Sustainability Appraisal of the Sandwell Local Plan 2024-2041

Ended on the 11 November 2024

Appendix D: Site Assessment Methodology and Assumptions

D.1 Overview

D.1.1 The purpose of this appendix

D.1.1.1 This appendix provides additional context to Chapter 4 of the main Regulation 19 SA Report (see Volume 2) regarding the methodology used to assess reasonable alternative sites within the emerging Sandwell Local Plan (SLP).

D.1.1.2 Topic-specific methodologies have been established which reflect the differences between the SA Objectives and how different receptors should be considered in the appraisal process for reasonable alternative sites. There are also a number of assumptions and limitations noted within each of the following sections, which should be borne in mind when considering the assessment findings.

D.1.1.3 The topic-specific methodologies set out in Boxes D.2.1 to D.15.3 explain how the likely impact per receptor has been identified in line with the local context and the impact symbols presented in Table 4.4 within the main Regulation 19 SA Report.

D.1.1.4 All distances stated in site assessments are measured 'as the crow flies' from the closest point of the site/receptor in question, unless otherwise stated.

D.1.1.5 Appendix E sets out the detailed appraisal of each reasonable alternative site proposed, pre-mitigation. The appraisal evaluates the likely significant effects of each reasonable alternative against the 14 SA Objectives, using the methodology as set out in this appendix.

D.1.1.6 The mitigating effects of SLP policies are considered within Appendix G.

D.1.1.7 The level of detail that can be expressed through the SA assessments depends on the level of detail provided associated with the part of the plan in question.

D.2 SA Objective 1: Cultural heritage

D.2.1 Introduction and context

D.2.1.1 Boxes D.2.1 to D.2.8 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 1: Cultural heritage.

D.2.1.2 Impacts on heritage assets will be largely determined by the specific layout and design of development proposals, as well as the nature and significance of the heritage asset. There is a risk of adverse effects occurring, some of which may be unavoidable. As such, this risk has been reflected in the assessment as a negative impact where a site is in close proximity to heritage assets.

D.2.1.3 Adverse impacts are recorded for options which have the potential to have an adverse impact on sensitive heritage designations, including Grade I, II* and II Listed Buildings, Scheduled Monuments (SM), Registered Parks and Gardens (RPG), and Conservation Areas (CA).

D.2.1.4 It is assumed that where a designated heritage asset coincides with a site proposal, the heritage asset will not be lost as a result of development (unless otherwise specified in the Local Plan). Development which could potentially be discordant with the local character or setting, for example, due to design, layout, scale or type, would be expected to adversely impact the setting of nearby heritage assets[1] that are important components of the local area. Adverse impacts on heritage assets are predominantly associated with impacts on the existing setting of the asset and the character of the local area, as well as adverse impacts on views of, or from, the asset.

D.2.1.5 Heritage assets identified on Historic England's Heritage at Risk Register may be identified as being at risk for a number of reasons, for example, due to dilapidation of the building fabric or other sources of risk such as coastal erosion, cultivation or scrub encroachment[2]. Where Heritage at Risk assets could potentially be impacted by the proposed development at a site, this has been stated.

D.2.1.6 It should be noted that not all of Sandwell's historic environment resource and heritage assets are subject to statutory designations; non-designated features comprise a significant aspect of heritage, which is often experienced on a daily basis. This may include buildings and other features of historic interest which are not listed, as well as both discovered and undiscovered archaeological remains.

D.2.1.7 It is anticipated that SMBC will require a Heritage Statement or Archaeological Desk-Based Assessment to be prepared to accompany future planning applications, where appropriate.

D.2.2 Cultural heritage receptors

Box D.2.1: SA Objective 1: Grade I Listed Buildings

Score	Likely Impact – Grade I Listed Buildings
--	Development proposal coincides with, is located adjacent to, or could significantly impact the setting of, a Grade I Listed Building.
-	Development proposal located within the wider setting of a Grade I Listed Building.
0	Development proposal is not considered likely to affect the setting or character of a Grade I Listed Building.
+	Development proposal which could potentially enhance a Grade I Listed Building or its setting.

Notes
Grade I Listed Buildings are considered to be those of exceptional interest. Data available from Historic England^[3].

Box D.2.2: SA Objective 1: Grade II* Listed Buildings

Score	Likely Impact - Grade II* Listed Buildings
--	Development proposal coincides with, or could significantly impact the setting of, a Grade II* Listed Building.
-	Development proposal located within the setting of a Grade II* Listed Building.
0	Development proposal not considered likely to impact a Grade II* Listed Building or its setting.
+	Development proposal which could potentially enhance a Grade II* Listed Building or its setting.

Notes
Grade II* Listed Buildings are considered to be those of more than special interest. Data sourced from Historic England^[4].

Box D.2.3: SA Objective 1: Grade II Listed Buildings

Score	Likely Impact - Grade II Listed Buildings
--	Development proposal coincides with a Grade II Listed Building.
-	Development proposal located within the setting of a Grade II Listed Building.
0	Development proposal not considered likely to impact a Grade II Listed Building or its setting.
+	Development proposal which could potentially enhance a Grade II Listed Building or its setting.

Notes
Grade II Listed Buildings are considered to those of special interest. Data sourced from Historic England^[5].

Box D.2.4: SA Objective 1: Scheduled Monuments

Score	Likely Impact - Scheduled Monuments
--	Development proposal coincides with a SM.
-	Development proposal located within the setting of a SM.
0	Development proposal not considered to impact an SM or its setting.
+	Development proposal which could potentially enhance an SM or its setting.

Notes

Scheduling is the selection of a sample of nationally important archaeological sites. Data sourced from Historic England^[6].

Box D.2.5: SA Objective 1: Registered Parks and Gardens

Score	Likely Impact - Registered Parks and Gardens
--	Development proposal coincides with an RPG.
-	Development proposal located within the setting of an RPG.
0	Development proposal not considered likely to impact an RPG or its setting.
+	Development proposal which could potentially enhance an RPG or its setting.

Notes
The main purpose of the Register is to celebrate designed landscapes of note and encourage appropriate protection. Data sourced from Historic England^[7].

Box D.2.6: SA Objective 1: Conservation Areas

Score	Likely Impact - Conservation Areas
-	Development proposal located within a Conservation Area or considered to be located within the setting of a Conservation Area.
0	Development proposal not considered to impact a Conservation Area or its setting.
+	Development proposals which could potentially enhance the character or setting of a Conservation Area.

Notes
Conservation Area data provided by SMBC. Information available online^[8].

Box D.2.7: SA Objective 1: Archaeological Priority Areas

Score	Likely Impact - Archaeological Priority Area
-	Development proposal coincides with an APA.
0	Development proposal does not coincide with an APA.
+	Development proposal which could potentially enhance an APA.

Notes
The Black Country Historic Landscape Characterisation (HLC) Study^[9] aimed to create a strategic landscape-level understanding of the historic character and environment of the Black Country, including Sandwell. The study also identified a number of Archaeological Priority Areas (APAs), which are considered to contain particularly rare or well-preserved remains of high archaeological and historic interest. APA data has been provided by SMBC and is detailed within the HLC report.

Notes

The Black Country Historic Landscape Characterisation (HLC) Study^[9] aimed to create a strategic landscape-level understanding of the historic character and environment of the Black Country, including Sandwell. The study also identified a number of Archaeological Priority Areas (APAs), which are considered to contain particularly rare or well-preserved remains of high archaeological and historic interest.

APA data has been provided by SMBC and is detailed within the HLC report.

Box D.2.8: SA Objective 1: Historic Landscape Characterisation

Score	Likely Impact - Historic Landscape Characterisation
-	Development proposal located within an area of high historic landscape or townscape value and/or area designed landscape of high historic value
0	Development proposal located outside of areas of high historic landscape or townscape value and designed landscapes
+	Development proposal which could potentially enhance historic character.

Notes
The Black Country HLC Study^[10] aimed to create a strategic landscape-level understanding of the historic character and environment of the Black Country, including Sandwell. The study identified several Historic Environment Area Designations (HEADs) within Sandwell's Green Belt and in the urban area. Areas of High Historic Townscape Value (AHHTVs) and Designed Landscapes of High Historic Value (DLHHVs) have also been identified within the HLC. AHHTVs are areas "where built heritage makes a significant contribution to the local character and distinctiveness" and have been identified due to their sense of place, street plan and form, streetscape, views and setting, and representation. DLHHVs are "designed landscapes that make an important contribution to local historic character but do not meet the criteria for inclusion on the national Register of Parks and Gardens" and have been identified due to the date, preservation, aesthetics, and associations with people and past events. HLC data has been provided by SMBC and is detailed within the HLC report.

