Sustainability Appraisal of the Sandwell Local Plan 2024-2041
8 Likely significant effects on the environment
Identified impacts
N102 Proposals in the SLP have been assessed for their sustainability impacts, the results of which are presented in the relevant appendices / report chapters as listed above. The assessment of the Plan, including reasonable alternatives, was undertaken using a combination of empirical evidence, and to a lesser extent, professional judgement.
N103 Table N.18 provides a summary of the potential negative impacts of the LP relating to each of the sustainability themes (as set out in full within Chapters 7 – 15 of the Main SA Report, Volume 2). These are the impacts that have been identified prior to the implementation of the SLP mitigation.
Table N.18: Summary of identified potential impacts of the Sandwell Local Plan
Sustainability theme
Summary of potential impacts of the Local Plan
AIR QUALITY
- Increased pollutant emissions: Impacts on air quality may arise during the construction and occupation of different types of development proposed within the SLP. Some types of new development, such as employment locations, local facility provisions or the cumulative impact of high-density residential development, are likely to increase the volume of traffic and associated emissions within the SLP area.
- Exposure of human and biodiversity receptors to poor air quality: An increase in air pollution from new development including vehicular emissions could potentially have adverse impacts on biodiversity assets, in particular European sites and SSSIs which are vulnerable to the impact of atmospheric nitrogen deposition, such as nearby SSSIs 'Wren's Nest' or 'The Leasowes'. In addition, Exposure to sources of air pollution could potentially have adverse effects on the health of local residents, with children, the elderly and those of poor health identified as the most vulnerable.
BIODIVERSITY, FLORA, FAUNA & GEODIVERSITY
- Threats or pressures to European sites: A number of likely significant effects (LSEs) have been identified in the HRA screening process with regard to several European sites; this includes adverse effects across a number of impact pathways including regarding air quality, and water quality and quantity.
- Threats or pressures to locally designated and non-statutory biodiversity sites: Adverse impacts on locally designated sites arising due to development proposed in the SLP could potentially include direct impacts on habitats and / or indirect impacts such as increased recreational disturbance caused by local residents visiting these sites, such as Local Nature Reserves, SINCs and SLINCs.
- Fragmentation of the ecological network and priority habitats: Over half of all allocated sites are located on previously undeveloped land or land with environmental value, which is likely to result in the loss of soil resources and the ecosystem services they provide. In addition, priority habitats cover 8% of the total site allocation area. High levels of development and increased density within the urban area of Sandwell may also result in losses to the GI network, where it is important to retain ecological links amongst built form.
CLIMATIC FACTORS
- Fluvial and surface water flood risk: Development within Flood Zones 2 or 3 (including 3a and 3b) has the potential to locate site end users at risk of fluvial flooding, may increase the risk of damage to property and increase risks to human health in the immediate area and/or contribute to exacerbation of flood risk in the surrounding areas. Additionally, development in areas of surface water flood risk may locate site end users in areas at risk of flooding, with safety implications, and further exacerbate flood risk in the surrounding area.
- Increased GHG emissions: The proposed development is likely to increase to some extent local GHG emissions through increased energy demand associated with the occupation of new dwellings and employment premises, transport-related emissions, and the production and use of materials during construction / release of embodied carbon associated with redevelopment sites.
- Loss of multi-functional green infrastructure: The proposed development will result in the loss of a significant area of land with environmental/ecological value. Some of the proposed development could potentially also result in the loss of trees, hedgerows and other vegetation currently on site. Multi-functional GI is vital in helping to reduce adverse impacts of climate change.
CULTURAL HERITAGE
- Alter character and/or setting of designated heritage assets: Development which coincides with or is located in close proximity to heritage assets such as Listed Buildings, Conservation Areas, Registered Parks and Gardens and Scheduled Monuments has the potential to affect both the asset itself and its setting.
- Effects on the historic environment: The Black Country Historic Landscape Characterisation (HLC) Study[26] identified a number of Archeological Priority Areas (APAs) and Areas of High Historic Townscape Value (AHHTVs).
HUMAN HEALTH
- Sustainable access to healthcare facilities: Sandwell is a predominately urban area, and as a consequence has access to a large number of health facilities. Where there is more limited access to these facilities, residents may be discouraged from living active and healthy lifestyles, which could potentially have adverse impacts on mental wellbeing as well as physical health.
- Exposure to air/noise pollution (from AQMAs/main roads): The entirety of the SLP area is classified as an AQMA and approximately half of allocated sites are located in proximity to main roads. The long-term health of residents, in particular vulnerable groups including children and the elderly, could be adversely affected by local reductions in air quality.
- Loss of public greenspace: Good access to public green or open spaces, a diverse range of natural habitats and travelling via walking and cycling are known to have physical and mental health benefits. Whilst there is generally good access to open space across Sandwell as a whole, there are spatial variations on existing access to different types and sizes of open space across different areas.
- Limited access to PRoW or cycle network: The majority of allocated sites are located in areas with good coverage by the PRoW and/or cycle networks, providing many site end users with opportunities for active travel and recreation parks, open space or the surrounding countryside. However, 13 allocated sites are located beyond the sustainable target distance of 600m to a PRoW or cycle path.
LANDSCAPE AND TOWNSCAPE
- Threaten or result in the loss of locally distinctive or sensitive landscapes: The introduction of new built form can contradict and conflict with distinctive local landscapes and townscapes which can result in adverse impacts on sensitive landscapes and loss of local character.
