EIPS and Equally Justified Strategies

Although the main failing of new style strategic plans so far had been on failure to look at reasonable alternatives, once they have taken a step backwards and done so through a new SEA there is no guarantee that one strategy only will pull clear of the rest.

A good example is North Essex where the SEA concludes that the preferred strategy and one incorporating elements (more development East ofColchester) of the opponents preferred approach score roughly equally.

Look at the soundness test in the NPPF

Justified – an appropriate strategy, taking into account the reasonable
alternatives, and based on proportionate evidence;

Note no longer the ‘most appropriate strategy’.  Providing that there is not on strategy which has significantly more environmental effects than another it is perfectly possible for more than one to pass the hurdle.

Then what is the role of the EIP panel – well if the strategy preferred passes this test it has to be found sound.  It is not the panels job to have a beauty contest of strategies. which might come to a surprise to opponents of the preferred strategy.  At the end of the day the choice between strategies where significant environmental effects are avoided/mitigated is a job for elected politicians not keyboard warriors or land promoters.

Of course this is partially to do with the relatively weak and subjective goals achievement matrix type scoring used, and the lack this far of good land-use/transport wide area models which assess carbon impact.  Im sure these will improve and will help justify.

Hence I think the attention will switch among oppositionist to challenging the justification given by cllrs towards one strategy than other.  I dont think justifications such as West Somerset/Bolton wouldn’t countenance any Green Belt Sites and Stockport said they had enough would justify as land use planning considerations as it would lead to weighted and unfair consideration between alternative sites in terms of their objective environmental impacts.

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