Sustainability Appraisal of the Sandwell Local Plan 2024-2041

Ended on the 11 November 2024

3 Baseline and key sustainability issues

Overview

N27 The SEA Regulations requires the Environmental Report to present "an outline of the contents and main objectives of the plan or programme, and of its relationship with other relevant plans and programmes", "the environmental characteristics of areas likely to be significantly affected" and "any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance".

N28 There are a number of plans, policies and programmes (PPPs) that set out the environmental protection objectives which proposals within the SLP should adhere to. These are discussed within the Scoping Report and are updated in Appendix A. Some examples of these include the NPPF and the Habitats Regulations, as well as regional or local guidance and strategies such as local transport initiatives, the Birmingham and the Black Country Biodiversity Action Plan and the Sandwell Biodiversity Net Gain Strategy.

N29 PPPs that could potentially affect the SLP have been reviewed and considered alongside the current characteristics of the Plan area.

N30 Volume 2 (the main Regulation 19 SA Report) includes information relating to the baseline and key issues for the Local Plan area, drawing on information gathered during the Scoping stage, relating to the following sustainability topics (which incorporate the topics identified in Schedule 2 of the SEA Regulations[9]):

  • Accessibility and transport
  • Air Quality;
  • Biodiversity, flora, fauna and geodiversity;
  • Climatic factors;
  • Cultural heritage;
  • Human health;
  • Landscape and townscape;
  • Population and material assets;
  • Water and soil resources.

N31 An overview of each topic, including the key issues, is provided below.

Accessibility and transport

N32 The accessibility and transport theme considers how new development would impact transport and accessibility, including increases in the levels of congestion experienced across the Plan area, and whether these developments have access to sustainable and active travel options.

N33 Accessibility and transport have been considered in the SA assessments primarily within SA Objective 9 (Transport and accessibility).

Key issues relating to accessibility and transport

  • Although there is a high amount of traffic and cross-boundary movement to neighbouring authorities including Birmingham, Dudley, Walsall and Wolverhampton, 29.2% of Sandwell residents have no access to a car according to the 2021 Census.
  • Severance of active travel routes owing to Sandwell's location alongside the motorway network and the local conurbation has resulted in the landscape being dominated by local highway networks.
  • Access to transport can be a barrier to work, and for social wellbeing. Better access to shops, services, healthcare, education, entertainment, and other services is needed for all residents, and particularly for socially excluded groups.
  • There is a need to focus development within locations where there is good access to high quality public transport infrastructure, or the opportunity to provide it. Residential development in particular should be focused within walkable neighbourhoods where people can access local services on foot.
  • Better integration of, and connections between, different transport modes is required to facilitate sustainable and well-connected neighbourhoods. Public transport, park and ride and cycle hire schemes should be improved.

Air quality

N34 The air quality theme considers the implications of new development for air pollution including the potential exposure of new residents to existing areas of poor air quality such as alongside the strategic road network and within Air Quality Management Areas (AQMAs).

N35 'Air quality' has been considered in the SA assessments primarily within SA Objective 7 (Pollution), and SA Objective 12 (Health).

Key issues relating to air quality

  • The borough's industrial character accompanied by the strategic network of local and major arterial roads, including the M5 and M6, has led to high traffic volumes and congestion, with adverse implications for air quality.
  • Sandwell AQMA covers the whole local authority area and the principal pollutant affecting air quality is nitrogen dioxide (NO2), mostly sourced from road traffic. There is a need to ensure development avoids exacerbating air pollution issues in existing AQMAs and contributes to air quality improvement measures.
  • There is a need to ensure development proposals are designed in order to avoid any significant adverse impacts from pollution, including cumulative impacts, on human health and wellbeing, biodiversity, the effective operation of neighbouring land uses and the water environment.

Biodiversity, flora and fauna

N36 The biodiversity and geodiversity theme considers how the proposed development would affect statutory and non-statutory biodiversity and geodiversity designations within Sandwell, including European sites[10], Sites of Special Scientific Interest (SSSIs) Impact Risk Zones (IRZs), Sites of Importance for Nature Conservation (SINC), Sites of Local Importance for Nature Conservation (SLINC) Local Nature Reserves (LNR), Local Wildlife Sites (LWS), ancient woodland and priority habitats.

N37 'Biodiversity, flora and fauna' has been considered in the SA assessments primarily within SA Objective 3 (Biodiversity, Flora, Fauna and Geodiversity).

N38 Likely significant effects of the Local Plan on European sites are explored in more detail in the Habitats Regulations Assessment (HRA) process.