POPULATION & MATERIAL ASSETS
- Provision of housing to meet local need: The large number of dwelling proposed is expected to meet a large proportion of the identified housing need with the remainder being met through other forms of housing provision such as through windfall developments and export to neighbouring local authorities via the Duty to Co-operate.
- Provision of employment opportunities: The SLP allocated a large area of employment land and will therefore be likely to have a positive impact on the local economy, as well as the wellbeing of residents.
- Sustainable access to services and facilities: Good access to public transport, schools, local services and employment opportunities is essential to reduce reliance on private car use, encourage healthy and active lifestyles and provide accessibility to spaces which could potentially have benefits to mental wellbeing and community cohesion.
- Increased pressure of local services and facilities: The proposed development within the SLP is expected to increase population density across Sandwell. This will be likely to apply greater pressures on the capacity of services within the Plan area, including schools, GP surgeries, leisure centres and open spaces.
- Addressing inequalities: All residents should be provided with equal access to a range of opportunities, to support the local population in living happy and healthy lifestyles. Fostering interactive and vibrant communities often benefit from a strong sense of place, a reduced fear of crime and a strong local economy.
- Increased household waste generation: SMBC has responsibility for the provision of waste collection and recycling services for households as part of the management of waste. The proposed development is expected to increase household waste generation and have a potential adverse impact on the capacity of waste management facilities.
SOIL
- Direct loss of soil resources: Soil provides a range of essential services to the local area, including nutrient cycling, abating flood risk, filtering water, carbon storage and providing the basis for vegetation to flourish. Where construction occurs, soil could potentially be compacted by heavy vehicles on-site. During the occupation or operation phase of development, soil, in some circumstances, could potentially be paved over, become subject to increased footfall or be subject to increased volumes of chemicals.
WATER
- Reduction in water quality and ecosystem services: The construction and occupation of new development has potential to increase the risk of contamination and pollution of waterways, primarily due to the potential loss of soil and surface water / pollutant runoff. A small proportion of development is also located within a groundwater source protection zone.
- Increased demand for water and wastewater management: The proposed population growth within the SLP is likely to increase water demand as well as wastewater treatment across the Plan area, in particular where wastewater treatment works have limited capacity.
Mitigation
N104 Table N.19 summarises these mitigating effects of the 88 SLP policies (as set out in full within Chapters 7 – 15 of the Main SA Report, Volume 2).
Table N.19: Summary of policy mitigation
Sustainability theme
Summary of mitigating effects of the Local Plan policies
AIR QUALITY
- Various policies seek to improve traffic flow and promote sustainable and active modes of transport in order to avoid reductions in air quality, including Policy STR1: Priorities for the development of the transport network and Policy STR5: Creating coherent networks for cycling and walking, as well as policies STR2, STR3, STR4, STR6, STR8 and Policy STR9.
- Policy SCC2: Reducing operational carbon for new build non-residential development, supported by Policy SCC1 – Energy Infrastructure, Policy SDS2: Increasing efficiency and resilience and Policy SDMI: Design Quality, promote energy-efficient development proposals which support low carbon technologies, which will likely result in a decrease of pollutant emissions from the construction and occupation of new development.
- Policy SDS8: Green and Blue Infrastructure in Sandwell and Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows encourage enhancements to the provision and connectivity of GI/BI, which will help to support ecosystem service functions such as the filtration of air pollutants and could potentially result in reducing impacts from increased emissions.
BIODIVERSITY, FLORA, FAUNA & GEODIVERSITY
- Policy SNE1: Nature Conservation seeks to protect, conserve and enhance biodiversity assets including local designations. Where the benefits of development strategically outweigh the importance of a local nature conservation site, "damage must be minimised" and remaining impacts must be fully mitigated with an accompanying mitigation strategy.
- Policy SNE2: Protection and enhancement of wildlife habitats supports the provision and enhancement of priority habitats as part of the implementation of biodiversity net gain.
- Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows aims to utilise these biodiversity features for habitat creation and the restoration of ecological networks. This is supported by Policy SDS8: Green and Blue Infrastructure in Sandwell, Policy SNE5: The Rowley Hills and Policy SNE6: Canals, all of which seek to improve habitat creation and enhancement in the Plan area.
CLIMATIC FACTORS
- Policy SCC5: Flood risk sets out measures to identify and manage the risk of flooding throughout the borough and ensure that development is avoided in areas of high fluvial and surface water flood risk, in line with the NPPF. The policy also encourages development proposals to naturalise urban watercourses and open up culverts to provide multi-functional benefits, including for reinstating natural river channels.
- Policy SCC6: Sustainable drainage underpins Policy SCC5 in relation to SuDS, outlining design requirements and states that "surface water drainage strategies are required for all major developments, regardless of their size and the flood zone and catchment they are in".
- Policies SNE1: Nature Conservation, SDS8: Green and Blue Infrastructure in Sandwell provides measures that would protect and enhance green and blue infrastructure and ecosystem services, with likely multi-functional benefits including for flood risk reduction.
- Policy SCC2: Reducing operational carbon for new build non-residential development, supported by Policy SCC1 – Energy Infrastructure, Policy SDS2: Increasing efficiency and resilience and Policy SDMI: Design Quality, promote energy-efficient development proposals which support low carbon technologies, which will likely result in a decrease of GHG emissions from the construction and occupation of new development.
