Sustainability Appraisal of the Sandwell Local Plan 2024-2041

SEC3-181

SEC4-1

SEC3-9

SEC3-99

SH1

SEC3-113

SEC3-46

SEC3-175

SEC3-36

SEC3-29

SEC3-148

SH2

SEC4-4

SEC3-191

SEC4-3

SEC3-133

SEC3-189

SEC3-22

SEC3-40

SEC1-4

SH3

SH4

SH5

SH6

SH7

SH8

SH9

SH62

SH10

SH11

35

36

38

40

42

43

44

45

46

SH13

SH14

SH15

SEC3-79

SH16

SH17

SH18

SEC3-193

SH19

SH20

SH21

SH22

SH23

63

SH24

SH25

SH26

SH27

SH28

SH29

71

74

SH30

SH31

SH32

SH33

SH34

SH35

SH36

SH37

SEC3-66

SH38

SM1

SH40

SH41

SH42

SEC1-3

110

118

120

132

137

140

142

SH43

SH44

SH47

SM3

SH49

SM4

SH50

SH51

SM5

SM6

SM7

SH52

SM8

SH53

SH54

SH55

SH56

SH57

SH58

SG1

188

189

SH59

191

SH61

SEC1-1

SEC1-8

SEC1-5

SEC1-6

SEC1-2

SEC1-7

SM2

SH45

SH63

SH65

SH64

SH66

Identified adverse effects on cultural heritage

• Direct adverse effects on heritage assets: A small number of reasonable alternative sites coincide with designated heritage assets (Grade II* and II Listed Buildings and scheduled monuments (SMs)), where there is potential for direct adverse impacts on heritage features. This includes Site SH7 which coincides with the 'Boat Gauging House' and Site SH14 which coincides with 'Langely Maltings' Grade II Listed Buildings.
• Alteration of character or setting of heritage assets: The proposed development at several reasonable alternative sites which lie within or in close proximity to conservation areas, or in close proximity to designated heritage assets (listed buildings, registered parks and gardens (RPGs) or scheduled monuments (SMs)) have been identified to potentially have an adverse impact on the setting or character of these heritage assets.

Policy mitigation for potential adverse effects associated with cultural heritage

• Policy SHE1: Listed buildings and conservation areas states that development proposals will be required to "conserve and enhance local character" and those aspects of the historic environment together with their settings and recognises that listed buildings, conservation areas and SMs are an irreplaceable resource. The policy also requires development proposals that would affect a heritage asset to carry out an Assessment of Significance which would inform part of a Design and Access Statement and / or a Heritage Impact Assessment.
• Policy SHE2: Development in the historic environment states that heritage assets within the borough will be "retained and, wherever possible, enhanced and their settings respected".
• Policy SHE3: Locally listed buildings ensures heritage assets are conserved and enhanced, stating that development proposals affecting locally listed buildings will only be permitted where they "positively contribute towards the significance of the heritage asset and avoid harm".
• Policy SHE4: Archaeology states that "development should protect and conserve both designated and non-designated archaeological assets and the character and setting of areas of acknowledged archaeological significance". The policy also requires sites with known archaeological potential to provide an archaeological assessment and / or field evaluation.
• Policy SDS5: Achieving well-designed places aims to ensure that new development conserves and where possible enhances the setting and significance of heritage assets, demonstrating a "clear understanding of the local and wider context, character, heritage and local distinctiveness".
• Many SLP policies including Policy SDS1: Spatial Strategy for Sandwell and SDS3: Regeneration in Sandwell encourage regeneration and redevelopment of industrial land, town centres and canal corridors with potential opportunities for enhancement of cultural heritage features and historic buildings which can contribute to creating a strong sense of place and celebrating Sandwell's history.
• Policy SNE6: Canals recognises the historic, architectural, archaeological and cultural significance of the canal network and will ensure that any development proposals affecting canals will protect and enhance these aspects.

Commentary: Will the policies mitigate the identified adverse effects?

• Direct adverse effects on, and alteration of the character/setting of heritage assets: YES ✓ The SLP policies will be expected to mitigate the identified adverse effects on designated cultural heritage assets and ensure opportunities are sought to enhance the historic environment. Non-designated heritage assets will also be protected and conserved under these policies, including areas of high historic value.

Identified adverse effects on landscape

• Threaten or result in the loss of locally distinctive or sensitive landscapes: All reasonable alternative sites lie outside of the landscape sensitivity assessment area and therefore the impact these will have on sensitive landscapes is uncertain (with the exception of Site 137 which is identified to be located within an area of 'low' landscape sensitivity). The proposed development at the reasonable alternative sites has potential to alter the characteristics of the local landscape and townscape.

