as required throughout the process and will continue to do so at each relevant stage as we move forward.  This ensures that relevant stakeholders have the opportunity to be involved and ultimately help shape the LDP.

1.11 In line with the consultation arrangements set out in the SA Report August 2018, representations to this addendum are invited through the subsequent consultation process.  Details of the consultation arrangements are provided on page 21.


2. Screening of required modifications

2.1 Schedule 1 of the direction issued by DfI sets out 78 required modifications (RM) in order that the dPS be considered sound.

2.2 The first stage of reporting as part of the SA Addendum is an initial screening of all RMs to identify those that could have a potential significant effect on the final outcome of implementation of the Plan Strategy.  Each RM has been compared against the plan policies and supporting information to check whether or not it changes the intention of that policy or supporting text, and subsequently the published SA results or any of the SA’s original assumptions.  This screening is set out in Table A1 of Appendix 1, which provides full details of each modification and the reason why they were screened in or out. 

Screened out modifications

2.3 The majority of the modifications had been discussed and agreed between the council and the PAC through the IE process, which included changes such as typing error corrections, minor amendments to text for clarification, factual updates and mapping corrections.  On this basis and by virtue of the minor nature of their changes, 76 of the 78 modifications could be ‘screened out’.  See Table A1 of Appendix 1 for further details.

2.4 A detailed sustainability appraisal is not required for these modifications as they would have no effect on the outcomes of the 2018 SA Report.

Screened in modifications

2.5 RM references MOD05 and MOD06 were ‘screened in’ as the proposed introduction of a new strategic policy was considered to have the potential to alter the likely significant effects within the scope of the 2018 SA Report.  A detailed appraisal of the modifications, including assessment of reasonable alternatives, is required to understand what impact they may have on the SA of the plan as a whole.


3   Detailed assessment of required modifications

3.1 The second stage of this process is where a RM has been ‘screened in’, the identified substantive changes must be assessed in detail.  This involves assessing the main identified outcomes of the amendment against the SA Objectives and questions set out in the SA Framework.  The appraisal works towards meeting the identified SA Objectives and therefore identifying the extent to which the recommended amendment has impacted the overall appraisal of the dPS as a whole.  The assessment methodology, scoring formulas and categories used are the same as those used in the 2018 SA Report.

3.2 Following the initial screening in Table A1 (Appendix 1), it has been determined that RM references MOD05 and MOD06 should be ‘screened in’ for detailed appraisal:

Table 1: Summary of ‘screened in’ modifications
Direction ref Recommended modification
MOD05 “Inclusion of a strategic policy on phasing as outlined in paragraph 3.42 of the PAC IE report. Consultation to be undertaken by BCC and final wording to be agreed with Department.”
MOD06 “Inclusion of a policy relating to public services/utilities as set out in paragraph 3.43 of the PAC IE report. Consultation to be undertaken by BCC and final wording to be agreed with Department.”

3.3 Both were suggested in response to the IE discussions on Policy SP1 ‘Growth Strategy’ of the dPS.  Given the nature of the recommended modifications and in line with the details provided in paragraphs 3.42 and 3.43 of the PAC IE report, the council is satisfied that both can be addressed together through the introduction of one new strategic policy, which will be referred to as ‘Strategic Policy SP1A’.

3.4 The introduction of a new policy could have a potential significant effect on the final outcome of the dPS implementation, therefore a detailed appraisal of the proposed policy, including assessment of reasonable alternatives, is required to understand what impact the policy may have on the SA of the plan as a whole.  

Appraisal of new Strategic Policy SP1A

3.5 The full detailed sustainability appraisal of the new policy is set out in Tables A2 – A7 in Appendix 2.  This includes consideration of reasonable alternatives and detailed assessment matrices of all options against the SA Objectives.  Assessment scoring and effect significance reflect the same methodology and formulas as per paragraphs 2.6.4 – 2.6.7 of the 2018 SA Report, with updated versions also provided in Appendix 2.

3.6 Subsequent assessments were then carried out on the council’s preferred option to determine its total score, and the total effects of the updated Strategic Policies against the SA Objectives.  Finally, it was determined how the preferred option would sit alongside the remainder of the dPS policies; and whether its introduction would influence or impact the effects of the plan as a whole against the SA Objectives. Table 2 below provides a summary of the detailed work in Appendix 2, alongside the subsequent conclusions and outcomes.