Notes

The Black Country HLC Study^[10] aimed to create a strategic landscape-level understanding of the historic character and environment of the Black Country, including Sandwell. The study identified several Historic Environment Area Designations (HEADs) within Sandwell's Green Belt and in the urban area.

Areas of High Historic Townscape Value (AHHTVs) and Designed Landscapes of High Historic Value (DLHHVs) have also been identified within the HLC. AHHTVs are areas "where built heritage makes a significant contribution to the local character and distinctiveness" and have been identified due to their sense of place, street plan and form, streetscape, views and setting, and representation. DLHHVs are "designed landscapes that make an important contribution to local historic character but do not meet the criteria for inclusion on the national Register of Parks and Gardens" and have been identified due to the date, preservation, aesthetics, and associations with people and past events.

HLC data has been provided by SMBC and is detailed within the HLC report.

D.3 SA Objective 2: Landscape

D.3.1 Introduction and context

D.3.1.1 Box D.3.1 sets out the specific methodology used to appraise the reasonable alternative sites against SA Objective 2: Landscape.

D.3.1.2 Impacts on landscape are often determined by the specific layout and design of development proposals, as well as the site-specific landscape circumstances, as experienced on the ground. Detailed designs for each development proposal are uncertain at this stage of the assessment. This assessment comprises a desk-based exercise which has not been verified in the field. Therefore, the nature of the potential impacts on the landscape are, to an extent, uncertain. There is a risk of negative effects occurring, some of which may be unavoidable. As such, this risk has been reflected in the assessment as a negative impact where a development proposal is located in close proximity to sensitive landscape receptors. The level of impact has been assessed based on the nature and value of, and proximity to, the landscape receptor in question.

D.3.1.3 Cannock Chase National Landscape/Area of Natural Beauty (AONB) lies approximately 14km to the north of Sandwell Borough at its closest point. Given this distance, there is unlikely to be any significant adverse effects on the special qualities of the National Landscape arising from the proposed development sites. It is assumed that any future development would be accompanied by a Landscape and Visual Impact Assessment (LVIA) or Landscape and Visual Appraisal (LVA) if necessary to consider any potential for adverse impacts.

D.3.1.4 There is no evidence available to inform the SA assessments with regard to the landscape character or sensitivity of Sandwell's urban areas. Information relating to the historic environment, including the Historic Landscape Characterisation and associated designations has been assessed under SA Objective 1: Cultural Heritage (see Box D.2.8).

D.3.2 Landscape receptors

Box D.3.1: SA Objective 2: Landscape sensitivity

Score	Likely Impact - Landscape Sensitivity Assessment
--	Development proposals located within areas of 'moderate-high' or 'high' landscape sensitivity.
-	Development proposals located within areas of 'low-moderate' or 'moderate' sensitivity.
+/-	Development proposals located outside of the Landscape Sensitivity Assessment study area.
0	Development proposals located within areas of 'low' sensitivity, or those not assessed in the study.
+	Development proposals which would protect or enhance features of the landscape as identified within the study.

Notes
The appraisal of sites is informed by the Black Country Landscape Sensitivity Assessment^[11], which assessed the sensitivity of land outside of the urban areas of Sandwell and the other Black Country Authorities (i.e. Green Belt land) to housing and commercial development. The aim of the study was to identify the extent to which the character and quality of Green Belt land is susceptible to change as a result of future development. Parcels of land were classified ranging from 'high' to 'low' sensitivity. As the majority of reasonable alternative development sites identified by SMBC lie outside of the Green Belt, and as such outside of the Landscape Sensitivity Assessment study area, the potential effects of each site on sensitive landscapes are uncertain and would benefit from further site-specific studies to identify any local sensitive views or landscapes. Only one reasonable alternative site, 137 (Poppy Drive Open Space) lies partially within the Green Belt area assessed in the Sensitivity Assessment.

Notes

The appraisal of sites is informed by the Black Country Landscape Sensitivity Assessment^[11], which assessed the sensitivity of land outside of the urban areas of Sandwell and the other Black Country Authorities (i.e. Green Belt land) to housing and commercial development. The aim of the study was to identify the extent to which the character and quality of Green Belt land is susceptible to change as a result of future development. Parcels of land were classified ranging from 'high' to 'low' sensitivity.

As the majority of reasonable alternative development sites identified by SMBC lie outside of the Green Belt, and as such outside of the Landscape Sensitivity Assessment study area, the potential effects of each site on sensitive landscapes are uncertain and would benefit from further site-specific studies to identify any local sensitive views or landscapes. Only one reasonable alternative site, 137 (Poppy Drive Open Space) lies partially within the Green Belt area assessed in the Sensitivity Assessment.

D.4 SA Objective 3: Biodiversity, flora, fauna and geodiversity

D.4.1 Introduction and context

D.4.1.1 Boxes D.4.1 to D.4.9 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 3: Biodiversity, flora, fauna and geodiversity.

D.4.1.2 The biodiversity objective considers adverse impacts of the proposed development at a landscape-scale. It focuses on an assessment of proposed development on a network of designated and undesignated sites, wildlife corridors and individual habitats within the Plan area.

D.4.1.3 Where a site is coincident with, adjacent to or located in close proximity to an ecological receptor, it is assumed that negative effects associated with development will arise to some extent. These negative effects include those that occur during the construction phase and are associated with the construction process and construction vehicles (e.g. habitat loss, habitat fragmentation, habitat degradation, noise, air, water and light pollution) and those that are associated with the operation/occupation phases of development (e.g. public access associated disturbances, increases in local congestion resulting in a reduction in air quality, changes in noise levels, visual disturbance, light pollution, impacts on water levels and quality etc.).

D.4.1.4 It is assumed that construction and occupation of previously undeveloped greenfield land would result in a net reduction in vegetation cover in the Plan area. This would also be expected to lead to greater levels of fragmentation and isolation for the wider ecological network, such as due to the loss of stepping-stones and corridors. This will restrict the ability of ecological receptors to adapt to the effects of climate change. The loss of greenfield land is considered under the Natural Resources objective (SA Objective 6) in this assessment.

D.4.1.5 It should be noted that no detailed ecological surveys have been completed by Lepus to inform the assessments made in this report.

D.4.1.6 Protected species survey information is not available for the sites within the Plan area. It is acknowledged that data is available from the local biological records centre. However, it is noted that this data may be under recorded in certain areas. This under recording does not imply species absence. As a consequence, consideration of this data on a site- by-site basis within this assessment would have the potential to skew results – favouring well recorded areas of the Plan area. As such impacts on protected species have not been assessed on a site-by-site basis.

D.4.1.7 It is anticipated that the Council will require detailed ecological surveys and assessments to accompany future planning applications. Such surveys will determine on a site-by-site basis the presence of Priority Species and Priority Habitats protected under the NERC Act.

D.4.1.8 It is assumed that mature trees and hedgerows will be retained where possible.

D.4.2 Biodiversity receptors

Box D.4.1: SA Objective 3: European sites

Score	Likely Impact – European site e.g. SAC, SPA or Ramsar site
--	Development proposal coincides with, or is located in close proximity to, a European site. Likelihood of direct impacts.
-	Development proposal is located within a recognised ZoI or similar spatial catchment relative to the European site. Likelihood of direct or indirect impacts.
+/-	Development located outside of a recognised ZoI where, in absence of HRA conclusions, the effect of development is uncertain.
0	Development not anticipated to result in adverse impacts on European sites.
+	Development proposals which would be expected to enhance features within a European site.

Notes
The area within which development proposals could potentially have direct, indirect and in-combination impacts on the integrity of a European site is referred to as the Zone of Influence (ZOI). This is determined through an identification of sensitive receptors at each European site (its qualifying features) and pathways via which the Local Plan may have an impact. At this stage, no ZOI have been formally identified for surrounding European sites, and so at this stage of the assessment process, the potential impact of each development site is uncertain. It should be noted that the impact of allocated sites on European sites will be tested through the Habitats Regulations Assessment (HRA) process, the findings of which will be used to inform the Regulation 19 SA (see Chapter 8 of Volume 2). The HRA will provide further detail relating to potential impacts on European sites within and surrounding the Plan area. Data for European sites is available from Natural England^[12].