Policy mitigation for potential adverse effects associated with landscape

• Policy SHE1: Listed buildings and conservation areas states that development proposals will be required to "conserve and enhance local character". This is supported by Policies SHE2: Development in the historic environment, SHE3: Locally listed buildings and SHE4: Archaeology, which will ensure the protection and enhancement of heritage assets within the borough to positively contribute to local character and distinctiveness.
• Policy SDS8: Green and blue infrastructure in Sandwell provides measures to support green and blue infrastructure within the borough, which is expected to positively contribute to the locally distinctive landscape and townscape character. Policy SDS2: Increasing efficiency and resilience supports this by encouraging an increase in green cover and the incorporation of "landscaping schemes".
• Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows supports the provision, retention and protection of trees, woodlands and hedgerows, which would also be expected to contribute towards the conservation and enhancement of landscape character through urban greening.
• Policy SNE5: The Rowley Hills aims to protect the Rowley Hills from inappropriate development that will lead to the loss of valued qualities that make up the local landscape character, including panoramic views.
• Policies SDM1: Design quality, SDM2: Development and design standards, SDM3: Tall buildings and gateway sites, SDS5: Achieving well-designed places and other Development Management policies seek to ensure that new development creates a strong sense of place and help to conserve and enhance the landscape / townscape character, and will ensure the visual effects of relevant proposals (such as tall buildings) are identified and assessed.
• Many SLP policies including Policy SDS1: Spatial Strategy for Sandwell and SDS3: Regeneration in Sandwell encourage regeneration and redevelopment of industrial land, town centres and canal corridors with potential opportunities for enhancement of Sandwell's townscapes which can contribute to creating a strong sense of place and improve the appearance and function of urban areas.

Commentary: Will the policies mitigate the identified adverse effects?

• Threaten or result in the loss of locally distinctive or sensitive landscapes: YES ✓ The SLP policies are expected to ensure that the potential for adverse effects on the landscape and townscape character associated with new developments are identified, assessed and mitigated, ensuring that new development respects and enhances local distinctiveness.

Identified adverse effects on biodiversity, flora, fauna and geodiversity

• Threats or pressures to European sites: New development within Sandwell has potential to have direct, indirect and in-combination impacts on the integrity of European sites surrounding the Plan area. These potential effects are explored in more detail in the Habitats Regulations Assessment (HRA), including consideration of likely significant effects on European sites from recreation, urbanisation, changes in water quantity and quality, and air quality.
• Threats or pressures to locally designated / non-statutory biodiversity sites: There is potential for the introduction of new development to lead to increased development related pressures and threats, including through reductions in air quality and water quality/quantity, habitat fragmentation and recreational pressures on biodiversity sites such as LNRs, SINCs and SLINCs.
• Loss or fragmentation of priority habitats: The proposed development at a small number of reasonable alternative sites could potentially result in the loss or degradation of priority habitats, resulting in habitat fragmentation and isolation of the wider ecological network.

Policy mitigation for potential adverse effects associated with biodiversity, flora, fauna and geodiversity

• Policy SNE1: Nature conservation seeks to protect, conserve and enhance biodiversity assets including international, national and local designations. Where the benefits of development strategically outweigh the importance of a local nature conservation site, "damage must be minimised" and remaining impacts must be fully mitigated with an accompanying mitigation strategy. This policy also states that development proposals will need to take account of the emerging Local Nature Recovery Strategy and "should plan for the maintenance and where possible enhancement of such linkages".
• Policy SNE2: Protection and enhancement of wildlife habitats supports the provision and enhancement of priority habitats and increased green cover as part of the implementation of biodiversity net gain (BNG), and will ensure that off-site BNG can be secured in the first instance within Sandwell Borough.
• Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows aims to utilise these biodiversity features for habitat creation and the restoration of ecological networks. This is supported by Policies SDS3: Regeneration in Sandwell, SDS8: Green and blue infrastructure in Sandwell, SNE5: The Rowley Hills, SNE6: Canals, SDM1: Design quality and SHW4: Open space and recreation all of which seek to improve habitat creation, enhancement and connectivity in the Plan area as well as wider green infrastructure (GI) coverage.

Commentary: Will the policies mitigate the identified adverse effects?