Table 2: Summary of detailed Sustainability Appraisal of new policy SP1A

Consideration of reasonable alternatives

Summary

Outcome of appraisal

Clarifies where reasonable alternatives were identified for the policy option, and if not, the reasons why they were scoped out. Includes:

  • Reasons for alternatives considered
  • Detailed consideration of social, economic & environmental effects of proposed policy and reasonable alternative
  • Reasons for choosing preferred option
  • Mitigation
  • Timescale of effect

The PAC report and Direction from DfI make it clear that such a policy is required to make the plan sound. 

‘No policy’ is therefore not considered a reasonable alternative and has been scoped out from the outset.

2 options have been identified as being reasonable:

  • Option 1; ‘Prescriptive phasing policy’ reflects the PAC’s suggested wording in paragraph 3.42 of the PAC Report and envisages a strict separation of land into specific phasing.
  • Option 2; ‘Strategic policy plus LPP’ represents the council’s proposed wording, which has a similar effect to the PAC’s suggested wording but with more flexibility in-built, referring to existing provisions within the broader dPS and the need for phasing within the Local Policies Plan (LPP).

Option 2 has been selected as the council’s preferred option on the basis that it scores higher, and the overall appraisal against the SA Objectives is more positive.

Assessment matrix for new policy options

Summary

Outcome of appraisal

Assessment matrix that appraises both options against the 19 SA Objectives.

  • Option 1 scored - 5, which equates to a minor negative total score.
  • Option 2 scored + 6, which equates to a minor positive total score.

This demonstrates that Option 2, as the council’s preferred option, would perform better against the SA Objectives (SAOs) than Option 1.

Total Strategic Policy scores

Summary

Outcome of appraisal

Scoring matrix of the council’s preferred policy option, alongside the other Strategic Policies to show updated total scores of all Strategic Policies.

The total policy score for the council’s preferred option is a minor positive, which would sit alongside the minor positive scores recorded for all other Strategic Polices.

All Policy Scores

Summary

Outcome of appraisal

Table showing the total scores of all dPS policies.

The total scoring for all policies in the plan has been updated to include the council’s preferred option, which introduces an additional minor positive impact.

Total Effects of Strategic Policies on SA Objectives

Summary

Outcome of appraisal

Scoring matrix of all six Strategic Policies appraised, to show the updated total effects of each Strategic Policy against the SA Objectives. Also includes a comparison with the total effects of the five Strategic Policies that were previously appraised in the 2018 SA Report (i.e., not including new policy SP1A).

Introducing the council’s preferred option into the dPS has affected ten individual scores. 

Of these, the final total effects have changed for three SA Objectives:

  • 2 are less positive with changes from significant positive to minor positive (SAOs 3 & 8),
  • 1 is more positive with a change from neutral to minor positive (SAO 16).

Total Effects of the LDP

Summary

Outcome of appraisal

Scoring matrix showing the total plan effects, with the total scores of all plan policies within each of the six themes shown against the SA Objectives. Also includes a comparison with the total plan effects from the 2018 SA Report (i.e., not including new policy SP1A).

The SA appraisal of the council’s preferred option demonstrates that its introduction into the Plan Strategy will have no impact on how the plan performs as a whole against the 19 SA Objectives.

The results of the 2018 SA Report will therefore not be affected, and will remain unchanged:

Updated total plan effects against the SA Objectives:

  • 14 x significant positive effects
  • 4 x minor positive effects
  • 1 x neutral effect

 

Summary

Having undertaken a detailed appraisal of the two reasonable alternatives considered for new Policy SP1A, it is concluded that:

  • Option 2 would have a total minor positive effect when appraised against the SA Objectives, which is better than Option 1 for which a total minor negative was recorded,
  • Option 2 was subsequently selected as the council’s preferred option on this basis,
  • A strategic policy based on Option 2 would introduce an additional minor positive scoring policy to the plan (i.e., when considering the total policy score for that option), which would be consistent with the minor positive scores recorded for the remaining strategic policies,
  • A strategic policy based on Option 2 would decrease the total positive effects of the Strategic Policies against SA Objectives 3 & 8, however these would still record minor positive scores,
  • A strategic policy based on Option 2 would increase the total positive effects of the Strategic Policies against SA Objective 16 from neutral to minor positive, and
  • A strategic policy based on Option 2 would have no impact on the total effects of the plan as a whole (as recorded in the 2018 SA Report).

