Sustainability Appraisal of the Sandwell Local Plan 2024-2041

• The SLP Vision and Objectives could be enhanced through incorporating stronger reference to the importance of conservation and enhancement of cultural heritage and the historic environment, such as seeking opportunities for heritage-led regeneration.
• The SLP Vision and Objectives could be strengthened through including wording to promote nature recovery and delivering measurable net gains in biodiversity alongside residential and economic growth.
• The SLP Vision would benefit from stronger reference to the importance of active travel networks in encouraging healthy lifestyles and addressing climate change and air quality impacts associated with road transport.
• The SLP Vision does not directly reference waste or recycling, although waste management is referred to within SLP Objective 10. Wording could be incorporated to recognise the role that the SLP can play in helping to minimise waste generation and promoting the recycling or re-use of materials during construction and occupation of development.
• Although the conservation of natural environments and importance of GI are highlighted through the SLP Vision and Objectives, it is suggested that wording could be included to recognise the importance of conserving and improving air and water quality for both human and ecosystem health. Air pollution in particular is a key issue for Sandwell.

• It is recommended that the policy provides further specification of the GI measures to strengthen the policy.

• Policy would benefit from stronger wording surrounding the historic environment and heritage assets, to ensure that the setting and significance of heritage assets is conserved and enhanced.

• Policy would benefit from stronger wording surrounding heritage assets and how their settings and significance should be conserved and enhanced alongside any proposed "heritage-related tourism" schemes.

• The policy states that "new development will be expected to conserve or enhance the setting and significance of heritage assets". It is recommended that stronger policy wording is used, such as to "conserve and where possible enhance" heritage assets and their setting, to more clearly set out the intention to secure benefits for the historic environment.

• The policy wording could be strengthened to ensure that all new developments contribute towards the provision of affordable homes and that the number/proportion will be determined through site-specific considerations including viability evidence.
• Policy SHO4 could usefully cross-reference to (or incorporate the wording from) Policy SHO6 (NB: now addressed in Policy SID1) to ensure that where providing 25% affordable homes is not possible, the maximum proportion of affordable housing is required that does not undermine the development's viability.
• The policy should include wording to ensure that the affordable housing provided will remain affordable in perpetuity.

• The policy could be strengthened through specifying requirements to ensure such sites are well designed to respect their surroundings and conserve local character, and ensure it is clear what is meant by "reflect any available national guidance".

• Policy SNE1 should take into account the findings / recommendations of the Habitats Regulations Assessment when available.

• The policy would benefit from stronger wording to seek an improvement in air quality and remediation of other pollutants.

• Stronger wording is recommended surrounding the "historic assets" mentioned, regarding how new development could contribute to conserving and enhancing historic assets and their settings.

• It is recommended that the requirement for LVIA/LVA is made clear within the policy wording rather than the supporting text. - landscape

• The policy could be enhanced through ensuring that development, or redevelopment, within these areas seeks opportunities to enhance the historic environment and the coverage and connectivity of GI with multi-functional benefits including for the landscape, biodiversity, flood risk management.

• The policy could be enhanced through ensuring that development, or redevelopment, within these areas seeks opportunities to enhance the historic environment, respect the surrounding landscape character, and seek opportunities to increase coverage and connectivity of GI with multi-functional benefits such as for climate change, landscape, biodiversity and flood risk management.

• The policy could be improved through including reference to the types of adverse effect covered to ensure clarity, for example whether this should include visual impacts, traffic generation, pollution (air, noise, water, soil), disturbance etc.

• It is recommended that the word "conserve" rather than "preserve" is used with regard to cultural heritage, reflecting the wording in the NPPF.

• The Council could consider the potential to merge Policy SHE1 and SHE2 into a single policy to provide a clear position across all designated heritage assets and to avoid repetition.

• The policy would benefit from stronger wording on the requirements for the location of infrastructure and measures that would ensure that the potential for adverse effects on landscape, biodiversity and heritage assets are considered and avoided/mitigated accordingly.

• It is recommended that this policy is expanded to ensure that the species of trees planted and their location within the development is informed by a site-specific survey carried out by a qualified ecologist/arboriculturist.

• Policy SWA4 states "proposals must accord with all other relevant Plan policies in relation to the protection of the environment and public amenity". It is recommended that this statement is expanded, and further detail provided to ensure clarity on the requirements.