- Policy SCC3: Climate-adapted design and construction aims to reduce the risk of heat gain and the urban heat island effect (UHI) through efficient building design. The policy requires "passive ventilation" and "active cooling systems", in order to reduce heat gain lost to the environment, which has potential for cumulative adverse effects when considering the impacts of global warming as a consequence of climate change.
- Policy SCC4: Embodied carbon and waste aims to limit the amount of embodied carbon resulting from the proposed development by completing a whole-life carbon assessment for large-scale developments and considering a range of options for small-scale development.
- Several policies including Policy SNE1: Nature conservation, Policy SNE2: Protection and enhancement of wildlife habitats, and Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows seek to improve biodiversity provision and ecological networks and Sandwell, which is likely to positively contribute to the conservation and enhancement of the GI/BI network.
CULTURAL HERITAGE
- Policy SHE1: Listed buildings and conservation areas states that development proposals will be required to "conserve and enhance local character" and those aspects of the historic environment together with their settings.
- Policy SHE2: Development in the historic environment states that areas of distinctive heritage within the borough will be "retained and, wherever possible, enhanced and their settings respected".
- Policy SHE3: Locally listed buildings ensures heritage assets are conserved and enhanced, stating that development proposals affecting locally listed buildings will only be permitted where they "positively contribute towards the significance of the heritage asset and avoid harm".
- Policy SHE4: Archaeology states that "development should protect and conserve both designated and non-designated archaeological assets and the character and setting of areas of acknowledged archaeological significance". The policy also requires sites with known archaeological potential to provide an archaeological assessment and / or field evaluation.
- Many SLP policies including Policy SDS1: Spatial Strategy for Sandwell and SDS3: Regeneration in Sandwell encourage regeneration and redevelopment of industrial land, town centres and canal corridors with potential opportunities for enhancement of cultural heritage features and historic buildings which can contribute to creating a strong sense of place and celebrating Sandwell's history.
- Policy SNE6: Canals recognises the historic, architectural, archaeological and cultural significance of the canal network and will ensure that any development proposals affecting canals will protect and enhance these aspects.
HUMAN HEALTH
- Policy SDS1: Spatial Strategy for Sandwell seeks to direct housing growth towards locations with the highest levels of sustainable transport access to services including healthcare facilities.
- Policy SHW1: Health Impact Assessments sets out the requirement for certain development proposals to undertake an HIA to ensure that adverse effects associated with physical and mental health and access to and demand for health and social care services are addressed, and that opportunities for promoting healthy lifestyles are maximised.
- Policy SHW2: Healthcare infrastructure states that new healthcare facilities should "well-designed" and "well-served by public transport infrastructure". Furthermore, the policy requires any development that has unacceptable impacts upon the functionality of healthcare facilities to "contribute to the provision or improvement of such services", and will ensure there is sufficient capacity in healthcare infrastructure to serve new growth.
- Policy SDM9: Community facilities includes measures to increase provision for community and leisure facilities, which has potential to encourage site end users to live active and healthy lifestyles.
- Policy STR1: Priorities for the development of the transport network states that "all new developments must provide adequate access for all modes of travel, including walking, cycling and public transport", which will likely improve access to healthcare and leisure facilities.
- Policy SDS1: Spatial Strategy for Sandwell will ensure that new public open spaces are created to serve new housing developments.
LANDSCAPE
- Policy SHE1: Listed buildings and conservation areas states that development proposals will be required to "conserve and enhance local character". This is supported by Policies SHE2: Development in the historic environment, SHE3: Locally listed buildings and SHE4: Archaeology, which will ensure the protection and enhancement of heritage assets within the borough to positively contribute to local character and distinctiveness.
- Policy SDS8: Green and blue infrastructure in Sandwell provides measures to support green and blue infrastructure within the borough, which is expected to positively contribute to the locally distinctive landscape and townscape character. Policy SDS2: Increasing efficiency and resilience supports this by encouraging an increase in green cover and the incorporation of "landscaping schemes".
- Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows supports the provision, retention and protection of trees, woodlands and hedgerows, which would also be expected to contribute towards the conservation and enhancement of landscape character through urban greening.
- Policy SNE5: The Rowley Hills aims to protect the Rowley Hills from inappropriate development that will lead to the loss of valued qualities that make up the local landscape character, including panoramic views.
- Policies SDM1: Design quality, SDM2: Development and design standards, SDM3: Tall buildings and gateway sites, SDS5: Achieving well-designed places and other Development Management policies seek to ensure that new development creates a strong sense of place and help to conserve and enhance the landscape / townscape character, and will ensure the visual effects of relevant proposals (such as tall buildings) are identified and assessed.
- Many SLP policies including Policy SDS1: Spatial Strategy for Sandwell and SDS3: Regeneration in Sandwell encourage regeneration and redevelopment of industrial land, town centres and canal corridors with potential opportunities for enhancement of Sandwell's townscapes which can contribute to creating a strong sense of place and improve the appearance and function of urban areas.
POPULATION & MATERIAL ASSETS
- Policy SHO1: Delivering sustainable housing growth and Policy SDS1: Spatial Strategy for Sandwell supports the delivery of 10,434 homes in order to contribute to meeting the identified housing need which providing a range of choice of new homes, whilst setting out locations of housing land supply including for potential windfall developments as set out in Policy SHO2: Windfall developments.