3.8 The results of the appraisal demonstrate that the council’s preferred option would have positive results when assessed as an individual policy.  When read alongside the existing, remaining policies, if such a policy was introduced to the Plan Strategy its inclusion would result in no impact, implications or changes to how the plan as a whole would perform against the SA Objectives as reported in the 2018 SA Report.


4 Conclusions and recommendations

4.1 This addendum highlights the effects that the required modifications to the dPS have had with regards to the original Sustainability Appraisal published in August 2018.

Screening process

4.2 The initial screening process concluded that 76 of the modifications detailed in Schedule 1 of the direction could be ‘screened out’ by virtue of their nature, and a detailed sustainability appraisal was not required.

4.3 These modifications will have no effect on the overall outcomes of the 2018 SA Report.

Detailed appraisal

4.4 Modifications MOD05 and MOD06 were screened in, and a detailed assessment has been carried out on the proposed Strategic Policy SP1A that would address both.  Reasonable alternatives were considered and fully appraised against the SA Objectives, and the council selected its preferred option.  Subsequent assessments were carried out to determine the total policy score for the council’s preferred option, total effects score, and to show how the appraised policy sits alongside the remainder of the dPS. 

4.5 The council’s preferred option would perform well as an individual policy with a minor positive SA score.  Crucially, its inclusion within the dPS alongside the existing policies would result in no impact or change to how the dPS as a whole would perform against the SA Objectives. 

4.6 The introduction of this policy to the dPS, to address modifications MOD05 and MOD06, would have no effect on the overall outcomes of the 2018 SA Report.

Summary 

4.7 The results of this report demonstrate that all of the required modifications to the dPS can be made without impacting or changing how the plan as a whole would perform against the SA Objectives.


5 Next stages

5.1 This Addendum to the SA Report 2018 has been published alongside the Draft Plan Strategy Modifications Consultation Overview for consultation, and incorporates the Environmental Report as required by the SEA Directive.  It presents the integrated findings of the combined SA and SEA of the required modifications set out in the direction from DfI, including the assessment of reasonable alternatives and recommendations for mitigating and monitoring significant effects.

5.2 The results of this addendum demonstrate therefore that all the recommended modifications can be made without having any implications on the overall performance of the dPS against the SA Objectives.  The originally published results and assumptions as set out in the 2018 report would remain unchanged.

What happens next?

5.3 The plan-making process will continue to follow the stages as detailed in the SA Report 2018. 

5.4 Following publication of the Draft Plan Strategy Modifications Consultation Overview and this SA Addendum, representations are invited through the subsequent consultation process.  Modifications to both may be made in response to consultation, and any significant changes to the plan will be subject to additional appraisal.

5.5 SEA Regulations require the council to produce a formal, post-adoption SA Statement to accompany the Plan Strategy, as soon as reasonably possible after its adoption.  The purpose of the post-adoption statement is to outline how the SA process has informed and influenced the plan preparation and decision-making process and demonstrate how consultation on the SA was taken into account.  The statement will include the modifications appraised through this addendum and any responses received to it through the consultation process.

Consultation arrangements

5.6 In line with the consultation arrangements set out in the SA Report August 2018, this addendum will be available for consultation alongside the Draft Plan Strategy Modifications Consultation Overview, for a statutory consultation period of eight weeks, from 12 May to 7 July 2022.

5.7 You can respond to this consultation exercise online, by emailing localdevelopmentplan@belfastcity.gov.uk or by post to:

Belfast Planning Service
Cecil Ward Building
4-10 Linenhall Street
Belfast
BT2 8BP

028 9050 0510 

5.8 All the relevant documentation will be available online at www.belfastcity.gov.uk/LDP from 12 May 2022.  They will also be available for inspection at the main reception in Belfast City Hall during normal public opening hours.

Belfast City Council
Belfast City Hall
Donegall Square North Belfast
BT1 5GS

028 9032 0202 


6 Appendices

This Addendum to the SA Report 2018 is accompanied by two appendices:

Back to top

Read aloud icon Read aloud