Notes

The area within which development proposals could potentially have direct, indirect and in-combination impacts on the integrity of a European site is referred to as the Zone of Influence (ZOI). This is determined through an identification of sensitive receptors at each European site (its qualifying features) and pathways via which the Local Plan may have an impact. At this stage, no ZOI have been formally identified for surrounding European sites, and so at this stage of the assessment process, the potential impact of each development site is uncertain. It should be noted that the impact of allocated sites on European sites will be tested through the Habitats Regulations Assessment (HRA) process, the findings of which will be used to inform the Regulation 19 SA (see Chapter 8 of Volume 2). The HRA will provide further detail relating to potential impacts on European sites within and surrounding the Plan area.

Data for European sites is available from Natural England^[12].

Box D.4.2: SA Objective 3: SSSI

Score	Likely Impact – Site of Special Scientific Interest (SSSI)
--	Development coincides with, or is located adjacent to, an SSSI.
-	Within an IRZ which indicates proposed development should be consulted on with Natural England. Likelihood of direct or indirect impacts.
0	Development within an IRZ which does not indicate the proposed development need to consult with Natural England.
+	Development proposals which would enhance features of an SSSI.

Notes
Natural England has developed Impact Risk Zones (IRZs) for each SSSI unit in the country. IRZs are a Geographical Information System (GIS) tool developed by Natural England which allow a rapid initial assessment of the potential risks posed by development proposals to: SSSIs, SACs, SPAs and Ramsar sites. They define zones around each site which reflect the particular sensitivities of the features for which it is notified and indicate the types of development proposal which could potentially have adverse impacts. Where a site falls within more than one SSSI IRZ the worst-case risk zone is reported upon in the assessment. Data for SSSIs and IRZs is available from Natural England^[13].

Notes

Natural England has developed Impact Risk Zones (IRZs) for each SSSI unit in the country. IRZs are a Geographical Information System (GIS) tool developed by Natural England which allow a rapid initial assessment of the potential risks posed by development proposals to: SSSIs, SACs, SPAs and Ramsar sites. They define zones around each site which reflect the particular sensitivities of the features for which it is notified and indicate the types of development proposal which could potentially have adverse impacts.

Where a site falls within more than one SSSI IRZ the worst-case risk zone is reported upon in the assessment.

Data for SSSIs and IRZs is available from Natural England^[13].

Box D.4.3: SA Objective 3: NNR

Score	Likely Impact – National Nature Reserve (NNR)
--	Development coincides with an NNR. Likelihood of direct impacts.
-	Development could potentially result in adverse impacts on an NNR. Likelihood of direct or indirect impacts.
0	Development not anticipated to result in adverse impacts on NNRs.
+	Development proposals which would enhance or create an NNR.

Notes
National Nature Reserves (NNRs) were established to protect some of England's most important habitats, species and geology, and to provide 'outdoor laboratories' for research. Data for NNRs is available from Natural England^[14].

Box D.4.4: SA Objective 3: Ancient woodland

Score	Likely Impact - Ancient woodland
--	Development proposal coincides with a stand of ancient woodland. Likelihood of direct impacts.
-	Development proposal anticipated to result in adverse impacts on a stand of ancient woodland. Likelihood of direct or indirect impacts.
0	Development proposal would not be anticipated to impact ancient woodland.
+	Development proposals which would enhance ancient woodland.

Notes
Ancient woodland is defined as an area that has been wooded continuously since at least 1600AD and includes 'ancient semi-natural woodland' and 'plantations on ancient woodland sites', both of which have equal protection under the NPPF^[15]. Data for ancient woodlands is available from Natural England^[16].

Box D.4.5: SA Objective 3: LNR

Score	Likely Impact – Local Nature Reserve (LNR)
-	Development proposal could potentially result in adverse impacts on an LNR, such as those which coincide or are located in close proximity. Likelihood of direct or indirect impacts.
0	Development proposal not anticipated to result in adverse impacts on an LNR.
+	Development proposals which would enhance or create an LNR.

Notes
Local Nature Reserves (LNRs) are statutory designations, representing places with wildlife or geological features that are of special interest locally, which give people special opportunities to study and learn about them or simply enjoy and have contact with nature. Data for LNRs is available from Natural England^[17].

Box D.4.6: SA Objective 3: SINC

Score	Likely Impact – Sites of Importance for Nature Conservation (SINC)
--	Development proposal coincides with a SINC. Likelihood of direct impacts.
-	Development proposal anticipated to result in adverse impacts on a SINC. Likelihood of direct or indirect impacts.
0	Development not anticipated to result in adverse impacts on a SINC.
+	Development proposals which would enhance or create a SINC.

Notes
Sites of Importance for Nature Conservation (SINCs) are non-statutory designated sites of Birmingham and the Black Country importance^[18]. They are endorsed by the Birmingham and Black Country Local Sites Partnership. Data for SINCs has been provided by SMBC. For the purposes of the SLP, SINCs operate as a hard constraint for site allocation because they are rated more highly for their value to ecology and the environment.

Notes

Sites of Importance for Nature Conservation (SINCs) are non-statutory designated sites of Birmingham and the Black Country importance^[18]. They are endorsed by the Birmingham and Black Country Local Sites Partnership. Data for SINCs has been provided by SMBC.

For the purposes of the SLP, SINCs operate as a hard constraint for site allocation because they are rated more highly for their value to ecology and the environment.

Box D.4.7: SA Objective 3: SLINC

Score	Likely Impact – Sites of Local Importance for Nature Conservation (SLINC)
-	Development proposal anticipated to result in adverse impacts on a SLINC, such as those which coincide or are located in close proximity. Likelihood of direct or indirect impacts.
0	Development not anticipated to result in adverse impacts on a SLINC.
+	Development proposals which would enhance or create a SLINC.

Notes
Sites of Local Importance for Nature Conservation (SLINCs) are non-statutory designated sites of borough importance^[19]. They are endorsed by the Birmingham and Black Country Local Sites Partnership, and then adopted by SMBC. Data for SLINCs has been provided by SMBC. For the purposes of the SLP, whilst SLINCs are protected, under certain circumstances development may take place adjacent to or on them where appropriate mitigation can be realised and where the value of the development is considered to be sufficient to outweigh any damage to the habitat.

Notes

Sites of Local Importance for Nature Conservation (SLINCs) are non-statutory designated sites of borough importance^[19]. They are endorsed by the Birmingham and Black Country Local Sites Partnership, and then adopted by SMBC. Data for SLINCs has been provided by SMBC.

For the purposes of the SLP, whilst SLINCs are protected, under certain circumstances development may take place adjacent to or on them where appropriate mitigation can be realised and where the value of the development is considered to be sufficient to outweigh any damage to the habitat.

Box D.4.8: SA Objective 3: Geological conservation

Score	Likely Impact - Geological conservation
-	Development proposal anticipated to result in adverse impacts on a geological site, due to location or proximity. Likelihood of direct or indirect impacts.
0	Development proposal not anticipated to result in adverse impacts on a Geological Site.
+	Development proposal anticipated to enhance a geological site.

Notes
Data for geological sites provided by SMBC and data for underlying geological context provided by British Geological Survey.

Box D.4.9: SA Objective 3: Priority habitat

Score	Likely Impact - Priority habitat
-	Development proposal coincides with a priority habitat.
0	Development proposal does not coincide with a priority habitat.
+	Development proposals which enhance or create a priority habitat.

Notes
For the purposes of this assessment, impacts on priority habitats have been considered in the context of Natural England's publicly available Priority Habitat Inventory database^[20]. It is acknowledged this may not reflect current local site conditions in all instances.

D.5 SA Objective 4: Climate change mitigation

D.5.1 Introduction and context

D.5.1.1 Box D.5.1 sets out the specific methodology used to appraise the reasonable alternative sites against SA Objective 4: Climate change mitigation.

D.5.1.2 The incorporation of GI within developments presents several opportunities to mitigate climate change, for example, through providing natural cooling to combat the 'urban heat island' effect, reducing the effects of air pollution and providing more pleasant outdoor environments to encourage active travel[21].

D.5.1.3 However, it is likely that new development would result in an increase in local greenhouse gas (GHG) emissions due to the increase in the local population and the number of operating businesses. The increase in GHG emissions caused by new developments is often associated with impacts of the construction phase, the occupation and operation of homes and businesses, fuel consumption and increases in local road transport with associated emissions. This impact is considered to be permanent and non-reversible.

D.5.1.4 It should be noted that the appraisal of the reasonable alternatives is limited in its assessment of carbon emissions. The 1% principle as set out in Box D.5.1 is only a coarse precautionary indicator, and greater detail of carbon data would help to better quantify effects.