- Policy SHO3: Housing density, type and accessibility seeks to provide a "range of types and sizes of accommodation" in order to create "mixed, sustainable and inclusive communities", which is supported by Policy SHO4: Affordable housing which aims to provide a proportion of affordable homes on developments of ten or more residences.
- Other policies such as Policy SHO5: Delivering accessible and self / custom build housing, Policy SHO6: Protecting family housing (Use Class C3) and Policy SHO7: Houses in multiple occupation set out a variety of regulations to ensure housing standards meet the needs of occupants.
- Policy SHO9: Accommodation for Gyspies, Travellers and Travelling Showpeople seeks to protect existing Gyspy, Traveller and Travelling Showpeople sites and ensures a sufficient number of pitches are allocated to meet the identified need.
- Policy SDS3: Regeneration in Sandwell states that the defined Regeneration Areas will provide high-quality employment land and will be the principal location for new industrial/logistics development, with likely benefits in terms of economic growth and providing opportunities for developing a skilled workforce.
- Policies SDM1: Design Quality, STR1: Priorities for the development of the transport network, STR2: Safeguarding the development of the KRN, STR3: Managing transport impacts of new development and STR5: Creating coherent networks for cycling and walking ensure that residents have sustainable access to employment opportunities through well-designed places and strong transport infrastructure.
- Policies SID2: Digital infrastructure and SDM10: Telecommunications will aim to improve access to employment opportunities, including home working, through the provision of a strong fibre network and telecommunications infrastructure.
- Policy SHO8: Education facilities supports the development or expansion of education facilities and states that nurseries, schools and higher education facilities should be "well- designed" to increase the quality and capacity of educational facilities.
- Policy SHW5: Playing fields and sports facilities states that playing fields and sports facilities "will be encouraged, especially in areas where public provision is deficient".
- Policy SWA1: Waste infrastructure future requirements sets out the waste infrastructure requirements to be adhered to throughout the borough, seeking to reduce the generation of waste and associated pollution, promote re-use and recycling of waste in line with the waste hierarchy. The policy ensures the "minimisation of waste production and the re-use and recovery of waste materials" by providing sufficient waste facilities.
- Policies SWA2: Waste sites, SWA3: Preferred areas for new waste facilities and SWA4: Locational considerations for new waste facilities set out measures to ensure waste facilities meet the demand of the borough in regard to capacity. These make sure waste facilities are sustainable by nature/design, whilst being strategically located in suitable locations.
SOIL
- The proposed development strategy for the SLP promotes the use of brownfield land as much as possible. Policy SDS1: Spatial Strategy for Sandwell states that development within the borough will seek to achieve sustainable development through "delivering development on brownfield sites in the urban area".
- Underpinning Policy SDS1 are Policies SDS3: Regeneration in Sandwell which focuses on regeneration of existing urban areas, SCO3: Land contamination and instability which encourages development to make use of contaminated land, SDM3: Tall Buildings and Gateway Sites which supports higher density development which will reduce overall land-take and make efficient use of land, and SHO2: Windfall developments which aims to prevent the use of unallocated greenfield land for development. These policies will help to ensure undeveloped land is protected and that previously developed land in urban areas is utilised.
- Policies SNE1: Nature conservation, SNE2: Protection and enhancement of wildlife habitats, SNE3: Provision, retention and protection of trees, woodlands and hedgerows, SDS7: Sandwell's Green Belt and SDS8: Green and blue infrastructure in Sandwell, include measures that protect land and soil resources with ecological, agricultural or environmental value.
WATER
- Various SLP policies including SNE1: Nature Conservation, SNE2: Protection and enhancement of wildlife habitats, SNE3: Provision, retention and protection of trees, woodlands and hedgerows, SDM1: Design Quality, SDS7: Sandwell's Green Belt and SDS8: Green and blue infrastructure in Sandwell encourage enhancements to the provision and connectivity of GI/BI, which will help to support ecosystem service functions such as the filtration of water and could potentially result in improvements to water quality.
- Policy SNE6: Canals requires development proposals to protect and enhance the canal network, including the water quality of canals.
- Policy SCC5: Flood Risk seeks to ensure that no development is permitted within a groundwater SPZ that could physically disturb an aquifer. This is supported by Policy SCC6: Sustainable drainage which outlines requirements for the inclusion of SuDS in development proposals which can play a role in improving water quality as specified. Policy SDS2: Increasing efficiency and resilience seeks to improve water efficiency through employing high environmental standards in the design of new developments.
- Policy SCC3: Climate adapted design and construction sets out the requirement for all non-residential development of 1,000m2 or more to achieve a BREEAM New Construction Certification of 'Very Good' or 'Excellent' depending upon the nature of development, which includes full credits for water efficiency.
- Policy SHW1: Health Impact Assessments will ensure an HIA is undertaken for the majority of new developments, to ensure that the construction and occupation of new residencies will have sufficient capacity to meet the needs of residents such as water supply
- Policy SHO9: Accommodation for Gyspies, Travellers and Travelling Showpeople are required to ensure there is adequate provision for on-site services such as water supply
- Policy SDM7: Management of hot food takeaways assists with the prevention of fats from reaching the wastewater system in order to minimise blockages.