• Threats or pressures to European sites: YES ✓ SLP Policy SNE1 is expected to mitigate potential adverse impacts on European sites and associated functionally linked land, subject to the recommendations of the emerging HRA.
• Threats of pressures to locally designated / non-statutory biodiversity sites: NO X The SLP policies are expected to help mitigate potential adverse impacts on locally designated sites and deliver BNG for all development sites. However, these policies are not expected to fully mitigate potential adverse impacts on LNRs, SINCs and SLINCs where proposed development sites coincide with, or are located directly adjacent to, these assets.
• Loss or fragmentation of priority habitats: NO XAlthough the SLP policies are likely to enhance the connectivity between habitats and improve the resilience of ecological and GI networks to current and future pressures, these policies are unlikely to prevent the loss of priority habitat where the majority of some sites coincides with priority habitat.

Identified adverse effects on climate change mitigation

• Increased carbon emissions: It is likely that new development will result in an increase in local carbon emissions due to the increase in the local population and the number of operating businesses. The increase in carbon 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.

Policy mitigation for potential adverse effects associated with climate change mitigation

• Various policies support improved low-emission forms of transport provision, including Policy STR1: Priorities for the development of the transport network and Policy STR9: Planning for low emission vehicles, as well as policies STR2, STR3, STR4, STR5, STR6, STR8 and SHW3. These policies support a reduction in private car use through reducing the need to travel, improved public transport connectivity and supporting methods of sustainable and active travel, whilst seeking to improve traffic flows to reduce pollutant emissions.
• Policy SDS2: Increasing efficiency and resilience aims to ensure that development proposals seek opportunities for adaptation to, and mitigation of, climate change. This is supported by various other SLP policies including Policy SCC2: Reducing operational carbon for new build non-residential development, SCC1: Energy infrastructure,and Policy SDMI: Design quality, which together promote energy-efficient development proposals which support low carbon technologies and encourage the use of decentralised energy sources and communal heating systems, which will likely result in a decrease in greenhouse gas (GHG) emissions from the construction and occupation of new development.
• Policy SCC3: Climate-adapted design and construction aims to reduce the risk of heat gain and the urban heat island effect (UHI) through efficient building design. The policy requires "passive ventilation" and "active cooling systems", in order to reduce heat gain lost to the environment, which has potential for cumulative adverse effects when considering the impacts of global warming as a consequence of climate change.
• Policy SCC4: Embodied carbon and waste aims to limit the amount of embodied carbon resulting from the proposed development by completing a whole-life carbon assessment for large-scale developments and considering a range of options for small-scale development.
• Policy SDS8: Green and blue infrastructure in Sandwell and Policy SNE3: Provision, retention and protection of trees, woodlands and hedgerows encourage enhancements to the provision and connectivity of GI/BI, which will help to support ecosystem service functions such as the filtration of air pollutants and could potentially result in reducing impacts from increased GHG emissions.

Commentary: Will the policies mitigate the identified adverse effects?

• Increased carbon emissions: NO X Although these policies strongly support a reduction in GHG emissions associated with development, the policies would not be expected to fully mitigate GHG emissions from development, for example, arising from the release of embodied carbon, GHG emissions from the operation of development and potential loss of carbon stores, for example in soils.

Identified adverse effects on climate change adaptation

• Risk of fluvial flooding: A small number of reasonable alternative sites are located within areas prone to the risk of fluvial flooding. This includes 11 sites where the site boundary includes land within Flood Zones 2 or 3, where five sites also coincide with indicative flood zones. Development at these locations will be likely to locate site end users in areas at risk of flooding, as well as exacerbate existing fluvial flood risk on site and downstream.
• Surface water flood risk: The majority of reasonable alternative sites coincide with areas at low and/or medium surface water flood risk (SWFR). A smaller number of sites contain areas of high SWFR. Development at these locations will be likely to locate site end users in areas at risk of flooding, as well as exacerbate flood risk in surrounding locations.

Policy mitigation for potential adverse effects associated with climate change adaptation

• Policy SCC5: Flood risk sets out measures to identify and manage the risk of flooding throughout the borough and ensure that development is avoided in areas of high fluvial and surface water flood risk, in line with the NPPF. The policy also encourages development proposals to naturalise urban watercourses and open up culverts to provide multi-functional benefits, including for reinstating natural river channels.
• Policy SCC6: Sustainable drainage underpins Policy SCC5 in relation to sustainable drainage systems (SuDS), outlining design requirements and states that "surface water drainage strategies are required for all major developments, regardless of their size and the flood zone and catchment they are in".
• Policy SNE6: Canals recognises the role the canal network can play in surface water management, encouraging the incorporation of SuDS and other mitigation measures where possible.
• Policy SHO10: Accommodation for Gypsies, Travellers and Travelling Showpeople will ensure that development for these communities is situated away from areas of flood risk.
• Various policies including Policies SNE1: Nature conservation, SDS8: Green and blue infrastructure in Sandwell, SHW4: Open space and recreation and SDM1: Design quality provide measures that would protect and enhance green and blue infrastructure and ecosystem services, with likely multi-functional benefits including for flood water storage, intercepting rainfall and mitigation of flood risk.