D.5.2 Climate change mitigation receptors

Box D.5.1: SA Objective 4: Carbon emissions

Score	Likely Impact - Carbon emissions
--	Residential-led development which could potentially result in an increase in CO₂ emissions by 1% or more in comparison to current levels.
-	Residential-led development which could potentially result in an increase in CO₂ emissions by 0.1% or more in comparison to current levels.
0	Development would be expected to result in a negligible increase in CO₂ emissions.
+/-	Non-residential or Gypsy and Traveller development where the carbon emissions produced as a result of the proposed development is uncertain, or development sites where the proposed use is uncertain.
+	Development proposals which include energy saving or renewable energy technologies. Development proposals which would reduce reliance on private car use, encourage active travel or the use of public transport.

Notes
The estimated CO2 emissions for Sandwell in 2022 was 1,247.3 kilo tonnes, with per capita emissions of 3.6 tonnes, according to UK local authority CO2 emissions data^[22]. Sandwell has an average of 2.7 people per dwelling^[23]. Based on these figures, and assuming new residents will generate CO2 emissions in line with the current average, it has been calculated that proposals for 1,283 homes or more are expected to increase carbon emissions by 1% or more in comparison to the current estimates for Sandwell. Proposals for 128 homes or more are expected to increase carbon emissions by 0.1% or more in comparison to current estimates for Sandwell.

Notes

The estimated CO2 emissions for Sandwell in 2022 was 1,247.3 kilo tonnes, with per capita emissions of 3.6 tonnes, according to UK local authority CO2 emissions data^[22]. Sandwell has an average of 2.7 people per dwelling^[23].

Based on these figures, and assuming new residents will generate CO2 emissions in line with the current average, it has been calculated that proposals for 1,283 homes or more are expected to increase carbon emissions by 1% or more in comparison to the current estimates for Sandwell. Proposals for 128 homes or more are expected to increase carbon emissions by 0.1% or more in comparison to current estimates for Sandwell.

D.6 SA Objective 5: Climate change adaptation

D.6.1 Introduction and context

D.6.1.1 Boxes D.6.1 to D.6.3 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 5: Climate change adaptation.

D.6.1.2 It is assumed that development proposals will be in perpetuity, and it is therefore likely that development will be subject to the impacts of flooding at some point in the future, should it be situated on land at risk of fluvial or surface water flooding.

D.6.2 Climate change adaptation receptors

Box D.6.1: SA Objective 5: Fluvial flooding

Score	Likely Impact - Fluvial flooding
--	Development proposals which coincide with Flood Zones 3.
-	Development proposals which coincide with Flood Zone 2.
+	Development proposals which are located wholly within Flood Zone 1.

Notes
Data for fluvial flooding has been derived from the latest available Environment Agency Flood Map for Planning (Rivers and Sea)^[24], such that: Flood Zone 3: Greater or equal to 1% chance of river flooding in any given year or greater than 0.5% chance of sea flooding in any given year; Flood Zone 2: Between 1% and 0.1% chance of river flooding in any given year or 0.5% and 0.1% chance of sea flooding in any given year; and Flood Zone 1: Less than 0.1% chance of river and sea flooding in any given year.

Notes

Data for fluvial flooding has been derived from the latest available Environment Agency Flood Map for Planning (Rivers and Sea)^[24], such that:

Flood Zone 3: Greater or equal to 1% chance of river flooding in any given year or greater than 0.5% chance of sea flooding in any given year;
Flood Zone 2: Between 1% and 0.1% chance of river flooding in any given year or 0.5% and 0.1% chance of sea flooding in any given year; and
Flood Zone 1: Less than 0.1% chance of river and sea flooding in any given year.

Box D.6.2: SA Objective 5: Surface water flooding

Score	Likely Impact - Surface water flooding
--	Development proposals which coincide with areas at high risk of surface water flooding.
-	Development proposals which coincide with areas at low and/or medium risk of surface water flooding.
0	Development proposals which are not located in areas determined to be at risk of surface water flooding.
+	Development proposals which include the integration of GI, open space, SUDS or other surface water flood risk alleviating measures

Notes
The assessment is based on the Environment Agency surface water flood risk data^[25], such that^[26]: High risk: more than 3.3% chance of flooding each year; Medium risk: between 1% - 3.3% chance of flooding each year; and Low risk: between 0.1% - 1% chance of flooding each year. Areas determined to be at very low risk of flooding (less than 0.1% chance) would be expected to result in a negligible impact on surface water flooding for the purposes of this assessment.

Notes

The assessment is based on the Environment Agency surface water flood risk data^[25], such that^[26]:

High risk: more than 3.3% chance of flooding each year;
Medium risk: between 1% - 3.3% chance of flooding each year; and
Low risk: between 0.1% - 1% chance of flooding each year.

Areas determined to be at very low risk of flooding (less than 0.1% chance) would be expected to result in a negligible impact on surface water flooding for the purposes of this assessment.

Box D.6.3: SA Objective 5: Indicative flood zone

Score	Likely Impact - Indicative flood zone
--	Development proposals which coincide with Indicative Flood Zone 3b.
0	Development proposals which do not coincide with Indicative Flood Zone 3b.

Notes
Indicative Flood Zone 3b is present in areas where flooding will potentially worsen in future due to climate change. Data for Indicative Flood Zones has been provided by SMBC, which relates to the data produced by JBA Consulting as part of the Black Country Level 1 Strategic Flood Risk Assessment (SFRA)^[27].

D.7 SA Objective 6: Natural resources

D.7.1 Introduction and context

D.7.1.1 Boxes D.7.1 to D.7.2 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 6: Natural resources.

D.7.1.2 In accordance with the core planning principles of the NPPF, development on previously developed land is recognised as an efficient use of land. Development of previously undeveloped land and greenfield sites is not considered to be an efficient use of land.

D.7.1.3 The natural resources objective also considers potential effects on mineral resources. Minerals are a finite, non-renewable resource and as such, their conservation and safeguarding for future generations is important. There are no Mineral Safeguarding Areas or Areas of Search identified within Sandwell in the Black Country Minerals Study[28]; as such all proposed development sites would be expected to have a negligible impact on mineral resources based on the current evidence available.

D.7.2 Natural resources receptors

Box D.7.1: SA Objective 6: Previously developed land / land with environmental value

Score	Likely Impact - Previously developed (brownfield) land / land with environmental value
-	Development proposals located on previously undeveloped land, or brownfield land with potential environmental value.
+	Development proposals located on previously developed or brownfield land with no environmental value.

Notes
Assessment of sites comprising previously developed land is in accordance with the definitions in the NPPF^[29]. Assessment of current land use and potential environmental value has been made through reference to aerial photography and the use of Google Maps. It should be noted that this may not reflect the current status of the site, and the nature of development within the site boundary is unknown, so a degree of uncertainty remains.

Notes

Assessment of sites comprising previously developed land is in accordance with the definitions in the NPPF^[29].

Assessment of current land use and potential environmental value has been made through reference to aerial photography and the use of Google Maps. It should be noted that this may not reflect the current status of the site, and the nature of development within the site boundary is unknown, so a degree of uncertainty remains.

Box D.7.2: SA Objective 6: BMV land

Score	Likely Impact – Best and most versatile (BMV) land
--	Development proposals which are situated on Grade 1, 2 or 3 ALC land comprising 20ha or more.
-	Development proposals which are situated on Grade 1, 2 or 3 ALC land comprising less than 20ha.
0	Development proposals located on previously developed land with no environmental value.
+	Development proposals which are situated on Grade 4 and 5 ALC land, or land classified as 'urban' or 'non-agricultural'.

Notes
The Agricultural Land Classification (ALC) system classifies land into five categories according to versatility and suitability for growing crops. The top three grades, Grades 1, 2 and 3a, are referred to as the Best and Most Versatile (BMV) land^[30]. In the absence of site-specific surveys to identify Grades 3a and 3b, and in line with the precautionary principle, ALC Grade 3 is considered as BMV land. ALC data is available from Natural England^[31]. A 20ha threshold has been used based on Natural England guidance^[32].

Notes

The Agricultural Land Classification (ALC) system classifies land into five categories according to versatility and suitability for growing crops. The top three grades, Grades 1, 2 and 3a, are referred to as the Best and Most Versatile (BMV) land^[30]. In the absence of site-specific surveys to identify Grades 3a and 3b, and in line with the precautionary principle, ALC Grade 3 is considered as BMV land. ALC data is available from Natural England^[31].

A 20ha threshold has been used based on Natural England guidance^[32].

D.8 SA Objective 7: Pollution

D.8.1 Introduction and context

D.8.1.1 Boxes D.8.1 to D.8.5 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 7: Pollution.

