Sustainability Appraisal of the Sandwell Local Plan 2024-2041

5 Reasonable alternatives

5.1 Context

5.1.1 Regulation 12 of the SEA Regulations[32] states that: "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".

5.1.2 PPG[33] states that: "Reasonable alternatives are the different realistic options considered by the plan-maker in developing the policies in its plan. They must be sufficiently distinct to highlight the different sustainability implications of each so that meaningful comparisons can be made".

5.1.3 The Council has therefore demonstrated how they have identified, described and evaluated reasonable alternatives as part of the plan making process within this SA Report (which includes the requirements of an SEA Environmental Report). The following sections of this chapter document the process of identifying and evaluating different types of reasonable alternative, when and where the Council considered reasonable alternatives, and how the SA influenced the preparation of the SLP.

5.2 Different types of reasonable alternatives

5.2.1 It is possible to derive reasonable alternatives for different aspects of a local plan. There is no prescribed formula or procedure about which aspects of a local plan require reasonable alternatives.

5.2.2 In the case of the SLP, all reasonable alternatives have been identified and described by SMBC as the Plan makers. Reasonable alternatives have been identified through consultation and engagement with stakeholders, including through the formal consultation periods, as well as a number of exhibitions, member workshops, and outreach via social media[34].

5.2.3 Further consideration of reasonable alternatives has been undertaken throughout the drafting process of the Plan, for example by issuing a Call for Sites. The Council also reassessed and reconsidered the role of previously identified / allocated sites in terms of their suitability for either housing, employment or other uses. In addition, consultation responses from stakeholders and other interested parties helped to refine the site allocation process and the 'fine tuning' of these sites, including for additional or alternative use to be made of a site or infrastructure provision.

5.2.4 A range of reasonable alternatives have been considered throughout the plan making process, including for the following different attributes of the SLP:

• Housing Growth Options x6 (see the Regulation 18(II) SA, 2023);
• Employment Growth Options x4 (see the Regulation 18(II) SA, 2023);
• Gypsy and Traveller Growth Options x3 (see the Regulation 18(II) SA, 2023);
• Spatial Growth Options x4 (see the Regulation 18(II) SA, 2023);
• Development Sites x124 (120 within the Regulation 18(II) SA, 2023; and four additional sites as part of this consultation (see Appendix E)).

5.2.5 Figure 5.1 summarises the reasonable alternatives considered throughout the plan making process, and at which chronological stage of the SA process these alternatives have been identified, described and evaluated.

Figure 5.1: The identification, description and evaluation of reasonable alternatives considered throughout the plan making process

5.3 Housing growth options (2023)

5.3.1 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[35] (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.

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

Table 5.1: Housing growth options identified by SMBC (see Regulation 18 (II) Draft Plan SA Report 2023)

5.3.3 Table 5.2 summarises the SA findings. The assessments are presented in full within the Regulation 18(II) Draft Plan SA (2023)[37].

Table 5.2: Summary SA findings for assessment of housing growth options A-F

5.3.4 As discussed in the Regulation 18 (II) Draft Plan SA Report, the high-level assessment of housing growth is limited due to the lack of specific information regarding location, density or design of housing, resulting in uncertain impacts being identified for various SA Objectives. Therefore, it should be noted that whilst every effort has been made to predict effects accurately, the sustainability impacts have been assessed at a high level and are reliant upon the understanding of the baseline at the time of their assessment.

5.3.5 Options D and E have been identified as the best performing options for housing growth against the majority of objectives. SA Objectives 4 (Climate Change Mitigation), 5 (Climate Change Adaptation), 7 (Pollution) and 8 (Waste) are likely to have the smallest level of impact under Option D. Option E would deliver a slightly larger housing number than Option D, and also seeks to focus new development within the Regeneration Areas and Centres, which is likely to lead to a more efficient use of land and more benefits in terms of rejuvenating Sandwell's centres and ensuring a greater proportion of new residents are located within a sustainable distance of services and facilities. As a result, under SA Objectives 1 (Cultural Heritage), 2 (Landscape), 3 (Biodiversity) and 6 (Natural Resources) Option E has been identified as the best performing.