• Where a development proposal could potentially result in substantial harm to the significance of a historic asset, clear justification should be provided, for example public benefits outweighing the harm to the asset. This will be particularly applicable if SMBC intend to prepare any site policies to accompany specific allocations at the Regulation 19 stage.

While no specific site-related policies are being introduced into the SLP, it does encourage the use of masterplans where appropriate. These are currently expected to reflect the requirements of the historic environment, and this will continue throughout the life of the SLP. The accompanying suite of policies on the historic environment will need to be taken into account when any such document is drafted.

• Ensure development proposals are in-keeping with the local landscape character and the findings of the most recent Landscape Sensitivity Assessment^[146], or any subsequent evidence prepared.
• Ensure development proposals are constructed in accordance with appropriate design guides and codes, including the 'Design: process and tools'^[147] government guidance.
• Support development proposals which are in accordance with the findings of the Green Belt Study^[148], where relevant.

Noted.

• Policies should support development which aims to protect, and where possible provide, supporting habitat to nearby Habitats sites.
• SMBC could consider implementing an Environmental Net Gain policy which would require developers to deliver a wider range of environmental benefits than BNG alone, such as for air quality and flood risk management^[149][150], which would better reflect the 25-year Environment Plan^[151].
• Protect and enhance the local green and blue infrastructure networks through a specific GI policy. It is recommended that a Green Infrastructure Plan or Strategy is prepared.
• Improve resilience and connectivity of biodiversity sites through landscape scale management.
• Ensure development proposals consider the potential to deliver wider benefits to natural capital and ecosystem services at every opportunity.

The Council is considering the development of a GI strategy and has recently undertaken the revision of the Green Space Audit, which will provide additional evidence for such a strategy. It is also working closely with neighbouring authorities and the West Midlands Combined Authority on a regional Local Nature Recovery Strategy, which is reflected in the NE policies in the SLP.

• Provide necessary infrastructure to encourage low carbon options and carbon neutral development where possible.
• Aim to protect and enhance public space to encourage safe walking and cycling opportunities.
• All development proposals should aim to exceed the standards set out in the Building Regulations.
• Seek to achieve no biodegradable waste to landfill to reduce emissions, in line with 'Net Zero the UK's contribution to stopping global warming'^[152].
• Consider retrofitting buildings to make them more energy efficient.
• It is recommended that further climate change evidence is gathered; this could also help to identify the carbon capture and storage potential of the Plan area.
• Consider local partnerships to establish locally appropriate solutions to the climate crisis.
• Where policies mention GI measures, ensure they are detailed and specific to strengthen individual policies.

The Council has commissioned a review and updating of the extant draft climate change policies for the SLP, which will take into account emerging issues around both mitigation and adaptation.

• Using relevant data sources, ensure development proposals incorporate green infrastructure where appropriate.
• Ensure development proposals do not result in the exacerbation of surface water flood risk in surrounding areas.
• Development proposals should be built in accordance with the relevant Surface Water Management Plan^[153]. It is recommended that the Black County Surface Water Management Plan is updated.
• Ensure capacity of water treatment works is sufficient to support the planned growth through early consultation with relevant water companies.

The Council has commissioned a review and updating of the extant draft climate change policies for the SLP, which will take into account emerging issues around both mitigation and adaptation.

• The retention of trees and other vegetation should be encouraged to help retain the stability of the soil and prevent erosion.
• Effective management should be in place to help prevent pollution and unnecessary compaction of soils during construction. Consider the requirement for Construction Environmental Management Plans in Planning Conditions.
• Where sites contain bare soil following construction of development, it is recommended that vegetation, in particular native plant species, be used to cover the ground.
• Where possible, provide green infrastructure or open space to protect areas of BMV soil within a site boundary.
• Encourage the reuse of contaminated land for new development, where it can be demonstrated that the contamination can be effectively managed or remediated so that it is appropriate for the proposed use.

All these issues are dealt with in the NE policies and throughout the SLP as a whole, including the need to retain and protect trees on development sites, the provision of additional green spaces and the reuse of brownfield sites.