Residual effects
N105 The SLP provides a range of policies which will likely help mitigate some of the adverse impacts of the proposed development, as outlined in Table N.19 above. However, where these policies will be unlikely to fully mitigate the identified effects, the following residual effects are identified and drawn to the attention of the plan makers.
N106 The overall residual positive effects of the Plan are set out in Table N.20, and the residual adverse effects in Table N.21.
Table N.20: Likely residual positive sustainability effects of the SLP
Summary of residual positive effects
1
Improved provision of multi-functional green infrastructure
The SLP promotes the conservation and enhancement of the multi-functional GI network through encouraging development proposals to increase connectivity of the wider green and blue infrastructure network.
Although the proposed development within the SLP will result in the loss of greenfield land and associated GI to some extent, the SLP policies are expected to mitigate and re-compensate for this loss of GI, resulting in a positive effect on GI provision in the longer term.
2
Effects on the historic environment
Where development is located in areas of distinctive heritage or in proximity to non-designated heritage assets within the HLC, these are likely to be mitigated through SLP policies by protecting, conserving and enhancing historic, architectural and archaeological features. The SLP encourages regeneration including that of historic features, industrial areas and canal networks and is therefore likely to have positive effects on the conservation and enhancement of historic areas such as APAs, AHHTVs and DLHHVs.
3
Provision of public greenspace
Various SLP Policies aim to provide a range of open spaces, sports facilities and recreational spaces for site end users including compensating for any facilities lost to development. This is expect to supplement public and recreational space in Sandwell and subsequently encourage active and healthy lifestyles.
4
Access to PRoW or cycle network
A large number of site allocations are expected to link to existing PRoW routes which have good coverage across the borough, and some allocations are located in proximity to cycle paths. Various SLP policies seek to promote cycling and walking, which is likely to improve the coverage of and accessibility to the PRoW, pedestrian and cycle networks across Sandwell. This would be expected to encourage residents to participate in physical exercise and active travel, with benefits to health and wellbeing.
5
Impacts of locally distinctive or sensitive landscapes
The SLP policies are expected to contribute positively to maintaining and improving the distinctiveness of Sandwell's landscape and townscape character through encouraging the conservation and enhancement of town centres, biodiversity areas and historic assets.
No allocations are situated in areas of locally distinctive or sensitive landscapes, where the policies prioritise development within the urban area of Sandwell or on PDL whilst encouraging regeneration. The SLP seeks to protect the panoramic views from the Rowley Hills alongside improving GI networks across the borough and it is therefore likely that any potential impacts on landscape and townscape will be fully mitigated, and where possible, enhanced.
6
Provision of housing to meet local need
In order to meet the identified housing need, the SLP proposes to deliver 10,434 new dwellings within the Plan period. Policies set out in the SLP include various requirements to ensure the provision of an appropriate mix of housing types and tenures that will address the needs of different groups including those requiring accessible dwellings, affordable housing and provision for the Gypsy and Traveller community.
7
Provision of employment opportunities
The Plan seeks to deliver 1,221ha of employment land. Various SLP policies are also be expected to improve quality, quantity and access to employment opportunities, such as through improving sustainable transport options, and by locating employment-led development in areas with good accessibility to the road and transport networks.
8
Sustainable access to local services and facilities
The majority of sites allocated in the SLP will locate site end users within a sustainable distance to a number of local services, healthcare and educational facilities. In addition, a variety of sustainable transport options are anticipated to be improved within the SLP area such as the rail and bus networks, and the pedestrian and cycle networks, which is also likely to improve access to these facilities.
The SLP will encourage the co-location of local services and facilities within Sandwell's town centres as well as providing facilities for residents living away from central areas. These facilities will be well-designed with sufficient capacity for an increased number of residents living in Sandwell.
9
Addressing inequalities
The SLP policies demonstrate SMBC's commitment to improving inequalities and enhancing community cohesion. The diverse accommodation needs of the population will be addressed through adequate housing provision and community facilities will be safeguarded and enhanced. Regeneration of town centres and deprived areas is likely to encourage a sense of safety for local residents, whilst improving the accessibility to and capacity of local services, facilities, open spaces and educational provision to deliver a high-quality public realm.
Table N.21: Likely residual adverse sustainability effects of the SLP
Summary of residual adverse effects
1
Increased pollutant emissions
Various SLP policies alongside local, regional and national policies aim to reduce air pollution and promote sustainable modes of transport such as improved walking, cycling and public transport provision. However, the introduction of 10,434 dwellings and 1,221ha of employment floorspace within the Sandwell AQMA is expected to increase vehicle emissions in the SLP area including NO2 and PM10, and result in an overall reduction in air quality on a potentially long-term basis.
Over time, this adverse impact is likely to be reduced to some extent should there be an increase in sustainable transport methods and a phasing out of petrol and diesel-powered cars by 2035, alongside other advances in technology.
2
Exposure to poor air quality and noise pollution
The introduction of 10,434 homes and 1,221ha of employment floorspace in the SLP area is expected to increase the exposure of site-end users to poor air quality within the Sandwell AQMA, and potentially noise pollution as a result of main roads.
The policies would be expected to prevent unacceptable impacts on human health associated with air and noise pollution, but in-combination with the volume of development proposed, there is likely to be a cumulative adverse effect of air quality and noise pollution as a whole which is unable to be fully mitigated by SLP policies alone. The volume of development proposed within the Sandwell AQMA also has potential to hinder meeting the pollutant objectives to set out in the Sandwell Air Quality Action Plan[27].
