Sustainability Appraisal of the Sandwell Local Plan 2024-2041

Ended on the 11 November 2024

4 Methodology

4.1 Scope of the Sustainability Appraisal

4.1.1 The purpose of the SA Scoping Report is to establish the scope of the sustainability appraisal. It includes information about:

  • Relevant plans, programmes and their environmental objectives which may have a bearing on the SA of the SLP (see Appendix A for further information);
  • Baseline information;
  • Environmental issues and problems; and
  • The SA Framework (see Appendix B).

4.1.2 The SA Scoping Report for the Local Plan was prepared by Lepus in 2023[21]. The Scoping Report was subject to a five-week period of consultation between February and March 2023 with the statutory consultees (Natural England, Historic England and the Environment Agency). No specific comments were received from the statutory consultees regarding the SA Scoping Report; however, responses received at other consultation stages are discussed further in Appendix C.

4.1.3 The appraisal uses objective geographic information relating to environmental receptors, the SA Framework and established standards (where available) to help make the assessment decisions transparent and robust.

4.1.4 The SA Framework is comprised of SA Objectives and decision-making criteria. Acting as yardsticks of sustainability performance, the SA Objectives are designed to represent the topics identified in Schedule 2 of the SEA Regulations[22]. The SA Objectives and the SEA Topics to which they relate are set out in Table 4.1.

4.1.5 Each SA Objective is considered when appraising SLP site allocations, policies and reasonable alternatives. The order of SA Objectives in the SA Framework does not infer prioritisation. The SA Objectives are at a strategic level and can potentially be open-ended. In order to focus each objective, decision making criteria are presented in the SA Framework to be used during the appraisal of policies and sites.

Table 4.1: Summary of the SA Objectives

SA Objectives

Relevance to SEA Regulations - Schedule 2

1

Cultural heritage: Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance.

Cultural heritage

2

Landscape: Protect, enhance and manage the character and appearance of the landscape and townscape, maintaining and strengthening local distinctiveness and sense of place.

Landscape, cultural heritage

3

Biodiversity, flora, fauna and geodiversity: Protect, enhance and manage biodiversity and geodiversity.

Biodiversity, flora and fauna

4

Climate change mitigation: Minimise Sandwell's contribution to climate change.

Climatic factors

5

Climate change adaptation: Plan for the anticipated levels of climate change.

Climatic factors, soil and water

6

Natural resources: Protect and conserve natural resources.

Soil, water and material assets

7

Pollution: Reduce air, soil, water and noise pollution.

Air, water, soil and human health

8

Waste: Reduce waste generation and disposal and achieve the sustainable management of waste.

Population and material assets

9

Transport and accessibility: Improve the efficiency of transport networks by increasing the proportion of travel by sustainable modes and by promoting policies which reduce the need to travel.

Climatic factors, population and material assets

10

Housing: Provide affordable, environmentally sound and good quality housing for all.

Population

11

Equality: Reduce poverty, crime and social deprivation and secure economic inclusion.

Population and human health

12

Health: Safeguard and improve community health, safety and wellbeing.

Human health and population

13

Economy: Develop a dynamic, diverse and knowledge-based economy that excels in innovation with higher value, lower impact activities.

Population and material assets

14

Education, skills and training: Raise educational attainment and develop and maintain a skilled workforce to support long-term competitiveness.

Population

4.2 Best practice guidance

4.2.1 Government policy recommends that both SA and SEA are undertaken under a single SA process, which incorporates the requirements of the SEA Regulations. This can be achieved through integrating the requirements of SEA into the SA process. The approach for carrying out an integrated SA and SEA is based on best practice guidance:

  • European Commission (2004) Implementation of Directive 2001/42 on the assessment of the effects of certain plan and programmes on the environment[23].
  • Office of Deputy Prime Minister (2005) A Practical Guide to the SEA Directive[24].
  • Department for Levelling Up, Housing and Communities (DLUHC) (2023) National Planning Policy Framework (NPPF)[25].
  • DLUHC and Ministry of Housing, Communities & Local Government (MHCLG) (2023) Planning Practice Guidance (PPG)[26].
  • Royal Town Planning Institute (RTPI) (2018) Strategic Environmental Assessment, Improving the effectiveness and efficiency of SEA/SA for land use plans[27].

4.3 Appraisal process

4.3.1 The purpose of this document is to provide an appraisal of the SLP including reasonable alternatives in line with Regulation 12 of the SEA Regulations[28] which states that:

4.3.2 "Where an environmental assessment is required by any provision of Part 2 of these Regulations, the responsible authority shall prepare, or secure the preparation of, an environmental report… [which] shall identify, describe and evaluate the likely significant effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme".

4.3.3 This document also provides information in relation to the likely characteristics of effects, as per the SEA Regulations (see Box 4.1).