D.8.1.2 The assessment under this objective considers the potential for reasonable alternative sites to generate pollution associated with the construction and occupation of new development, as well as the potential to expose site end users to existing sources of pollution.

D.8.2 Pollution receptors

Box D.8.1: SA Objective 7: AQMA

Score	Likely Impact - AQMA
-	All development proposals in the Black Country are located within an AQMA.

Notes
Air Quality Management Areas (AQMAs) are considered to be an area where the national air quality objective will not be met. Introducing new development within an AQMA would therefore be expected to expose new residents to poor air quality. UK AQMA data is available from Defra^[33].

Box D.8.2: SA Objective 7: Main road

Score	Likely Impact - Main road
-	Development proposals located within 200m of a main road.
0	Development proposals located over 200m from a main road.
+	Development proposals which would help to reduce the number of cars used, promote the use of public transport and active travel and reduce congestion on nearby roads.

Notes

It is assumed that sites located in close proximity to main roads would expose site end users to transport associated noise and air pollution. Negative impacts on the long-term health of site end users would be anticipated where residents would be exposed to air pollution.

In line with the DMRB guidance, it is assumed that receptors would be most vulnerable to these impacts located within 200m of a main road^[34]. The Department for Transport (DfT) in their Transport Analysis Guidance (TAG) consider that, "beyond 200m from the link centre, the contribution of vehicle emissions to local pollution levels is not significant"^[35]. A 200m buffer distance from main roads (motorways and A-roads) has therefore been applied in this assessment. Road data is available from Ordnance Survey^[36].

Box D.8.3: SA Objective 7: Water quality

Score	Likely Impact - Water quality
-	Development proposals located within 10m of a watercourse.
+/-	Development proposals located over 10m from a watercourse.
+	Development proposal includes integration of GI or the naturalisation of watercourses.

Notes

Construction activities in or near watercourses have the potential to cause pollution, impact upon the bed and banks of watercourses and impact on the quality of the water. A 10m buffer zone from a watercourse in which no works, clearance, storage or run-off should be permitted has been used as per available guidance^[37]^[38]. However, it should be noted that development further away than this has the potential to lead to adverse impacts such as those resulting from runoff and should be considered on a site-by-site basis; as such, sites over 10m from a watercourse are scored as 'uncertain' in this assessment.

Watercourse mapping data is available from the Ordnance Survey^[39].

Box D.8.4: SA Objective 7: Groundwater SPZ

Score	Likely Impact - Groundwater SPZ
-	Development proposal coincides with a groundwater SPZ.
0	Development proposal does not coincide with a groundwater SPZ.

Notes

The vulnerability of groundwater to pollution is determined by the physical, chemical and biological properties of the soil and rocks, which control the ease with which an unprotected hazard can affect groundwater. Groundwater Source Protection Zones (SPZs) indicate the risk to groundwater supplies from potentially polluting activities and accidental releases of pollutants. As such, any site that is located within a groundwater SPZ could potentially have an adverse impact on groundwater quality. Groundwater source catchments are divided into three zones:

Inner Zone (Zone I) – 50-day travel time from any point below the water table to the source;
Outer Zone (Zone II) – 400-day travel time; and
Total Catchment (Zone III) – within which all groundwater recharge is presumed to be discharged at the source.

SPZ data is available from the Environment Agency^[40].

Box D.8.5: SA Objective 7: Increase in air pollution

Score	Likely Impact - Increase in air pollution
--	Development proposals which could potentially result in a significant increase in air pollution.
-	Development proposals which could potentially result in a minor increase in air pollution.
0	Development would be expected to result in a negligible increase in air pollution.
+/-	The air pollution likely to be generated as a result of development proposals is uncertain. Including development sites for Gypsy and Traveller use, or development sites where the proposed use is uncertain.

Notes

It is assumed that development would result in an increase in traffic and thus traffic generated air pollution. Residential sites proposed for the development of between ten and 99 dwellings would therefore be expected to have a minor negative impact on local air pollution^[41]. Residential sites proposed for the development of 100 dwellings or more would be expected to have a major negative impact. Employment sites which propose the development of between 1ha and 9.9ha of employment space would be expected to have a minor negative impact and sites which propose 10ha or more would be expected to have a major negative impact.

Where a site is proposed for the development of nine dwellings or less, or for 0.99ha of employment floorspace or less, a negligible impact on local air quality would be anticipated.

D.9 SA Objective 8: Waste

D.9.1 Introduction and context

D.9.1.1 Box D.9.1 sets out the specific methodology used to appraise the reasonable alternative sites against SA Objective 8: Waste.

D.9.1.2 It is expected that new development would result in an increase in the local population, and consequently an increase in household waste generation.

D.9.1.3 It should be noted that the appraisal of the reasonable alternatives is limited in its assessment against waste. The 1% principle as set out in Box D.9.1 is only a coarse precautionary indicator, and greater detail of waste data would help to better quantify effects. The amount and type of waste produced will vary depending upon the specific site circumstances and end use and may have differing implications for the management of waste; such detail is not available to inform the assessment of reasonable alternative sites.

D.9.2 Waste receptors

Box D.9.1: SA Objective 8: Waste

Score	Likely Impact - Waste
--	Residential-led development which could potentially result in an increase in household waste generation by 1% or more in comparison to current levels.
-	Residential-led development which could potentially result in an increase in household waste generation by 0.1% or more in comparison to current levels.
0	Development would be expected to result in a negligible increase in household waste generation.
+/-	The waste generated as a result of development proposals for non-residential or Gypsy and Traveller use is uncertain, or development sites where the proposed use is uncertain.
+	Development proposals which include provision of waste and recycling storage.
++	Development proposals for waste or recycling facilities.

Notes

Residential-led development is likely to result in an increase in household waste generation, to some extent. According to the UK local authority household waste data^[42] , approximately 132,228 tonnes of waste was produced within Sandwell in 2022/2023. It is assumed that new residents in Sandwell will have an annual waste production of 377kg per person, in line with the England average^[43]. Sandwell has an average of 2.7 people per dwelling^[44].

Based on these figures, and assuming new residents will generate waste in line with the current average, it has been calculated that proposals for 1,299 homes or more are expected to increase household waste generation by 1% or more in comparison to the current estimates for Sandwell. Proposals for 130 homes or more are expected to increase household waste generation by 0.1% or more in comparison to current estimates for Sandwell.

D.10 SA Objective 9: Transport and accessibility

D.10.1 Introduction and context

D.10.1.1 Boxes D.10.1 to D.10.6 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 9: Transport and accessibility.

D.10.1.2 The Local Plan should seek to ensure that residents in Sandwell have access to a range of sustainable transport modes, to help facilitate a modal shift away from private car use to help tackle air quality and congestion issues and provide for more efficient travel. The Plan should also promote a reduced need to travel overall, facilitating local journeys via active travel wherever possible.

D.10.1.3 Accessibility modelling data[45] indicates the level of sustainable accessibility to local services (fresh food and centres) across Sandwell and the wider Black Country.

D.10.2 Transport and accessibility receptors

Box D.10.1: SA Objective 9: Bus stop

Score	Likely Impact – Bus stop
-	Development proposals where the majority of the site is located over 400m from a bus stop.
+	Development proposals where the majority of the site is located within 400m of a bus stop.

Notes

It is desirable for site end users to be situated within walking distance of a bus stop.

Bus stop data available from Transport for West Midlands^[46]. A target distance of 400m to a bus stop has been used in line with Barton et al. sustainable distances^[47].

Box D.10.2: SA Objective 9: Railway or metro station

Score	Likely Impact – Railway or metro station
-	Development proposals where the majority of the site is located over 2km from a railway or metro station.
+	Development proposals where the majority of the site is located within 2km of a railway or metro station.

Notes

Railway and metro station data available from Transport for West Midlands^[48]. The assessments have used the latest version of this dataset (2022). It is acknowledged that there are new metro stations under construction along the Wednesbury – Brierley Hill route which are not captured within this data. No subsequent updates to the data have been available to inform the Regulation 19 SA assessments.

A target distance of 2km to a railway station has been used in line with Barton et al. sustainable distances^[49].

Box D.10.3: SA Objective 9: Pedestrian access

Score	Likely Impact – Pedestrian access
-	Development proposals located in areas which currently have poor access to the surrounding footpath network.
+	Development proposals which are well connected to the existing footpath network and would be expected to provide safe access for pedestrians.

Notes

New development sites have been assessed in terms of their access to the surrounding footpath network, allowing for safe local travel on foot. Safe access is determined to be that which is suitable for wheelchair users and pushchairs.