The exposure to poor air quality and noise pollution is likely to result in a long-term impact which has potential to be reduced through technological advances and improvements in sustainable transport methods such as the phasing out of petrol and diesel-powered cars. However, ongoing exposure to air and noise pollution can contribute to long-term health impacts for site-end users.
3
Threats or pressures to locally designated and non-statutory biodiversity sites
Although locally designated biodiversity sites will benefit from legislative protection including SLP policies which aim to protect, conserve and enhance biodiversity sites, these are unlikely to fully mitigate adverse impacts arising from the proposed development. The proximity of allocated sites to LNRs, SINCs and SLINCs is likely to result in adverse impacts including habitat losses, exposure to poor air quality and recreational pressures.
When considered at a landscape scale, the construction of 10,434 homes and 1,221ha in-combination is likely to result in a long-term and permanent significant effect of locally designated biodiversity, flora and fauna sites.
4
Fragmentation of the ecological network and priority habitats
The SLP is expected to result in the loss of some previously undeveloped land or land with environmental value, including soil resources, priority habitats and ecological links between biodiversity assets.
Fragmentation of the ecological network and priority habitats is likely to be a long-term significant adverse effect, in particular where priority habitats cover 8% of the total site allocation area. Should biodiversity net gain and landscape-scale ecological enhancements be effectively implemented, there is potential for this effect to be temporary and beneficial in the long-term.
5
Increased GHG emissions
The SLP policies aim to increase uptake of sustainable transport and active travel, as well as utilising building design and construction methods to minimise the increase in greenhouse gas emissions related to development. However, the SLP is not expected to fully mitigate these impacts, particularly those related to the occupation of development and increased transported related emissions.
An increase in carbon emissions in Sandwell is likely to be a long-term and permanent significant effect. However, over time, there is potential for technological advances and alternative solutions to reduce this impact to some extent.
6
Increased household waste generation
It is difficult for the SLP to specifically reduce waste generation within the Plan area, although it aims to promote the reduction, re-use and recycling of waste. National trends indicate a general decrease in household waste generation, however the introduction of 10,434 households and 1,221ha of employment land is expected to increase waste production to some extent.
7
Loss of soil resources
Although the majority of sites are located in the urban area and where possible, areas of previously developed land, the proposed allocations would cumulatively result in the loss of up to approximately 224ha of previously undeveloped land or land which may have environmental or ecological value. The loss of permeable soils could potentially increase the risk of flooding and loss of soil biome, resulting in a loss of biodiversity across the Plan area. Loss of soil can also result in an increase in soil erosion and have subsequent impacts on agricultural yield.
8
Increased demand for water and wastewater management
The increased population within the SLP area would be expected to increase demand on water infrastructure. Although the WCS indicted that Severn Trent Water does not expect water supply infrastructure to be a constraint to development within its water resource zone, there is potential for a residual adverse effect in regard to wastewater infrastructure when planned growth is considered in-combination with an increase in sewage production and potential for storm overflow events. It is likely that further monitoring and investment to wastewater infrastructure will be required to accommodate development.
Cumulative effects
N107 The cumulative effects assessment (CEA) is the process of identifying and evaluating the effects that arise when the total significant effects of the Local Plan and assessed alongside known existing underlying trends and other PPPs.
N108 Cumulative effects are different from effects that occur alone. Alone, the Plan may not result in residual adverse effects for a particular topic, for example the effects of urban sprawl on landscape character, but when considered cumulatively, may result in significant effects that require mitigation or monitoring.
N109 Cumulative effects of the Sandwell Local Plan are discussed in Table N.22.
Table N.22: Cumulative effects assessment of the Local Plan
|
Summary of identified effects in the SA process |
Details of cumulative effect |
Cumulative effect |
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Air
|
Nationally, measures to improve air quality are in place and continue to be prioritised by the UK government, which includes proposals to ban sales of petrol and diesel cars by 2035. Local, regional and national policy including the West Midlands Transport Plan[28] and the Sandwell Air Quality Action Plan[29] will complement the SLP policies, seeking to increase the coverage and connectivity of public transport, pedestrian and cycle networks which would be likely to help reduce reliance on private car use. However, due to the introduction of 10,434 dwellings and 1,221ha of employment floorspace through the SLP, all of which will lie within Sandwell AQMA, an increase in traffic flows and subsequent reduction of air quality will be expected to have residual adverse effects which cannot be fully mitigated through the SLP policies alone. Overall, the Plan will likely result in a long-term but potentially temporary significant cumulative adverse effect on air quality, which could result in secondary effects such as for the health of residents. |
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Biodiversity, flora and fauna
|
Biodiversity sites designated for their national, international or local biodiversity value will continue to benefit from legislative protection, and the policy framework set out in the SLP will ensure biodiversity assets are protected, conserved and enhanced where possible. The SLP seeks to increase the coverage of GI, alongside mandatory 10% BNG); however, there remains potential for the proposed development to adversely affect some biodiversity, flora and fauna features when considered together at a landscape scale. Site-based approaches to nature conservation can fail to identify strategic landscape ecological considerations. The background trends indicate an overall picture of habitat losses and reduction in species diversity in the UK. Overall, there is potential for a cumulative adverse effect on biodiversity, owing to the fragmentation of the ecological network and incremental losses of priority habitats. |
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Climatic factors
|