Box 4.1: Schedule 1 of the SEA Regulations[29]

Criteria for determining the likely significance of effects (Schedule 1 of SEA Regulations)

The characteristics of plans and programmes, having regard, in particular, to:

  • the degree to which the plan or programme sets out a framework for projects and other activities, either with regard to the location, nature, size and operating conditions or by allocating resources;
  • the degree to which the plan or programme influences other plans and programmes including those in a hierarchy;
  • the relevance of the plan or programme for the integration of environmental considerations in particular with a view to promoting sustainable development;
  • environmental problems relevant to the plan or programme; and
  • the relevance of the plan or programme for the implementation of Community legislation on the environment (e.g. plans and programmes linked to waste management or water protection).

Characteristics of the effects and of the area likely to be affected, having regard, in particular, to:

  • the probability, duration, frequency and reversibility of the effects;
  • the cumulative nature of the effects;
  • the transboundary nature of the effects;
  • the risks to human health or the environment (e.g. due to accidents);
  • the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected);
  • the value and vulnerability of the area likely to be affected due to:
  • special natural characteristics or cultural heritage;
  • exceeded environmental quality standards or limit values;
  • intensive land-use; and
  • the effects on areas or landscapes which have a recognised national, Community or international protection status.

4.4 Impact assessment and determination of significance

4.4.1 Significance of effect is a combination of the sensitivity of receptors and the magnitude of anticipated impacts. Sensitivity can be expressed in relative terms, based on the principle that the more sensitive the resource, the greater the magnitude of the change, and as compared with the do-nothing comparison, the greater will be the significance of effect.

Sensitivity

4.4.2 Sensitivity has been measured through consideration as to how the receiving environment will be impacted by a plan proposal. This includes assessment of the value and vulnerability of the receiving environment, whether or not environmental quality standards will be exceeded, and, for example, if impacts will affect designated areas or landscapes.

4.4.3 A guide to the range of scales used in determining sensitivity is presented in Table 4.2. For most receptors, sensitivity increases with geographic scale.

Table 4.2: Impact sensitivity

Scale

Typical criteria

International/ national

Designations that have an international aspect or consideration of transboundary effects beyond national boundaries. This applies to effects and designations/receptors that have a national or international dimension.

Regional

This includes the regional and sub-regional scale, including county-wide level and regional areas.

Local

This is the district and neighbourhood scale.

Magnitude

4.4.4 Magnitude relates to the degree of change the receptor will experience, including the probability, duration, frequency and reversibility of the impact. Impact magnitude has been determined on the basis of the susceptibility of a receptor to the type of change that will arise, as well as the value of the affected receptor (see Table 4.3).

Table 4.3: Impact magnitude

Impact magnitude

Typical criteria

High

  • Likely total loss of or major alteration to the receptor in question;
  • Provision of a new receptor/feature; or
  • The impact is permanent and frequent.

Medium

Partial loss/alteration/improvement to one or more key features; or

The impact is one of the following:

  • Frequent and short-term;
  • Frequent and reversible;
  • Long-term (and frequent) and reversible;
  • Long-term and occasional; or
  • Permanent and occasional.

Low

Minor loss/alteration/improvement to one or more key features of the receptor; or

The impact is one of the following:

  • Reversible and short-term;
  • Reversible and occasional; or
  • Short-term and occasional.

4.5 Significant effects

4.5.1 A single value from Table 4.4 has been allocated to each SA Objective for each reasonable alternative. Justification for the classification of the impact for each SA objective is presented in an accompanying narrative assessment text for all reasonable alternatives that have been assessed through the SA process.

4.5.2 The assessment of impacts and subsequent evaluation of significant effects is in accordance with Schedule 2 (6) of the SEA Regulations[30], where feasible, which states that the effects should include: "secondary, cumulative, synergistic, short, medium and long-term effects, permanent and temporary effects, positive and negative effects, cumulative and synergistic effects".

Table 4.4: Guide to scoring significant effects

Significance

Definition (not necessarily exhaustive)

Major Negative

--

The size, nature and location of a development proposal would be likely to:

  • Permanently degrade, diminish or destroy the integrity of a quality receptor, such as a feature of international, national or regional importance;
  • Cause a very high-quality receptor to be permanently diminished;
  • Be unable to be entirely mitigated;
  • Be discordant with the existing setting; and/or
  • Contribute to a cumulative significant effect.

Minor Negative

-

  • The size, nature and location of development proposals would be likely to:
  • Not quite fit into the existing location or with existing receptor qualities; and/or
  • Affect undesignated yet recognised local receptors.

Negligible

0

Either no impacts are anticipated, or any impacts are anticipated to be negligible.

Uncertain

+/-

It is entirely uncertain whether impacts would be positive or adverse.

Minor Positive

+

The size, nature and location of a development proposal would be likely to:

  • Improve undesignated yet recognised receptor qualities at the local scale;
  • Fit into, or with, the existing location and existing receptor qualities; and/or
  • Enable the restoration of valued characteristic features.

Major Positive

++

The size, nature and location of a development proposal would be likely to:

  • Enhance and redefine the location in a positive manner, making a contribution at a national or international scale;
  • Restore valued receptors which were degraded through previous uses; and/or
  • Improve one or more key elements/features/characteristics of a receptor with recognised quality such as a specific international, national or regional designation.