Assessment of proximity to existing footpaths has been made through reference to aerial photography and the use of Google Maps^[50].

Box D.10.4: SA Objective 9: Road access

Score	Likely Impact – Road access
-	Development proposals located in areas which currently have poor access to the surrounding road network.
+	Development proposals which are adjacent to an existing road.

Notes
Assessment of proximity to existing roads has been made through reference to aerial photography and the use of Google Maps^[51].

Box D.10.5: SA Objective 9: Pedestrian access to local services

Score	Likely Impact – Pedestrian access to local services
-	Development proposals where the majority of the site is located over a 15-minute walk to local services.
+	Development proposals where the majority of the site is located over a 10-minute walk but within a 15-minute walk to local services.
++	Development proposals where the majority of the site is located within a 10-minute walk to local services.

Notes
Data on fresh food centre locations and accessibility modelling (travel time to fresh food and centres) has been provided by SMBC.

Box D.10.6: SA Objective 9: Public transport access to local services

Score	Likely Impact - Public transport access to local services
-	Development proposals where the majority of the site is located over a 15-minute travel time via public transport to local services.
+	Development proposals where the majority of the site is located over a 10-minute travel time but within a 15-minute travel time via public transport to local services.
++	Development proposals where the majority of the site is located within a 10-minute travel time via public transport to local services.

Notes
Data on fresh food centre locations and accessibility modelling (travel time to fresh food centres) has been provided by SMBC.

D.11 SA Objective 10: Housing

D.11.1 Introduction and context

D.11.1.1 Box D.11.1 sets out the specific methodology used to appraise the reasonable alternative sites against SA Objective 10: Housing.

D.11.1.2 When striving for sustainable development, housing density should be considered carefully. High population densities can limit the accessibility of local key services and facilities such as hospitals, supermarkets and open spaces, including playgrounds and sports fields. High population densities also influence perceptions of safety, social interactions and community stability[52].

D.11.2 Housing receptors

Box D.11.1: SA Objective 10: Provision of housing

Score	Likely Impact - Provision of housing
--	Development proposals which result in a significant net decrease in housing (of 100 dwellings or more).
-	Development proposals which result in a minor net decrease in housing (of between one and 99 dwellings).
0	Development proposals which would not impact housing provision.
+/-	It is uncertain whether the proposed development would result in a net change in housing provision. Residential-led development sites for which the net housing capacity was unknown at the time of writing, or development sites where the proposed use is uncertain but may include residential.
+	Development proposals resulting in a minor net gain in housing (of between one and 99 dwellings).
++	Development proposals resulting in a significant net gain in housing (of 100 dwellings or more).

Notes

Estimated housing capacity for each reasonable alternative site has been provided by SMBC.

At this stage of the assessment process, information is not available relating to the specific housing mix / type that would be delivered through each reasonable alternative site, including potential for development of affordable homes. It is assumed that development options will provide a good mix of housing type and tenure opportunities.

D.12 SA Objective 11: Equality

D.12.1 Introduction and context

D.12.1.1 Box D.12.1 sets out the specific methodology used to appraise the reasonable alternative sites against SA Objective 11: Equality.

D.12.1.2 The Index of Multiple Deprivation (IMD) measures the relative levels of deprivation in 32,844 Lower Super Output Areas (LSOAs) in England. LSOAs are small areas designed to be of similar population, of approximately 1,500 residents or 650 households. According to the IMD (2019)[53], Sandwell ranks as 12th out of 317 local authorities in England (with 1 being most deprived and 317 being least deprived). 1 in 5 of the LSOAs in Sandwell are ranked among the 10% most deprived in England[54].

D.12.2 Equality receptors

Box D.12.1: SA Objective 11: Index of Multiple Deprivation

Score	Likely Impact - Index of Multiple Deprivation
-	Development proposals within most deprived 10 percent LSOAs in England. Development proposals would result in the loss of affordable housing, community services or could potentially increase crime/the fear of crime in the area.
0	Development proposals outside most deprived 10 percent LSOAs in England. Development proposals would be expected to have no significant impact on equality.
+	Development proposals would result in the provision of affordable housing, community services or would reduce crime/the fear of crime in the area.

Notes

UK Indices of Multiple Deprivation (IMD) available from MHCLG^[55].

It should be noted that there is a degree of uncertainty in regard to the impacts of each site on deprivation and equality, which will be dependent on site-specific circumstances that are unknown at the time of writing.

An EqIA is being prepared by the Council alongside the emerging SLP.

D.13 SA Objective 12: Health

D.13.1 Introduction and context

D.13.1.1 Boxes D.13.1 to D.13.5 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 12: Health.

D.13.1.2 In order to facilitate healthy and active lifestyles for existing and new residents, it is expected that the Local Plan should seek to ensure that residents have access to NHS hospitals, GP surgeries, leisure facilities and a diverse range of accessible natural habitats and the surrounding PRoW network.

D.13.1.3 Accessibility modelling data[56] indicates the level of sustainable accessibility to healthcare (GP surgeries) across Sandwell and the wider Black Country.

D.13.1.4 It should be noted that healthcare capacity information has not been available; the assessment is based on accessibility alone.

D.13.2 Health receptors

Box D.13.1: SA Objective 12: NHS hospital

Score	Likely Impact - NHS hospital
-	Development proposals where the majority of the site is located over 5km from an NHS hospital providing an A&E service.
+	Development proposals where the majority of the site is located over 5km from an NHS hospital providing an A&E service.

Notes

For the purposes of this assessment, accessibility to a hospital has been taken as proximity to an NHS hospital with an A&E service. Distances of sites to other NHS facilities (e.g. community hospitals and treatment centres) or private hospitals has not been taken into consideration in this assessment. NHS hospital department data available from the NHS website^[57], and local hospital data provided by SMBC.

The target distance of 5km to an NHS hospital with an A&E service has been used in line with Barton et al. sustainable distances^[58].

It should be noted that the current 'Birmingham City Hospital' will be replaced with the new 'Midland Metropolitan Hospital' in 2024^[59]. Given the timescales for these changes, for the purpose of the SA accessibility to the new 'Midland Metropolitan Hospital' has been considered within the site assessments, and the 'Birmingham City Hospital' has not been included within site assessments.

Box D.13.2: SA Objective 12: Pedestrian access to GP surgery

Score	Likely Impact - Pedestrian access to GP surgery
-	Development proposals where the majority of the site is located over a 15-minute walk to a healthcare location.
+	Development proposals where the majority of the site is located over a 10-minute walk but within a 15-minute walk to a healthcare location.
++	Development proposals where the majority of the site is located within a 10-minute walk to a healthcare location.

Notes
Data for healthcare locations and accessibility modelling (travel time to healthcare) has been provided by SMBC. The modelling data does not incorporate new / emerging healthcare locations such as the Wednesbury Health Centre^[60]; no subsequent updates to the data have been available to inform the Regulation 19 SA assessments.

Box D.13.3: SA Objective 12: Public transport access to GP surgery

Score	Likely Impact - Public transport access to GP surgery
-	Development proposals where the majority of the site is located over a 15-minute travel time via public transport to a healthcare location.
+	Development proposals where the majority of the site is located over a 10-minute travel time but within a 15-minute travel time via public transport to a healthcare location.
++	Development proposals where the majority of the site is located within a 10-minute travel time via public transport to a healthcare location.

Notes
Data for healthcare locations and accessibility modelling (travel time to healthcare) has been provided by SMBC.

Box D.13.4: SA Objective 12: Access to / net loss of greenspace

Score	Likely Impact - Access to / net loss of greenspace
-	Development proposals which coincide with greenspace. Development proposals where the majority of the site is located over 600m from greenspace.
0	Development proposals do not coincide with greenspace.
+	Development proposals where the majority of the site is located within 600m of a greenspace.

Notes

Access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and wellbeing of communities. The assessment of proximity to/net loss of greenspaces is based on Ordnance Survey Open Greenspaces^[61]. It is assumed that these greenspaces are publicly accessible.

The target distance of 600m to a public greenspace has been used in line with Barton et al. sustainable distances^[62].

Box D.13.5: SA Objective 12: Access to PRoW / cycle routes

Score	Likely Impact - Access to PRoW / cycle routes
-	Development proposals where the majority of the site is located over 600m from a PRoW and cycle route.
+	Development proposals where the majority of the site is located within 600m from a PRoW and/or cycle route.

Notes
New development sites have been assessed in terms of their access to the local PRoW and cycle networks. PRoW data provided by SMBC, and strategic cycle route data is available from Transport for West Midlands^[63]. The target distance of 600m to a footpath or cycle path has been used in line with Barton et al. sustainable distances.