• Where appropriate, planning obligations should be used to secure contributions to tackle poor air quality or for air quality monitoring.
• Development should take into consideration recommendations within the relevant Air Quality Action Plan and the outputs of the Annual Status Reports.
• Ensure visual and auditory buffers are incorporated at the edge of development proposals located in close proximity to railway lines to help mitigate noise pollution.
• Ensure development proposals which could potentially result in an increase in noise disturbance are adequately mitigated, for example, through efficient layout of development, restrict activities at certain times or the use of noise insulation.
• Development proposals should aim to protect areas identified as tranquil. An example method for identifying tranquillity include 'Mapping Tranquility'^[154].
• Development proposals should be built in accordance with recommendations within the Water Cycle Study^[155] and other relevant documents within the Evidence Base, including Water Resource Management Plans, Catchment Flood Management Plan and Basin Management Plans. It is recommended that the Water Cycle Study is updated.

The Council has considered the various potential impacts of pollution in various forms on the health of the residents of the borough and seeks to safeguard the health and quality of life of its residents by refusing applications for planning permission that would give rise to unacceptable levels of noise, odours, light or atmospheric pollution. Issues around flooding and water infrastructure have been taken into account when considering sites for allocation / adoption in the SLP

• Development proposals should demonstrate measures to minimise waste generation during construction.
• Development proposals should integrate well-designated waste storage space to facilitate effective waste storage, recycling and composting.

Included in revised climate change policies on construction waste / demolition.

• Ensure all development proposals and Travel Plans (where applicable) aim to reduce the reliance on the private car where-ever possible and aim to promote access to local facilities and services in a manner which minimises climate change emissions and promotes active travel.

Accessibility by means other than the private car formed part of the assessment process when the Council was considering reasonable alternative sites for both employment and residential development sites. Active travel is also being promoted both through the transport policies and as part of the approach to planning and health set out in the health and wellbeing chapter.

• Ensure all development proposals are built to a high-quality design in line with the 'Design: process and tools'^[156]government guidance.

The Council will be introducing a Sandwell-specific design code and promote high standards of design throughout the SLP, including in relation to the historic and natural environment as well as for new housing and employment sites.

• Ensure residential development proposals incorporate functional private or communal open space, including green space.
• Ensure development proposals provide adequate indoor space in line with, or beyond, the requirements set out in the technical housing standards^[157].
• Where appropriate, consider the option for community ownership of some facilities and services.
• Ensure development proposals promote social interaction, including the establishment of strong neighbourhood centres.
• Ensure development proposals take into account privacy, access to sunlight, noise and disturbance, vibration, artificial lighting, odor, crime and safety.
• Ensure development proposals promote safe and accessible neighbourhoods, helping to reduce crime and the fear of crime.

All these issues are covered across a number of policies in the SLP, and applicants / developers will be expected to deliver all relevant requirements, unless there are clear, specific and robust reasons why this cannot be achieved. In such cases, the Council will require clear evidence demonstrating why this cannot be achieved in whole or in part.

• Development proposals should take into consideration the findings of the relevant Playing Pitch or Sports Strategies, along with other relevant documents within the evidence base.
• Improve or enhance the PRoW and cycle network across the Plan area. It is recommended that the Rights of Way Improvement Plan is updated.
• Provide or improve safe pedestrian and cycle access to public greenspaces and open spaces.
• Development proposals should be in accordance with the relevant Open or Green Space Strategy.
• Ensure development proposals do not result in detrimental impacts to the safety of pedestrians and cyclists.

The Rights of Way mapping is in the process of being updated. Road safety for all users is also being promoted throughout the SLP, as is the importance of green and blue infrastructure. The SLP has also benefitted from the production of an up to date playing pitch strategy, which has been used to identify areas of shortfall and thus inform larger proposals in terms of the need for additional provision.

• Ensure residential-led proposals are located in close proximity to bus stops or other sustainable transport options to reach employment opportunities, informed by the latest available accessibility information.
• Improve access to employment opportunities, through provision of bus stops and bus services, and/or improvements to the local pedestrian and cycle networks.
• Infrastructure policies should be strongly worded to ensure potential for adverse effects on landscape, biodiversity and heritage assets are considered and avoided/mitigated accordingly.

Accessibility by means other than the private car formed part of the assessment process when the Council was considering reasonable alternative sites for both employment and residential development sites.

• Increase the provision and capacity of primary and secondary schools across the Plan area in line with the identified need.

The need for additional educational provision has been the subject of discussions with the Council's education department and areas where additional provision may be required have been considered.