5.3.6 SA Objectives 9 (Transport and Accessibility), 12 (Health) and 14 (Education, Skills and Training) are likely to result in more positive impacts under Options A, D and E, since these three options deliver the smallest quantum of growth, c.9,500 – 12,500. All options perform similarly against SA Objective 13 (Economy) as the options considered in this assessment focus on housing growth only, and all options are likely to provide good access to employment opportunities within Sandwell.

5.3.7 Option F is identified as the best performing against SA Objective 10 (Housing) given this option would exceed the identified housing need and benefit the wider HMA. Options B, C and F would meet Sandwell's housing need and as such would be most likely to deliver benefits in terms of addressing inequalities (SA Objective 11). However, SA Objectives 2 (Landscape), 3 (Biodiversity), 4 (Climate Change Mitigation), 5 (Climate Change Adaptation), 6 (Natural Resources), 7 (Pollution) and 8 (Waste) are likely to carry more negative impacts under Options B, C and F, as these would all deliver c. 23,500 – 30,000 homes.

5.3.8 Options B, C and F may however not be achievable without significant increases in density, use of undeveloped land and/or significant export of growth, given that there is an existing supply of only 11,194 homes in Sandwell.

5.3.9 On balance, Option E is identified as the best performing option, 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.

5.3.10 It should be noted that although Option E has been selected, the housing quanta associated with Option E has now changed from 11,167 dwellings from 2022-2041 to 10,434 dwellings from 2024-2041. The change in housing number is based on the Plan period changing from 2022-2041 to 2024-2041, as well as the latest evidence regarding the supply of residential land in Sandwell.

5.4 Employment growth options (2023)

5.4.1 Four options for employment growth were assessed within the Draft Plan SA Report[38] (Regulation 18(II), 2018), as shown in Table 5.3.

5.4.2 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)[39] and 2023 update[40] 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 5.3: Employment growth options identified by SMBC (see the R18 (II) Draft SA Report, 2023)

5.4.3 Table 5.4 summarises the SA findings. The assessments are presented in full within the Regulation 18(II) Draft Plan SA (2023)[41].

Table 5.4: SA performance of the employment growth options (see the R18 (II) Draft Plan SA Report, 2023)

5.4.4 It should be noted that whilst every effort has been made to predict effects accurately, the sustainability impacts have been assessed at a high level and are reliant upon the current understanding of the baseline. These assessments have been based on information provided by SMBC, as well as expert judgement.

5.4.5 There is uncertainty regarding the exact impacts that each employment growth option would have owing to the unknown scale and nature of the developments, and the options can act differently against each of the SA Objectives meaning identifying a single best performing option is difficult.

5.4.6 Option B proposes the highest amount of employment land (238ha), and as such performs best against economic objectives, but performs less well against environmental objectives as it would be likely to require the greatest extent of previously undeveloped land. Conversely, Option A performs best against environmental objectives owing to its focus on existing vacant employment land but less well against economic objectives as it would not fulfil Sandwell's identified employment land need.

5.4.7 Option C would provide for the lowest estimate of need according to the EDNA (132ha), and Option D would provide for the mid-range estimate of need (185ha). As such, both options C and D would lead to similar impacts in terms of balancing employment land delivery with reducing potential for adverse effects associated with higher growth targets, although Option C is likely to perform marginally better than Option D for SA Objectives 1 (Cultural Heritage), 2 (Landscape), 3 (Biodiversity), 4 (Climate change mitigation), 5 (Climate change adaptation), 6 (Natural resources), 7 (Pollution), 8 (Waste) and 12 (Health) due to the lower quantum of land being developed for employment purposes.

5.4.8 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.

5.5 Gypsy, Traveller and Travelling Showpeople growth options

5.5.1 The Black Country Gypsy and Traveller Accommodation Assessment (GTAA)[42] 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.

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

Table 5.5: Gypsy, Traveller and Travelling Showpeople growth options identified by SMBC (see the R18 (II) Draft SA Report, 2023)

5.5.3 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[43].

Table 5.6: SA performance of the Gypsy, Traveller and Travelling Showpeople growth options (see the R18 (II) Draft Plan SA Report, 2023)

5.5.4 It should be noted that whilst every effort has been made to predict effects accurately, the sustainability impacts have been assessed at a high level and are reliant upon the current understanding of the baseline. These assessments have been based on information provided by SMBC, as well as expert judgement.