D.14 SA Objective 13: Economy

D.14.1 Introduction and context

D.14.1.1 Boxes D.14.1 to D.14.3 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 13: Economy.

D.14.1.2 Accessibility modelling data[64] indicates the level of sustainable accessibility to employment locations across Sandwell and the wider Black Country. It is assumed that the mapped employment locations would provide a range of job opportunities for residents.

D.14.2 Economy receptors

Box D.14.1: SA Objective 13: Pedestrian access to employment opportunities

Score	Likely Impact - Pedestrian access to employment opportunities
-	Residential development proposals where the majority of the site is located over a 30-minute walk to a key employment location.
0	Development proposals for non-residential use.
+	Residential development proposals where the majority of the site is located over a 20-minute walk but within a 30-minute walk to a key employment location.
++	Residential development proposals where the majority of the site is located within a 20-minute walk to a key employment location.

Notes
Data for key employment locations and accessibility modelling (travel time to employment) has been provided by SMBC.

Box D.14.2: SA Objective 13: Public transport access to employment opportunities

Score	Likely Impact - Public transport access to employment opportunities
-	Residential development proposals where the majority of the site is located over a 30-minute travel time via public transport to a key employment location.
0	Development proposals for non-residential use.
+	Residential development proposals where the majority of the site is located over a 20-minute travel time but within a 30-minute travel time via public transport to a key employment location.
++	Residential development proposals where the majority of the site is located within a 20-minute travel time via public transport to a key employment location.

Notes
Data for key employment locations and accessibility modelling (travel time to employment) has been provided by SMBC.

Box D.14.3: SA Objective 13: Employment floorspace

Score	Likely Impact - Employment floorspace
--	Development proposals which result in a significant net decrease in employment floorspace.
-	Development proposals which result in a minor net decrease in employment floorspace.
0	Development proposals which would not impact employment floorspace.
+/-	It is uncertain whether the proposed development would result in a net change in employment floorspace. This includes development sites where the proposed use is uncertain but may include employment.
+	Development proposals which result in a minor net increase in employment floorspace.
++	Development proposals which result in a significant net increase in employment floorspace.

Notes
An assessment of current land use has been made through reference to aerial photography and the use of Google Maps^[65].

D.15 SA Objective 14: Education, skills and training

D.15.1 Introduction and context

D.15.1.1 Boxes D.15.1 to D.15.3 set out the specific methodology used to appraise the reasonable alternative sites against SA Objective 14: Education, skills and training.

D.15.1.2 It is assumed that new residents in the Plan area require access to primary and secondary education services to help facilitate good levels of education, skills and qualifications of residents. Accessibility modelling data[66] indicates the level of sustainable accessibility to schools across Sandwell and the wider Black Country.

D.15.1.3 It should be noted that school capacity information has not been available; the assessment is based on accessibility alone.

D.15.2 Education receptors

Box D.15.1: SA Objective 14: Pedestrian access to primary school

Score	Likely Impact - Pedestrian access to primary school
-	Residential development proposals where the majority of the site is located over a 15-minute walk to a primary school.
0	Development proposals for non-residential use.
+	Residential development proposals where the majority of the site is located over a 10-minute walk but within a 15-minute walk to a primary school.
++	Residential development proposals where the majority of the site is located within a 10-minute walk to a primary school.

Notes
Data for primary school locations and accessibility modelling (travel time to primary schools) has been provided by SMBC.

Box D.15.2: SA Objective 14: Pedestrian access to secondary school

Score	Likely Impact - Pedestrian access to secondary school
-	Residential development proposals where the majority of the site is located over a 25-minute walk to a secondary school.
0	Development proposals for non-residential use.
+	Residential development proposals where the majority of the site is located over a 20-minute walk but within a 25-minute walk to a secondary school.
++	Residential development proposals where the majority of the site is located within a 20-minute walk to a secondary school.

Notes
Data for secondary school locations and accessibility modelling (travel time to secondary schools) has been provided by SMBC.

Box D.15.3: SA objective 14: Public transport access to secondary school

Score	Likely Impact - Public transport access to secondary school
-	Residential development proposals where the majority of the site is located over a 25-minute travel time via public transport to a secondary school.
0	Development proposals for non-residential use.
+	Residential development proposals where the majority of the site is located over a 20-minute travel time but within a 25-minute travel time via public transport to a secondary school.
++	Residential development proposals where the majority of the site is located within a 20-minute travel time via public transport to a secondary school.

Notes
Data for secondary school locations and accessibility modelling (travel time to secondary schools) has been provided by SMBC.

^[1] Setting is taken to mean the surroundings in which a heritage asset may be experienced, which does not relate solely to distance from proposed developments to heritage assets. Historic England (2017) The Setting of Heritage Assets. Historic Environment Good Practice Advice in Planning: 3 (2^nd Edition). Available at: https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/ [Date accessed: 07/08/24]

^[2] Historic England (2023) Search the Heritage at Risk Register. Available at: https://historicengland.org.uk/advice/heritage-at-risk/search-register/ [Date accessed: 07/08/24]

^[3] Historic England (2024) Download Listing Data. Available at: https://historicengland.org.uk/listing/the-list/data-downloads/ [Date accessed: 07/08/24]

^[4] Ibid

^[5] Ibid

^[6] Ibid

^[7] Ibid

^[8] Sandwell Metropolitan Borough Council (2024) Listed Buildings and conservation areas. Available at: https://www.sandwell.gov.uk/planning/historic-environment/3 [Date accessed: 07/08/24]

^[9]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]

^[10]Ibid

^[11] LUC (2019) Black Country Landscape Sensitivity Assessment. Available at: https://blackcountryplan.dudley.gov.uk/media/13883/black-country-lsa-front-end-report-final-lr_redacted.pdf [Date accessed: 12/08/24]

^[12] Natural England (2024) Special Areas of Conservation (England). Available at: https://naturalengland-defra.opendata.arcgis.com/datasets/e4142658906c498fa37f0a20d3fdfcff_0 [Date accessed: 20/06/23]

^[13] Natural England (2024) Natural England's Impact Risk Zones for Sites of Special Scientific Interest. Available at: https://data.gov.uk/dataset/5ae2af0c-1363-4d40-9d1a-e5a1381449f8/sssi-impact-risk-zones [Date accessed: 12/08/24]

^[14] Natural England (2024) National Nature Reserves (England). Available at: https://data.gov.uk/dataset/726484b0-d14e-44a3-9621-29e79fc47bfc/national-nature-reserves-england [Date accessed: 07/08/24]

^[15]Forestry Commission and Natural England (2022) Ancient woodland, ancient trees and veteran trees: protecting them from development. Available at: https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences [Date accessed: 07/08/24]

^[16] Natural England (2024) Ancient Woodland (England). Available at: https://data.gov.uk/dataset/9461f463-c363-4309-ae77-fdcd7e9df7d3/ancient-woodland-england [Date accessed: 07/08/24]

^[17] Natural England (2024) Local Nature Reserves (England). Available at: https://data.gov.uk/dataset/acdf4a9e-a115-41fb-bbe9-603c819aa7f7/local-nature-reserves-england [Date accessed: 07/08/24]

^[18] EcoRecord (2023) Local Wildlife Sites. Available at: https://www.ecorecord.org.uk/local-sites [Date accessed: 07/08/24]

^[19] Ibid

^[20] Natural England (2024) Priority Habitat Inventory (England). Available at: https://data.gov.uk/dataset/4b6ddab7-6c0f-4407-946e-d6499f19fcde/priority-habitat-inventory-england [Date accessed: 07/08/24]

^[21] TCPA (2023) What is Green Infrastructure? Available at: https://www.tcpa.org.uk/what-is-green-infrastructure/ [Date accessed: 07/08/24]

^[22] Department for Energy Security and Net Zero (2024) UK local authority and regional greenhouse gas emissions statistics, 2005 to 2022. Available at: https://www.gov.uk/government/statistics/uk-local-authority-and-regional-greenhouse-gas-emissions-statistics-2005-to-2022 [Date accessed: 07/08/24]

^[23] People per dwelling has been calculated using the ONS mid-2021 population estimates (Available at: https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationestimates/datasets/populationestimatesforukenglandandwalesscotlandandnorthernireland) and dwelling stock (Available at: https://www.gov.uk/government/statistical-data-sets/live-tables-on-dwelling-stock-including-vacants) [Date accessed: 07/08/24]

