Sustainability Appraisal of the Sandwell Local Plan 2024-2041

6 Reasonable alternatives

Preface

N60 The SEA Regulations state as part of the requirements for preparing an environmental report, that the local plan making process must identify, describe, and evaluate reasonable alternatives that have been considered.

N61 There is no precise guide as to what constitutes a 'reasonable alternative'. SMBC have identified reasonable alternatives for the SLP at different stages of the plan making process, including different types of reasonable alternatives, for example, different options to meet the required growth such as housing growth options, employment growth options, policies and reasonable alternative sites.

N62 The SA has assessed reasonable alternative sites on a comparable basis against the SA Framework to identify likely sustainability impacts, and it is the Council's role to use the SA findings, alongside other evidence base material, to decide which sites to 'select' for allocation in the SLP and which to 'reject' from further consideration.

N63 In the case of the SLP, all reasonable alternatives have been identified and described by the Council's plan makers. Figure N.5 below outlines the definitions for the different types of reasonable alternatives assessed throughout the SA process.

Figure N.6 summarises the reasonable alternatives considered throughout the plan-making process, and where these alternatives have been identified, described and evaluated.

Figure N.5: Definitions for the different types of reasonable alternatives assessed in the SA process

Figure N.6: The identification, description and evaluation of reasonable alternatives considered throughout the plan-making process

Housing growth options

N65 Six high level options for the overall quantity of housing growth to be delivered through the SLP were assessed within the Draft Plan SA Report^[14] (Regulation 18(II), 2023). These options include numbers based on different sources to provide an illustration of how the SLP could address the borough's housing need in a realistic manner.

N66 The six residential growth options are summarised in Table 5.1.

Table N.4: Housing growth options identified by SMBC (see Regulation 18 (II) Draft Plan SA Report 2023)

N67 Table 5.2 summarises the SA findings. The assessments are presented in full within the Regulation 18(II) Draft Plan SA (2023)^[16].

Table N5: Summary SA findings for assessment of housing growth options A-F

N68 Option E is identified as the best performing option overall, assuming that a large proportion of growth under this option would be on previously developed land and within the existing centres, with the benefits in terms of regeneration meaning this option slightly out-performs Option D, although neither option would deliver sufficient housing to satisfy the identified need.

Employment growth options

N69 Four options for employment growth were assessed within the Draft Plan SA Report^[17] (Regulation 18(II), 2018), as shown in Table 5.3.

N70 Sandwell is located within the Black Country Functional Economic Market Area (FEMA) which also covers the local authorities of Dudley, Walsall and Wolverhampton. The Black Country Economic Development Needs Assessment (EDNA) and Black Country Employment Area Review (BEAR) are the key pieces of evidence relating to employment land need and supply. The EDNA (2022)^[18] and 2023 update^[19] identified an estimated demand of 185ha of employment land in the district for the Plan period, although neighbouring authorities may have a role to play in helping to satisfy the employment shortfall through the Duty to Co-operate.

Table N.7: Employment growth options identified by SMBC (see the R18 (II) Draft SA Report, 2023)

N71 Table 5.4 summarises the SA findings. The assessments are presented in full within the Regulation 18(II) Draft Plan SA (2023)^[20].

Table N.8: SA performance of the employment growth options (see the R18 (II) Draft Plan SA Report, 2023)

N72 Overall, Option C could be considered as the best performing against all the objectives collectively as it provides enough land to meet the lower estimate of need, performs well against the economic objectives, and although having negative impacts against the environmental objectives, would likely have less of an impact than Option B.

Gypsy and Traveller growth options

N73 The Black Country Gypsy and Traveller Accommodation Assessment (GTAA)^[21] assessed accommodation needs for Gypsies, Travellers and Travelling Showpeople across Sandwell and the wider Black Country. The GTAA (2022) identified a need for 14 pitches and 32 plots in Sandwell.

N74 Three options for Gypsy, Traveller and Travelling Showpeople (GTTS) growth have been identified by SMBC (see Table 5.5).

Table N.9: Gypsy, Traveller and Travelling Showpeople growth options identified by SMBC (see the R18 (II) Draft SA Report, 2023)

N75 Table 5.6 summarises the likely impacts of each GTTS growth option in relation to the 14 SA Objectives. The assessments are presented in full in the Regulation 18 (II) SA Draft Plan^[22].

Table N.10: SA performance of the Gypsy, Traveller and Travelling Showpeople growth options (see the R18 (II) Draft Plan SA Report, 2023)

N76 Option A could be identified as best performing overall as it provides for a proportion of both the Gypsy and Traveller and Travelling Showperson needs but also has lower potential for adverse impacts across the other SA Objectives than Option C. However, it should be acknowledged that since Option A proposes to "schedule an early review of the SLP to readdress need across later stages", there is some uncertainty regarding the longer-term effects.

Spatial growth options

N77 Four spatial growth options were assessed within the Draft Plan SA Report^[23] (Regulation 18(II), 2018), as shown in Table 5.7. These options consider how the overall number of homes and area of employment land (and other types of land use where applicable) could be strategically distributed, helping to meet some of the strategic aims of the emerging SLP.

N78 Given Sandwell's highly urbanised nature with very little vacant or unused open spaces, and the importance of the existing open and green spaces for environmental and human health, the Council is limited in the number of approaches it can take to accommodate growth.

