Sustainability Appraisal of the Sandwell Local Plan 2024-2041

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3 Evolution of the environment without the Plan

3.1 Overview

3.1.1 The SEA Regulations requires the Environmental Report to present "information on the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme".

3.1.2 In the absence of the SLP, no new plan-led development would occur within the Plan area over and above that which is currently proposed in the adopted Core Strategy and SAD. In this scenario, an appeal-led system would predominate. The nature and scale of development that may come forward under an appeal-led system would be uncertain. In a 'no plan' scenario, other plans and policies would continue to be a material consideration in planning decisions and legislative protection would continue to be in place.

3.1.3 Table 3.1 considers the likely evolution of the baseline within Sandwell in the absence of the SLP. This takes into account information gathered at the Scoping stage and more up-to-date data and statistics.

Table 3.1: Likely evolution without the Plan

Theme

Likely evolution without the Plan

Air

Sandwell Air Quality Management Area (AQMA) covers the whole local authority area and the principal pollutant affecting air quality is nitrogen dioxide (NO₂), mostly sourced from road traffic. Continuing to monitor air quality, especially within AQMAs, and implementation of measures outlined in Air Quality Action Plans will ensure that objectives are in place to decrease exceedances over time.
Traffic and congestion are likely to increase with population growth, with implications in particular for air quality, residents and wildlife. Although national trends suggest there is an increasing uptake of lower emission vehicle types which will be likely to help limit road transport associated emissions in the SLP area, in absence of the plan there may be reduced scope to implement and monitor effective policies and strategies which can facilitate alternative transport modes and encourage behavioural changes to improve air quality.

Biodiversity, flora and fauna

Sites designated for their national and international biodiversity and/or geodiversity value would continue to benefit from legislative protection. The NPPF and its policies relating to biodiversity would continue to be material considerations in planning decisions.
As of February 2024, mandatory biodiversity net gain (BNG) has come into force for Town and Country Planning Act developments, although without the SLP there may be more limited opportunity to strive for higher BNG targets or other biodiversity enhancement measures. Without the SLP there may be less opportunity to establish a strategically planned green infrastructure (GI) network or Local Nature Recovery Network across Sandwell, and/or potential habitat banks for delivering compensatory BNG off-site, where on-site delivery is proved to be unviable.
It may be difficult to ensure that development is of appropriate type, scale and location to avoid adverse impacts on either biodiversity/geodiversity designations (of international or local significance) or on the functioning ecological network of Sandwell and the wider area and the various essential ecosystem services this provides, without the SLP.

Climatic factors

Climatic and anthropogenic-induced climate change are increasing concerns nationally and globally. Without a clear strategy to reduce emissions across all sectors at the local level, Sandwell's contributions towards the causes of climate change may be exacerbated, particularly policies and strategies to facilitate and encourage a modal shift away from private car use.
In absence of a clear growth strategy implemented through the SLP, a less sustainable development pattern could result within Sandwell which could potentially result in an increased need to travel, with associated increases in GHG emissions.
Technological advances, which may include renewable energies, electric vehicles, and efficient electricity supplies, would be expected to occur over time in the UK energy market. However, there may be less opportunity to seek aspirational targets regarding improving energy efficiency within developments in association with meeting the target of carbon neutrality by 2050, in the absence of the SLP.
The risk of flooding will be likely to increase over time due to the changing climate, increasing the occurrence of extreme weather events. Although national policies and legislation will continue to restrict uses within flood zones, without the SLP there may be less control over the location of growth which could limit the effectiveness of strategic GI networks and natural water management functions.

Cultural heritage

National and local guidance seeks to protect designated assets and their settings such as Listed Buildings, Conservation Areas, Scheduled Monuments, and Registered Parks and Gardens, which would continue with or without the SLP.
The Heritage at Risk Register will continue to be managed by Historic England who will continue to work with stakeholders to protect these assets, although there could be less opportunity to focus on regeneration and investment without the SLP.
It is uncertain if connectivity with places, local distinctiveness and culture would be emphasised and protected in the absence of the plan, as it is anticipated that the SLP will require a Heritage Statement or Archaeological Desk-Based Assessment to be prepared to accompany future planning applications, where appropriate.