Climate, infrastructure, flood risk, sustainable transport and GI policies within the SLP will be likely to help reduce adverse impacts of the proposed development within the SLP in regard to climatic factors. These policies set out provisions to mitigate the increased GHG emissions, UHI effect, loss of green infrastructure and exacerbated flood risk that may potentially occur as a result of the proposed development. Despite these policies, it is likely there will be a cumulative increase in GHG emissions during occupation of new development including those associated with increased energy demand associated with the occupation of new dwellings and employment premises, transport-related emissions, the production and use of materials during construction, and the release of embodied carbon. Overall, the SLP could potentially result in a cumulative adverse effect on climate change which may lead to secondary effects such as flood risk, threats to the health and safety of residents and possibly the supply of water across the Plan area. It should be noted that the Future Homes Standard is expected to come into effect in 2025 which will seek to ensure that new homes are future-proofed with low-carbon heating systems, air-source heat pumps and high levels of energy efficiency. The necessary legislation is expected to be introduced in 2024, ahead of implementation in 2025. This new standard, coupled with local interventions and consideration of carbon offsetting schemes, has the potential to limit Sandwell's contributions to the climate crisis in the longer term. |
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|
Cultural heritage
|
Sandwell supports range of designated and non-designated historic features. The SLP policies in combination with legislation such as Conservation Area Appraisals[30] will be expected to ensure no significant impacts on the designated heritage assets arise from the proposed development sites. These will further encourage the conservation and enhancement of historic, architectural and archaeological features which may lead to longer term benefits to Sandwell's historic environment through encouraging regeneration and redevelopment of industrial land, town centres and canal corridors. |
0 |
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Human health
|
The majority of site allocations in the SLP are located in areas with good sustainable access to healthcare facilities and sustainable transport options, as well as walking and cycling links. SLP policies are likely to increase sustainable access to facilities, as well as improving the quality and capacity of existing services and ensure a range of greenspaces and recreational facilities are provided for new and existing communities. A positive cumulative effect is therefore expected in relation to sustainable access to health facilities, active travel and recreation. |
+ |
|
Human health
|
Air and noise pollution associated with road traffic and AQMAs can have adverse implications for health. Although various SLP policies seek to minimise exposure to pollution, the development proposed may lead to a cumulative adverse effect on air quality as discussed in the 'air' section above. |
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|
Landscape
|
The SLP focuses the majority of growth within the existing urban area. The SLP policies seek to ensure that development proposals maintain and improve the distinctiveness of Sandwell's landscape and townscape character, including through the provision of GI, urban greening, the protection of historic assets, appropriate design and the consideration of views from sensitive landmarks such as the Rowley Hills. Where relevant, the SLP policies will ensure the potential for adverse effects is explored, including through LVA/LVIA to inform the development of any tall buildings. There is potential for a cumulative positive effect on the landscape in the medium-long term, where the SLP seeks to ensure development proposals enhance and regenerate Sandwell's landscape, townscape and historic environment. |
+ |
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Population and material assets
|
The SLP is likely to have a positive cumulative effect on the population and the economy, due to the provision of new homes and jobs to meet the varied needs of the community. Although issues with housing affordability are likely to continue with Sandwell and nationally, the SLP seeks to deliver affordable housing and a range of type, tenure and size of homes in line with the identified housing needs. The SLP policies demonstrate SMBC's commitment to enhancing community cohesion and improving inequalities by addressing the diverse accommodation needs of the population, safeguarding community services and facilities, and encouraging development proposals to incorporate careful design which delivers a high-quality public realm. The SLP is anticipated to result in a positive cumulative effect on local communities through improving opportunities for social interaction, sense of place and reducing social inequalities. |
+ |
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Population and material assets
|
The introduction of 10,434 dwellings and 1,221ha of employment floorspace through the SLP is likely to increase waste generation over the Plan period. Although recycling rates are increasing on a national scale, it is unlikely this will help to significantly decrease waste generation within the Plan area. A long-term permanent negative cumulative effect is expected for waste. |
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Soil
|
Nationally, rates of soil erosion are increasing. Soil is a non-renewable resource, which performs a number of important ecosystem services and supports a diverse range of habitats. Despite seeking to make the best use of available brownfield sites, and ensuring the protection of high-quality agricultural land, the proposed allocations within the SLP will cumulatively result in the loss of up to 224ha of previously undeveloped land or land which may have environmental / ecological value. Although the SLP aims to increase GI provision across the Plan area, the loss of permeable soils has potential to increase the risk of flooding and result in a loss of biodiversity across the Plan area. Loss of soil can also result in an increase in soil erosion and have subsequent impacts on air quality, agricultural yield and the ability of soil biome to effectively provide ecosystem services. Overall, there is potential for a long-term, irreversible cumulative adverse effect on ecosystem services. |
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Water
|
The increased population in the Plan area would be expected to increase demand on water supply and management. The WCS (2024)[31] indicates that Severn Trent Water do not expect water supply infrastructure to be a constraint to development within Sandwell, and water efficiency is increasing nationally. Water abstraction, consumption and treatment in the local area will continue to be managed by the Environment Agency and water companies through the RBMP, WRMP and CAMS in line with the EU Water Framework Directive. Development within the allocated sites has potential to lead to an increased risk of watercourse and groundwater contamination. The WCS (2024) has identified potential impacts for downstream water quality as a result of growth within the Plan area. In combination with climate change and increased storm events, this is likely to lead to increased potential for overflows of untreated sewage and storm water into nearby waterbodies. A long-term cumulative effect has been identified in terms of water quality. |
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Monitoring
N110 Monitoring proposals are set out in Table N.23 for SMBC to consider in the implementation of the SLP.