^[24] Environment Agency (2023) Flood Map for Planning (Rivers and Sea) – Flood Zone 2 and Flood Zone 3. Available at: https://www.data.gov.uk/dataset/cf494c44-05cd-4060-a029-35937970c9c6/flood-map-for-planning-rivers-and-sea-flood-zone-2 and https://www.data.gov.uk/dataset/bed63fc1-dd26-4685-b143-2941088923b3/flood-map-for-planning-rivers-and-sea-flood-zone-3 [Date accessed: 07/08/24]

^[25] Environment Agency (2024) Risk of Flooding from Surface Water Extent: 3.3 percent annual chance, 1 percent annual chance, 0.1 percent annual chance. Available at: https://www.data.gov.uk/dataset/95ea1c96-f3dd-4f92-b41f-ef21603a2802/risk-of-flooding-from-surface-water-extent-3-3-percent-annual-chance [Date accessed: 07/08/24]

^[26] Environment Agency (2013) Risk of flooding from surface water. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/297429/LIT_8986_eff63d.pdf [Date accessed: 07/08/24]

^[27] JBA Consulting (2020) The Black Country Authorities Level 1 Strategic Flood Risk Assessment Final Report 25^th June 2020. Available at: https://blackcountryplan.dudley.gov.uk/t2/p4/t2p4h/ [Date accessed: 07/08/24]

^[28] wood (2020) Review of the Evidence Base for Minerals to support preparation of the Black Country Plan. Available at: https://blackcountryplan.dudley.gov.uk/t2/p4/t2p4f/ [Date accessed: 07/08/24]

^[29] Department for Levelling Up, Housing and Communities (2023) National Planning Policy Framework. Available at: https://www.gov.uk/government/publications/national-planning-policy-framework--2 [Date accessed: 07/08/24]

^[30] MAFF. October 1988. Available at Natural England. http://publications.naturalengland.org.uk/publication/6257050620264448?category=5954148537204736 [Date accessed: 07/08/24]

^[31] Natural England (2019) Agricultural Land Classification (ALC) (England). Available at: https://naturalengland-defra.opendata.arcgis.com/datasets/5d2477d8d04b41d4bbc9a8742f858f4d_0?geometry=-3.131%2C52.513%2C-0.667%2C53.094 [Date accessed: 07/08/24]

^[32] Natural England (2009) Agricultural Land Classification: protecting the best and most versatile agricultural land. Available at: http://publications.naturalengland.org.uk/publication/35012 [Date accessed: 07/08/24]

^[33] Department for Environment Food and Rural Affairs (2024) UK Air Information Resource. Available at: https://uk-air.defra.gov.uk/aqma/maps/ [Date accessed: 07/08/24]

^[34]Design Manual for Roads and Bridges (2024) LA 105 Air Quality. Available at: https://www.standardsforhighways.co.uk/search/af7f4cda-08f7-4f16-a89f-e30da703f3f4 [Date accessed: 12/08/24]

^[35] Department for Transport (2023) TAG unit A3 Environmental Impact Appraisal. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/825064/tag-unit-a3-environmental-impact-appraisal.pdf [Date accessed: 07/08/24]

^[36] Ordnance Survey (2023) OS Open Roads. Available at: https://www.ordnancesurvey.co.uk/business-government/products/open-map-roads [Date accessed: 07/08/24]

^[37] DAERA (2019) Advice and Information for planning approval on land which is of nature conservation value. Available at: https://www.daera-ni.gov.uk/articles/advice-and-information-planning-approval-land-which-nature-conservation-value [Date accessed: 07/08/24]

^[38] Wild Trout Trust. Buffer Zones. Available at: https://www.wildtrout.org/content/buffer-zones [Date accessed: 07/08/24]

^[39] Ordnance Survey (2023) OS Open Rivers. Available at: https://www.ordnancesurvey.co.uk/business-government/products/open-map-rivers [Date accessed: 07/08/24]

^[40] Environment Agency (2023) Source Protection Zones. Available at: https://data.gov.uk/dataset/09889a48-0439-4bbe-8f2a-87bba26fbbf5/source-protection-zones-merged [Date accessed: 07/08/24]

^[41] Institute of Air Quality Management (2017) Land-Use Planning & Development Control: Planning for Air Quality. Paragraph 5.8. Available at: https://www.iaqm.co.uk/text/guidance/air-quality-planning-guidance.pdf [Date accessed: 07/08/24]

^[42] Department for Environment, Food and Rural Affairs (2024) Local Authority Collected Waste Statistics. Available at: https://www.gov.uk/government/statistics/local-authority-collected-waste-management-annual-results [Date accessed: 07/08/24]

^[43] Department for Environment Food and rural Affairs (2024) Statistics on waste managed by local authorities in England in 2022/23. Available at: https://www.gov.uk/government/statistics/local-authority-collected-waste-management-annual-results/local-authority-collected-waste-management-annual-results-202223#:~:text=In%202022%2C%20total%20'waste%20from,decrease%20of%207.9%20per%20cent. [Date accessed: 07/08/24]

^[44] People per dwelling has been calculated using the ONS mid-2021 population estimates (Available at: https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationestimates/datasets/populationestimatesforukenglandandwalesscotlandandnorthernireland) and dwelling stock (Available at: https://www.gov.uk/government/statistical-data-sets/live-tables-on-dwelling-stock-including-vacants) [Date accessed: 07/08/24]

^[45] Unpublished data provided to Lepus by the Council – Black Country Accessibility Modelling (2021)

^[46] Transport for West Midlands (2022) Transport for West Midlands Data Portal. Available at: https://data-tfwm.opendata.arcgis.com/ [Date accessed: 07/08/24]

^[47] Barton, H., Grant. M. & Guise. R. (2010) Shaping Neighbourhoods: For local health and global sustainability, January 2010

^[48] Transport for West Midlands (2022) Transport for West Midlands Data Portal. Available at: https://data-tfwm.opendata.arcgis.com/ [Date accessed: 07/08/24]

^[49] Ibid

^[50] Google Maps (2024) Available at: https://www.google.co.uk/maps

^[51] Ibid

^[52]Dempsey. N., Brown. C. and Bramley. G. (2012) The key to sustainable urban development in UK cities? The influence of density on social sustainability. Progress in Planning 77:89-141

^[53] Ministry of Housing, Communities and Local Government (2019) The English Indices of Deprivation 2019. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/835115/IoD2019_Statistical_Release.pdf [Date accessed: 07/08/24]

^[54] Sandwell Metropolitan Borough Council (2023) Deprivation – Sandwell in a West Midlands Context. Available at: https://www.sandwelltrends.info/deprivation_west_midlands_context/#:~:text=England%20is%20made%20up%20of,deprived%2010%25%20nationally%20in%202019. [Date accessed: 07/08/24]

^[55] Ministry of Housing, Communities and Local Government (2019) Indices of Multiple Deprivation (IMD). Available at: http://data-communities.opendata.arcgis.com/datasets/indices-of-multiple-deprivation-imd-2019-1?geometry=-2.688%2C52.422%2C-1.456%2C52.714 [Date accessed: 07/08/24]

^[56] Unpublished data provided to Lepus by the Council – Black Country Accessibility Modelling (2021)

^[57] NHS (2024) NHS hospitals overview. Available at: https://www.nhs.uk/service-search/other-services/Accident-and-emergency-services/LocationSearch/428 [Date accessed: 07/08/24]

^[58] Barton, H., Grant. M. & Guise. R. (2010) Shaping Neighbourhoods: For local health and global sustainability, January 2010

^[59] SMBC (2023) Projects: Midland Metropolitan University Hospital. Available at: https://regeneratingsandwell.co.uk/sandwell_projects/midland-metropolitan-university-hospital/ [Date accessed: 07/08/24]

^[60] SMBC (2023) Projects: Wednesbury Health Centre and Housing. Available at: https://regeneratingsandwell.co.uk/sandwell_projects/wednesbury-health-centre-and-housing/ [Date accessed: 07/08/24]

^[61] Ordnance Survey (2023) OS Open Greenspace. Available at: https://www.ordnancesurvey.co.uk/business-government/products/open-map-greenspace [Date accessed: 07/08/24]

^[62] Barton, H., Grant. M. & Guise. R. (2010) Shaping Neighbourhoods: For local health and global sustainability, January 2010

^[63] Transport for West Midlands (2021) Transport for West Midlands Data Portal. Available at: https://data-tfwm.opendata.arcgis.com/ [Date accessed: 07/08/24]

^[64] Unpublished data provided to Lepus by the Council – Black Country Accessibility Modelling (2021)

^[65] Google Maps (2024) Available at: https://www.google.co.uk/maps

^[66] Unpublished data provided to Lepus by the Council

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