Human health

Sandwell's population is expected to continue to increase, which is likely to place greater pressure on the capacity of key services and amenities, including health and leisure facilities and housing.
The life expectancy of men and women is anticipated to rise over time, in line with national trends, leading to a greater proportion of older residents with specific needs for housing and services. It may be more difficult to ensure these needs are met in absence of the plan.
Without a clear plan-led development strategy, it is uncertain if existing public green spaces and open spaces would be maintained or enhanced to encourage residents to live healthy and active lifestyles. Existing open spaces may be under greater pressure from windfall development without the SLP.

Landscape

The West Midlands Green Belt will continue to benefit from legislative protection.
In the absence of Plan-led development, there may be less opportunity to promote the conservation and enhancement of the local landscape / townscape character. There could potentially be a rise in the quantity of new development which discords with the local character by altering the style and scale of development, depending on the nature of any future changes to national regulations, such as the proposed revisions to the NPPF and potential implementation of mandatory design codes promoted in the Levelling Up and Regeneration Act.

Population and material assets

The borough's population is forecast to increase by 30,300 between 2016 and 2030^[20], leading to the potential for secondary effects. Without plan-led development, there may be less scope to manage and implement sufficient health, education, social and transport infrastructure to meet local needs and address inequalities.
It is uncertain if future housing provision would satisfy local needs in terms of type, cost and location. There is likely to be a continued increase in the cost of buying or renting housing, although the rate of increase may reduce compared to previous years, in line with national trends. It is uncertain whether affordable housing needs would be met.
Without the influence of the SLP, there would be less planning control over the location of housing with potential for new housing being allowed in unsustainable locations and/or without necessary supporting infrastructure.
Without plan-led development it is likely that housing shortages will be exacerbated. This could lead to existing residents who wish to form new households living in overcrowded conditions or being forced to move outside the area, and potential new residents being unable to move in.
Without a clear plan-led strategy to focus the limited amount of investment into centres and to defend against further investment in out-of-centre locations, the vitality of Sandwell's centres may decline. This could lead to a less sustainable development pattern resulting in an increased need to travel, with associated increases in GHG emissions and potentially exacerbating issues with social exclusion and access to key services.
The overall number of jobs and businesses operating within Sandwell may continue to increase; however, there may be less planning control over the location of employment land and there may be limited job availability in some sectors if land is not allocated through the SLP.
There is likely to be an increase in the proportion of the road transport fleet which are electric or hybrid vehicles, in line with national trends. Over time, there is likely to be a rise in car ownership in general.
The Local Transport Plan will still be implemented, which would be likely to have a positive impact on Sandwell's road network, seeking to relieve congestion and improve provision of public transport across the plan area. Although, in absence of the SLP there may be reduced scope to implement and monitor effective policies and strategies which can facilitate alternative transport modes and encourage behavioural changes.

Soil

Soil is a non-renewable resource that would be likely to continue to be lost. Rates of soil erosion and loss of soil fertility will be likely to continue to rise due to the impacts of agriculture and climate change.

Water

Water abstraction, consumption and treatment in the local area will continue to be managed by the Environment Agency and water companies through the Humber and Severn RBMPs, WRMP and CAMS in line with the Water Framework Directive. However, without plan-led development, there could potentially be new developments that result in over-capacity issues at wastewater treatment works (either cumulatively or individually).
In the absence of plan-led development, the efficiency and sustainability of water consumption may be unlikely to improve as the local population grows and increases water demand, depending on the nature of any future changes to national regulations, such as the Building Regulations and any emerging policy / regulations relating to water neutrality.

^[20]SMBC (2018) Sandwell Trends: Population Projection Release. Available at: https://www.sandwelltrends.info/news/population-projection-release/ [Date accessed: 20/08/24]

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