Letter from Dave Black, Head of Planning and Transportation at DCC, in reply to the Letter to DCC, regarding DCC's Sustainability Appraisal (SA) first referred to in Negative impact on flight safety only "minor"?
The reply from DCC argues that since the site appraisals considered "...social, environmental and economic impacts, it was not considered necessary to undertake SA of the site options prior to identifying the preferred and excluded sites for consultation." Government advice is however that Strategic Environmental Assessment [SEA, a European Directive which forms part of the SA] is most effective when started as early as possible...". In DCC's case the SA report, with its conclusions on the relative environmental impacts of each site, was published some three months after the Consultation started, and did not inform the selection of the Preferred Sites, or the rejection of the alternatives, a point also made by Natural England. It is therefore unclear how DCC will be able to demonstrate that Article 2(b) of directive 2001/42/EC "the taking into account of the Environmental Report... in decision making" has been fulfilled.
DCC does not see a conflict of interest in the same person overseeing preparation of the Minerals Plan and the Sustainability Appraisal. Many local authorities however, Oxfordshire, Somerset and Wiltshire to name three, engage outside consultants to "undertake an independent Sustainability Appraisal" which helps avoid any accusation that the SA is not entirely impartial. Government advice says it is "helpful to involve people... who are not directly concerned in producing the plan or programme and can contribute expertise or a detached and independent view". It is not a "legal requirement" for the SA to be independent, but good practice when working to find the best outcome, not just the most deliverable.
DCC does however welcome any comments from the public on the SA report "... including any inaccuracies or disagreement with judgements made in the report", but otherwise has decided that the SA report "... does not warrant a wider consultation." The SA report on S7 (Straitgate) can be found in S7 and S7 appendix. Click for the Sustainability Appraisal Team contact details. Here is a list of our comments so far.