5.5.5 It is difficult to determine an overall best performing option as the performance of each option depends on the SA Objective under consideration, however, it is possible to identify the best option according to performance against specific SA Objectives.

5.5.6 Option B is likely to have the smallest impact against the environmentally focused SA Objectives although negative impacts have still been identified; this is due to Option B having the least number of proposed pitches/plots. However, a minor negative effect has been identified for Option B for the SA Objective 10 (Housing) as it would only partially meet the Gypsy and Traveller need and provides no Travelling Showperson plots.

5.5.7 Option C alone would fulfil all identified needs of the community since it provides all the required pitches and plots, and as such would have a major positive impact on SA Objective 10 (housing), however since it proposes the highest amount of growth it also would be likely to have the greatest potential for adverse effects.

5.5.8 Consequently, 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.

5.6 Spatial growth options

5.6.1 Four spatial growth options were assessed within the Draft Plan SA Report[44] (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, thus helping to meet some of the strategic aims of the emerging SLP.

5.6.2 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 5.7: Spatial growth options identified by SMBC (see the R18 (II) Draft SA Report, 2023)

5.6.3 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[45].

Table 5.8: SA performance of the Spatial growth options (see the R18 (II) Draft Plan SA Report, 2023)

5.6.4 It should be noted that whilst every effort has been made to predict effects accurately, the sustainability impacts have been assessed at a high level and are reliant upon the current understanding of the baseline. These assessments have been based on information provided by SMBC, as well as expert judgement.

5.6.5 It is difficult to determine an overall best performing spatial option as the performance of each option varies depending on the SA Objective in question. Generally, options which perform better against economic needs put the most pressure on environmental or social resources and vice versa.

5.6.6 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.

5.6.7 The Balanced Green Growth spatial strategy has been identified by SMBC drawing on the spatial growth options assessed in the SA process and presented in Policy SDS1, which has been discussed further in Chapter 6 and evaluated in Appendix F.

5.7 Reasonable alternative development sites

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

5.7.2 The Black Country Call for Sites request first opened in July 2017 and re-opened from 9th July – 20th August 2020[46]. Since then, SMBC have carried out annual SHLAAs of sites within which have the potential to accommodate new housing development, factoring in the latest available evidence. Other sources of supply considered for the SLP include sites with planning permission, existing allocations from adopted plans, and sites which have been identified as surplus for example those identified in Open Space strategies.

5.7.3 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
• Sites were also filtered out where the landowner has expressed unwillingness, or sites with one or more significant planning constraints which cannot be mitigated.

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

5.7.5 The Regulation 18 (II) SA Report (2023)[47] 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.

5.7.6 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.

5.7.7 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.

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

5.7.9 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.

5.7.10 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.

5.7.11 All reasonable alternative development sites have been assessed before and after mitigation. The main purpose of this exercise is to avoid any risk of 'green wash': a process whereby immediate application of policy prescription can give the impression that no adverse effects will arise, without knowing the extent of adverse effect that existed in the first place. This process helps achieve transparency in the appraisal process and follows established best practice (RTPI Guidance, 2018[48]) of presenting assessment results before and after mitigation has been applied. Evaluating policies in the SA enables scrutiny of how effective the policies are as mitigation tools.

5.7.12 All reasonable alternative sites have been assessed pre-mitigation in terms of potential impacts on each SA Objective, the results of which are presented in their entirety in Appendix E.

5.7.13 Scores should be read in conjunction with the detailed text narrative provided for each site in the relevant SA report. These tables are intended as an overview of the assessments to provide a useful indicator of sustainability performance associated with each site.

5.7.14 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.

5.7.15 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.

5.8 Selection and rejection of sites

5.8.1 The SA process has been used to evaluate reasonable alternative sites on a comparable basis against the SA Framework to identify likely sustainability impacts. It is SMBC'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.

5.8.2 The SA findings relating to reasonable alternative sites were fed back to the Council on an iterative basis to assist in decision-making regarding the selection or rejection of each site within the emerging SLP.

5.8.3 Appendix H sets out the outline reasons for selection and rejection of all reasonable alternative sites considered throughout the SA process, provided by SMBC.

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