Key issues relating to biodiversity, flora and fauna

  • Growth promoted within the emerging SLP is likely to put pressure on biodiversity resources. There are potential impacts such as habitat fragmentation resulting from new development areas and recreational pressures on wildlife sites.
  • A number of Habitats sites, which are sensitive to changes in air quality, may be affected by changes in traffic generated by the SLP growth alone and in-combination with other plans and projects. The HRA of the SLP alongside a review of traffic modelling data will explore these potential effects in detail.
  • The SLP area is hydrologically connected to the Severn and the Humber Estuaries and their associated biodiversity designations. Habitats at these sites and migratory species of fish which use the wider catchment for phases of their lifecycle are sensitive to changes in water supply and quality which may be influenced by development proposals within the SLP. The HRA of the SLP will explore these potential effects in detail.
  • Careful consideration should be given during the plan-making process to the potential impacts on habitats and species of principle importance. The remaining areas of priority habitats within Sandwell should be protected from development and enhanced where possible.
  • There is a need to establish a coordinated and comprehensive GI network providing connectivity between biodiversity sites, green spaces, watercourses and other environmental features across the SLP area and wider Black Country.
  • Sandwell Valley supports a high level of ecological value, which may be lost or degraded as pressure increases for new development.

Climatic factors

N39 The climate change theme considers the implications of new development on greenhouse gas (GHG) emissions, the extent and coverage of green infrastructure (GI), as well as fluvial, coastal and surface water flood risk.

N40 'Climate change' has been considered in the SA assessments primarily within SA Objectives 4 and 5 (Climate Change Mitigation and Adaptation), SA Objective 7 (Pollution), and SA Objective 12 (Health).

Key issues relating to climatic factors

  • Fluvial and surface water flooding pose significant risks to areas within Sandwell. Flash flooding, resulting from excessive overland flow or overtopping of minor watercourses, is a key issue and as such surface water run-off management and incorporation of effective sustainable drainage systems (SuDS) should be a priority for new developments within the borough. Climate change has the potential to increase the risk of flooding.
  • There is a need to increase the quality and quantity of GI within the SLP area, and the wider Black Country, to provide multi-functional benefits including improved carbon storage, urban cooling, natural flood resilience/flood water storage, and provide a more attractive public realm to encourage active travel.
  • New development needs to incorporate energy efficiency measures and climate change adaptive features in order to respond to predicted levels of climate change, and to increase low-carbon and renewable energy generation and usage throughout the SLP area.
  • A range of further risks linked to climate change may affect the SLP area. These include the following:
    • an increased incidence of heat related illnesses and deaths during the summer;
    • increased risk of injuries and deaths due to increased number of storm events and flooding;
    • adverse effects on water quality from watercourse levels and turbulent flow after heavy rain and a reduction of water flow;
    • loss of species that are at the edge of their southerly distribution and spread of species at the northern edge of their distribution;
    • an increased move by the insurance industry towards a more risk-based approach to insurance underwriting, leading to higher cost premiums for local business; and
    • increased drought and flood related problems such as soil shrinkages and subsidence.

Cultural heritage

N41 The cultural heritage theme considers how the proposed development would affect statutory and non-statutory cultural heritage assets including Listed Buildings, Registered Parks and Gardens (RPGs), Scheduled Monuments (SMs) and Conservation Areas, as well as the wider historic environment and non-designated assets such as archaeology.

N42 'Cultural heritage' has been considered in the SA assessments primarily within SA Objective 1 (Cultural Heritage).

Key issues relating to cultural heritage

  • Development promoted through the emerging SLP may have the potential to cause adverse effects on historic landscapes and lead to damage to archaeological sites, monuments and buildings and / or their settings.
  • There are six heritage assets listed on the Heritage at Risk register within the SLP area which should be protected from inappropriate development and require improved management.
  • There is a need to promote innovative re-use of existing building stocks. The SLP should seek to improve the energy efficiency of historic buildings and take into account their embodied carbon value when considering their retention and re-use, versus their replacement.
  • Archaeological remains, both seen and unseen, have the potential to be adversely affected by new development. The Black Country HLC indicates some rare archaeological features of interest within Sandwell that should be preserved.

Human health

N43 The human health theme considers the potential for sustainable access to healthcare facilities (GP surgeries and NHS hospitals), leisure centres and green spaces for new residents.

N44 'Health' has been considered in the SA assessments primarily within SA Objectives 12 (Health) and 11 (Equality), although there is some overlap with other objectives such as SA Objective 7 (Pollution) in terms of the implications of poor air quality for human health and wellbeing.

Key issues relating to human health

  • As all the proposed development within the SLP will be located within an AQMA, this is likely to lead to adverse impacts on health, without intervention.
  • Residents in Sandwell experience significant inequalities in health, with residents having a lower life expectancy and experiencing illness and disability at a younger age on average, compared to other parts of England.
  • The increasing population in Sandwell is likely to place pressure on the capacity of health infrastructure and leisure facilities, which will need careful planning.
  • Anti-social behaviour is an issue within some of Sandwell's green spaces according to the Green Space Strategy, which may discourage their use by the local community. There is a need to establish greater management and maintenance of green spaces, and support more local involvement.