Table N.23: Proposals for monitoring adverse sustainability impacts of the SLP
|
Theme/ SEA Regulations |
Indicator |
Scale and frequency |
Target |
|
Air |
Concentration of NO2 and PM10 |
Annually, Plan area wide |
Decrease |
|
Air |
Traffic flows on main roads |
Bi-annually, Plan area wide |
Decrease |
|
Air |
Rates of public transport uptake |
Annually, Plan area wide |
Increase |
|
Biodiversity, flora and fauna |
Percentage of SSSIs in favourable condition |
Annually, Plan area wide |
Increase |
|
Biodiversity, flora and fauna |
Number of planning approvals granted contrary to the advice of Natural England or Birmingham and Black Country Wildlife Trust |
Annually, Plan area wide |
Zero |
|
Biodiversity, flora and fauna |
Percentage loss of the ecological network |
Annually, Plan area wide |
Zero |
|
Biodiversity, flora and fauna |
Quality and extent of priority habitats |
Annually, Plan area wide |
Increase |
|
Biodiversity, flora and fauna |
Canopy cover within Sandwell |
Every 3 to 4 years, Plan area wide |
Increase |
|
Climatic factors |
CO2 emissions per capita |
Annually, Plan area wide |
Decrease |
|
Climatic factors |
Percentage of energy generated from renewable sources |
Annually, Plan area wide |
Increase |
|
Climatic factors |
Number of properties at risk of flooding |
Annually, Plan area wide |
Decrease |
|
Climatic factors |
Extent of surface water flood risk within Sandwell |
Annually, Plan area wide |
Decrease |
|
Cultural heritage |
Number of conservation area appraisals |
Annually, Plan area wide |
Increase |
|
Cultural Heritage |
Number of heritage assets identified as 'heritage at risk' |
Annually, Plan area wide |
Decrease |
|
Human health |
Percentage of physically active adults |
Bi-annually, Plan area wide |
Increase |
|
Human health |
Number of GP surgeries |
Annually, Plan area wide |
Increase |
|
Landscape |
Quantity of development in sensitive landscapes |
Annually, Plan area wide |
Zero |
|
Population and material assets |
Number of affordable housing completions |
Annually, Plan area wide |
Increase |
|
Population and material assets |
Percentage of economically active residents |
Annually, Plan area wide |
Increase |
|
Population and material assets |
LSOAs in Sandwell within the 10% most deprived in Great Britain |
Every 3 to 4 years, Plan area wide |
Decrease |
|
Population and material assets |
Quantity of household waste sent to landfill |
Annually, Plan area wide |
Decrease |
|
Soil |
Number of dwellings built on PDL |
Annually, Plan area wide |
Increase |
|
Soil |
Area of contaminated land remediated |
Annually, Plan area wide |
Increase |
|
Water |
Number of planning permissions granted contrary to EA advice |
Annually, Plan area wide |
Zero |
|
Water |
Number of waterbodies classified as 'good' ecological status |
Annually, Plan area wide |
Increase |
|
Water |
Number of overflow events of untreated sewage discharges into rivers |
Annually, Plan area wide |
Zero |
|
Water |
Water efficiency in new homes |
Annually, Plan area wide |
Increase |
|
Water |
Water availability for extraction |
Annually, Plan area wide |
Increase |
Consultation and next steps
N111 The Regulation 19 SA Report will be published alongside the Publication Draft Version of the Sandwell Local Plan.
N112 A minimum of six-week period of consultation will be undertaken by SMBC to offer statutory consultees, stakeholders, organisations and individuals an opportunity to submit representations regarding the SLP, as well as the supporting evidence including this SA Report.
N113 Following this round of consultation, all comments will be analysed by the plan makers as part of the ongoing plan making process. Further stages of SA will be prepared if and when necessary.
[26] Oxford Archaeology (2019) Black Country Historic Landscape Characterisation Study. Available at: https://blackcountryplan.dudley.gov.uk/media/13895/comp_black-country-hlc-final-report-30-10-2019-lr_redacted.pdf [Date accessed: 07/08/24]
[27] SMBC (2020) Air Quality Action Plan 2020-2025. Available at: https://www.sandwell.gov.uk/downloads/download/396/air-quality-action-plan-2020-2025 [Date accessed: 28/08/24]
[28] Movement for Growth: The West Midlands Strategic Transport Plan. Available at: https://www.tfwm.org.uk/media/3ukj3yw0/movement-for-growth.pdf [Date accessed: 23/08/24]
[29] SMBC (2020) Air Quality Action Plan 2020-2025. Available at: https://www.sandwell.gov.uk/downloads/download/396/air-quality-action-plan-2020-2025 [Date accessed: 23/08/24]
[30] SMBC. Conservation Area Appraisals. Available at: https://www.sandwell.gov.uk/planning/historic-environment/3 [Date accessed: 29/08/24]
[31] JBA Consulting (2024) Sandwell Phase 2 Water Cycle Study.