Table N.11: Spatial growth options identified by SMBC (see the R18 (II) Draft SA Report, 2023)

N79 Each option has been assessed using the SA Framework and summary findings are presented in Table 5.8. The assessments are presented in full in the Regulation 18 (II) SA Draft Plan^[24].

Table N.12: SA performance of the Spatial growth options (see the R18 (II) Draft Plan SA Report, 2023)

N80 Overall, it appears Option B performs best against the largest number of SA Objectives; it reduces the impacts on the environment whilst providing residential and employment growth. However, it is not clear exactly what level of growth this option would support as the quantities of housing or employment development that could be attained under this option are not known. As such, it may be a refinement of this option provides the best option overall.

Evaluation of reasonable alternative sites

N81 The identification, description and evaluation of development sites has taken place throughout the plan making process at different stages.

N82 SMBC have undertaken a filtering process (or 'gateway check') of all potential sites identified through the evidence base in order to determine which sites should be considered as reasonable alternatives for the purpose of the SA. If the following receptors were obviously present at a site, the Council have generally rejected such sites from inclusion:

• Ancient Hedgerows
• Ancient Woodland/Veteran Tree
• Common Land
• Flood Zone 3
• Green Belt
• Health and Safety Executive (HSE) Zone 1 (for residential)
• Local Nature Reserve (LNR)
• Operational Burial Grounds
• Registered Park & Garden (RPG)
• Scheduled Monument (SM)
• Site of Importance for Nature Conservation (SINC)
• Site of Special Scientific Interest (SSSI) / Special Area of Conservation (SAC)
• Strategic Open Space

N83 Sites were also filtered out where the landowner has expressed unwillingness, or sites with one or more significant planning constraints which cannot be mitigated.

N84 Through undertaking this filtering process, a total of 124 reasonable alternative development sites have been identified by SMBC and considered throughout the SA process.

N85 The Regulation 18 (II) SA Report (2023)^[25] included an assessment of 120 reasonable alternative sites identified by the Council, comprising:

• 55 residential-led sites
• 19 employment-led sites;
• One Gypsy, Traveller and Travelling Showperson site;
• Eight sites for mixed use; and
• 37 sites for multiple uses.

N86 The Regulation 19 SA Report (this report) includes an assessment of four additional reasonable alternative sites proposed for housing use, identified by the Council since the previous stage (see Appendix E of Volume 3). In addition to these four sites, the Council has provided updated information for the use of 36 reasonable alternative sites assessed at the Regulation 18 (II) stage, and boundary changes for four sites including SH16, SEC3-133, SM7 and SM8.

N87 A total of 124 sites have therefore been assessed across the SA process as follows:

• 84 residential-led sites;
• 28 employment-led sites;
• One Gypsy, Traveller and Travelling Showperson site;
• Eight sites for mixed use; and
• Two sites for multiple use.

N88 The SA identified a range of positive and adverse potential impacts of the reasonable alternative sites on the objectives within the SA Framework.

N89 Negative impacts were mainly identified in relation to issues associated with air quality due to the proximity of reasonable alternative sites to the borough's major roads and the location of all development within Sandwell AQMA; the likely impact on the borough's carbon footprint associated with the construction and occupation of new development; loss of undeveloped land and/or land with potential environmental value; proposed development within areas of surface water flood risk; potential adverse effects on Sites of Local Importance for Nature Conservation (SLINCs) especially where development sites coincide or are located adjacent to these designations; and sites located in deprived areas with potential to exacerbate inequalities without careful planning.

N90 Positive impacts were identified in relation to the provision of new housing and employment floorspace which would contribute towards meeting the identified needs; benefits to health and accessibility as many reasonable alternative sites are located within sustainable distance to NHS hospitals, GP surgeries and public green spaces; sustainable accessibility to schools and public transport including railway and bus services; and the majority of sites being located within Flood Zone 1 where fluvial flood risk is low.

N91 All reasonable alternative sites which have been considered at the Regulation 19 stage (120 sites following the removal of four reasonable alternative sites as explained in Appendix H) have been assessed pre-mitigation in terms of potential impacts on each SA Objective as seen in Table N.13 below, the results of which are presented in their entirety in Appendix E.

Table N.13: Summary of pre-mitigation reasonable alternative site assessments (extracted from Appendix E)

Post-mitigation assessments of reasonable alternative sites

N92 Mitigation, using the emerging SLP policies (see Appendix F for the SA evaluation of policies), has been applied to the SA results for each reasonable alternative site and presented in Appendix G.

N93 Following the application of policy mitigation, it was identified that many of the adverse effects will likely be reduced or mitigated, including:

• Alterations to the character/setting of heritage assets;
• Threats to locally distinctive or sensitive landscapes;
• Threats to biodiversity sites, priority habitats and ecological networks;
• Reduction in GHG emissions;
• Risk of fluvial and surface water flooding;
• Loss of land with environmental value;
• Exposure to and exacerbation of poor air quality;
• Risk of contamination of groundwater Source Protection Zones and watercourses;
• Access to transport networks and local services;
• Location of residents in deprived areas;
• Access to healthcare facilities;
• Access to greenspace;
• Loss of an access to employment; and
• Access to education opportunities.

Table N.14: Summary of post-mitigation reasonable alternative site assessments (extracted from Appendix G)

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