Landscape

N45 The landscape theme considers how the proposed development would integrate with existing local character and potential effects on views. Sandwell has a strong urban character with open green spaces, such as parks, and designated and non-designated sites dispersed across the borough and also including a section of Green Belt.

N46 'Landscape' has been considered in the SA assessments primarily within SA Objective 2 (Landscape).

Key issues relating to landscape and townscape

  • The north east of Sandwell lies within the West Midlands Green Belt. Parts of land in this area, within the Sandwell Valley, are identified as being of 'moderate' or 'moderate-high' landscape sensitivity.
  • There is a risk that the need for new housing development could increase the risk of encroachment into the remaining undeveloped areas of the borough or alter the character, tranquility and sense of place in suburban settlements. This includes the Rowley Hills, in the south west of the borough.
  • There is a need for new development to be in accordance with the scale and character of the local area and seek to conserve and enhance the quality of the surrounding landscape or townscape.

Population and material assets

N47 The population theme considers the implications for new development on meeting housing and employment needs, addressing inequalities and providing access to jobs and services. Material assets include a variety of built assets including healthcare, schools and essential infrastructure, as well as mineral resources and other natural assets. Together these themes seek to create places where residents have good access to services to meet their day-to-day needs, supporting a healthy and vibrant population.

N48 'Population and material assets' has been considered in the SA assessments across a number of SA Objectives including 4 and 6 (Waste and Natural Resources), 9 (Transport and Accessibility), 10 (Housing), 11 (Equality), 12 (Health), 13 (Economy) and 14 (Education, Skills and Training).

Key issues relating to population and material assets

  • Sandwell's residents have on average lower qualification levels and employment rates compared to the West Midlands and Great Britain.
  • There is a need to increase the proportion of waste sent for reuse, recycling or composting and move away from the use of landfill for waste disposal.
  • Sandwell is ranked as the 12th most deprived local authority in England. There is a need to support strong, vibrant and healthy communities by:
    • Providing the supply of housing required to meet the needs of present and future generations;
    • Creating a high-quality built environment, with accessible local services that reflect the community's needs and support health, social and cultural wellbeing;
    • Creating a strong sense of place by strengthening the distinctive and cultural qualities of towns and villages; and
    • Creating safe and accessible environments where crime, disorder and the fear of crime do not undermine quality of life or community cohesion.
  • Due to Sandwell's demography and urban structure, the population was hit hard by the COVID-19 pandemic, most notably its central corridor of older, poor-quality housing and communities from ethnic minority backgrounds, where infection rates were highest. The pandemic has deepened hardship and inequality in an already deprived area, with high reliance on Universal Credit, increased mental health issues and educational disruption.

Water and soil resources

N49 The water theme considers the implications of new development on water quality and quantity, and on soil resources.

N50 'Water and soil resources' has been considered in the SA assessments primarily within SA Objectives 6 (Natural Resources) and 7 (Pollution).

Key issues relating to water and soil resources

  • Soil is a non-renewable resource that will continue to be lost as a result of new development proposed within the emerging SLP as well as supporting infrastructure. The majority of land in the SLP area is ALC 'urban', with pockets of ALC Grade 3 and 4, which may be under threat from new growth areas and associated infrastructure.
  • New development and an increased population is likely to place pressure on water resources and may result in a deficit between supply and demand if not carefully planned and managed alongside the water companies.
  • There is a need to give close consideration to the impacts of development proposals on wastewater treatment in the local area, and the capacity of treatment works, as well as the consequences of new wastewater generation for local water quality and the ecological status of ground and surface water bodies.
  • Culverted watercourses have the potential to become blocked by debris during periods of heavy or sustained rainfall. They also offer little biodiversity or recreational interest relative to more natural watercourses. In such cases, environmental and water quality benefits can be secured at minimal cost.
  • Most forms of development reduce the amount of rainfall that is intercepted by vegetation on the ground and can have detrimental implications for surface water run-off.

[9] Schedule 2 of the SEA Regulations identifies the likely significant effects on the environment, including "issues such as (a) biodiversity, (b) population,(c) human health, (d) fauna, (e) flora, (f) soil, (g) water, (h) air, (i) climatic factors, (j) material assets, (k) cultural heritage including architectural and archaeological heritage, (l) landscape and (m) the interrelationship between the issues referred to in sub-paragraphs (a) to (l)."

[10] These sites consist of Special Areas of Conservation (SACs) designated under the Habitats Directive, and Special Protection Areas (SPAs) classified under the Birds Directive. Additionally, paragraph 181 of the NPPF (2023) requires that sites listed under the Ramsar Convention are to be given the same protection as fully designated Habitats sites.

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