4.5.3 When selecting a single value to best represent the sustainability performance, and to understand the significance of effects of a spatial option in terms of the relevant SA Objective, the precautionary principle[31] has been used. This is a worst-case scenario approach. If a positive effect is identified in relation to one criterion within the SA Framework (see the second column of the SA Framework in Appendix B) and a negative effect is identified in relation to another criterion within the same SA Objective, the overall impact has been assigned as negative for that objective. It is therefore essential to appreciate that the impacts are indicative summarily and that the accompanying assessment text provides a fuller explanation of the sustainability performance of the option.

4.5.4 The assessment considers, on a strategic basis, the degree to which a location can accommodate change without adverse effects on valued or important receptors (identified in the baseline).

4.5.5 Significance of effect has been categorised as minor or major. Table 4.4 sets out the significance matrix and explains the terms used. The nature of the significant effect can be either positive or negative depending on the type of development and the design and mitigation measures proposed.

4.5.6 Each reasonable alternative that has been identified in this report has been assessed for its likely significant impact against each SA Objective in the SA Framework, as per Table 4.4. Likely impacts are not intended to be summed.

4.5.7 It is important to note that the assessment scores presented in Table 4.4 are high level indicators. The assessment narrative text should always read alongside the significance scores.

4.6 SEA topic methodologies and assumptions

4.6.1 A number of topic specific methodologies and assumptions have been applied to the appraisal process for specific SA Objectives (see Appendix D). These should be borne in mind when considering the assessment findings.

4.7 Limitations of predicting effects

4.7.1 SA/SEA is a tool for predicting potential significant effects. Predicting effects relies on an evidence-based approach and incorporates expert judgement. It is often not possible to state with absolute certainty whether effects will occur, as many impacts are influenced by a range of factors such as the design and the success of mitigation measures.

4.7.2 The assessments in this report are based on the best available information, including that provided to Lepus by the Council and information that is publicly available. Every attempt has been made to predict effects as accurately as possible.

4.7.3 SA operates at a strategic level which uses available secondary data for the relevant SA Objective. All reasonable alternatives and preferred options are assessed in the same way using the same method. Sometimes, in the absence of more detailed information, forecasting the potential impacts of development can require making reasonable assumptions based on the best available data and trends. However, all options must be assessed in the same way and any introduction of site-based detail should be made clear in the SA report as the new data could potentially introduce bias and skew the findings of the assessment process.

4.7.4 The assessment of development proposals is limited in terms of available data resources. For example, up to date ecological surveys and/or landscape and visual impact assessments have not been available. The appraisal of the SLP is limited in its assessment of carbon emissions, and greater detail of carbon data would help to better quantify effects.

4.7.5 All data used is secondary data obtained from the Council or freely available on the internet.


[21] Lepus Consulting (2023) Sustainability Appraisal of the Sandwell Local Plan: Scoping Report. Available at: https://www.sandwell.gov.uk/downloads/file/896/sandwell-local-plan-issues-and-options-sustainability-appraisal-scoping-reportDate accessed: 21/05/24]

[22] 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)."

[23]European Commission (2004) Implementation of Directive 2001/42 on the assessment of the effects of certain plan and programmes on the environment. Available at: http://ec.europa.eu/environment/archives/eia/pdf/030923_sea_guidance.pdf [Date accessed: 07/08/24]

[24]Office of Deputy Prime Minister (2005) A Practical Guide to the SEA Directive. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/7657/practicalguidesea.pdf [Date accessed: 07/08/24]

[25]DLUHC (2023) National Planning Policy Framework, December 2023. Available at: https://www.gov.uk/government/publications/national-planning-policy-framework--2 [Date accessed: 07/08/24]

[26]DLUHC & MHCLG (2023) Planning practice guidance. Available at: https://www.gov.uk/government/collections/planning-practice-guidance [Date accessed: 07/08/24]

[27]RTPI (2018) Strategic Environmental Assessment, Improving the effectiveness and efficiency of SEA/SA for land use plans. Available at: https://www.rtpi.org.uk/research/2018/january/strategic-environmental-assessment-seasa-for-land-use-plans/ [Date accessed: 07/08/24]

[28] The Environmental Assessment of Plans and Programmes Regulations 2004 (SEA Regulations). Available at: https://www.legislation.gov.uk/uksi/2004/1633/contents/made [Date accessed: 07/08/24]

[29] The Environmental Assessment of Plans and Programmes Regulations 2004 (SEA Regulations). Available at: https://www.legislation.gov.uk/uksi/2004/1633/contents/made [Date accessed: 07/08/24]

[30] The Environmental Assessment of Plans and Programmes Regulations 2004 (SEA Regulations). Available at: https://www.legislation.gov.uk/uksi/2004/1633/contents/made [Date accessed: 05/03/24]

[31]The European Commission describes the precautionary principle as follows: "If a preliminary scientific evaluation shows that there are reasonable grounds for concern that a particular activity might lead to damaging effects on the environment, or on human, animal or plant health, which would be inconsistent with protection normally afforded to these within the European Community, the Precautionary Principle is triggered".

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