Commentary: Will the policies mitigate the identified adverse effects?

• Risk of fluvial or surface water flooding: YES ✓ Assuming that the Sequential Test is passed, or the Exception Test is applied where required, these policies are expected to mitigate potential adverse impacts associated with development in areas at risk of fluvial or surface water flooding.

Identified adverse effects on natural resources

• Loss of previously undeveloped land / land with environmental value: Over half of reasonable alternative sites comprise previously developed land; however, a large number of reasonable alternative sites wholly or partially comprise greenfield land / land with environmental value which is likely to be lost as a result of the proposed development.

Policy mitigation for potential adverse effects associated with natural resources

• The proposed development strategy for the SLP promotes the use of brownfield land as much as possible. Policy SDS1: Spatial Strategy for Sandwell states that development within the borough will seek to achieve sustainable development through "delivering development on brownfield sites in the urban area".
• Underpinning Policy SDS1 are Policies SDS3: Regeneration in Sandwell which focuses on regeneration of existing urban areas, SCO3: Land contamination and instability which encourages development to make use of contaminated land, SDM3: Tall Buildings and Gateway Sites which supports higher density development which will reduce overall land-take and make efficient use of land, and SHO2: Windfall developments which aims to prevent the use of unallocated greenfield land for development. These policies will help to ensure undeveloped land is protected and that previously developed land in urban areas is utilised.
• Policies SNE1: Nature conservation, SNE2: Protection and enhancement of wildlife habitats, SNE3: Provision, retention and protection of trees, woodlands and hedgerows, SDS7: Sandwell's Green Belt and SDS8: Green and blue infrastructure in Sandwell, include measures that protect land and soil resources with ecological, agricultural or environmental value.

Commentary: Will the policies mitigate the identified adverse effects?

• Loss of previously undeveloped land / land with environmental value: NO X The above policies will help to promote an efficient use of land and reduce the loss of undeveloped land and associated soil resources; however, the policies would not be expected to fully mitigate these impacts and some small-scale losses of soil will remain.

Identified adverse effects on pollution

• Reduction in air quality: Impacts on air quality may arise during construction and operation

of different types of development. The proposed development within the SLP will also be likely to increase the volume of traffic and traffic-related emissions within the Plan area with consequent adverse impacts on air quality.

• Exposure to air pollution from AQMAs and main roads: All reasonable alternative sites lie within Sandwell Air Quality Management Area (AQMA). In addition, several major roads pass through Sandwell, where a large proportion of sites lie within 200m of these main roads. The proposed development could exacerbate air pollution issues regarding existing AQMAs and expose site end users to poor air quality associated with road transport emissions.
• Risk of contamination of watercourses: A small number of reasonable alternative sites lie in within 10m of a watercourse where development has higher potential to lead to deterioration in water quality in Sandwell and downstream. All reasonable alternatives may contribute to cumulative adverse effects on water quality.
• Risk of contamination of groundwater Source Protection Zones: Several reasonable alternative sides wholly or partially coincide with a groundwater Source Protection Zone (SPZ), which has potential to physically disturb an aquifer or hinder ecosystem services related to water filtration.

Policy mitigation for potential adverse effects associated with pollution

• Under Policy SHW3: Air quality development will only be permitted where it can be demonstrated that it will not further deteriorate existing poor air quality, supported by Policy SHWI: Health Impact Assessments. Any development that has potential to lead to significant adverse impacts on air quality will need to undertake an air quality assessment.
• Policy SDS2: Increasing efficiency and resilience ensures that development proposals will be designed to avoid a reduction in air quality and subsequent adverse impacts on human health. The policy is underpinned by other policies that aim to reduce emission of air pollutants and particulate matter through promoting energy efficiency for new development, including Policies SCC1: Energy Infrastructure and SCC2: Reducing operational carbon for new build non-residential development.
• Policies SDS8: Green and blue infrastructure in Sandwell and SNE3: Provision, retention and protection of trees, woodlands and hedgerows encourage enhancements to the provision and connectivity of GI/BI, which will help to support ecosystem service functions such as the filtration of air and water and could potentially result in improvements to air and water quality.
• Various policies seek to improve traffic flows and promote sustainable and active modes of transport which will help to avoid reductions in air quality, including Policy STR1: Priorities for the development of the transport network and Policy STR5: Creating coherent networks for cycling and walking, as well as other transport policies STR2-STR9.
• Policy SCC5: Flood Risk seeks to ensure that no development is permitted within a groundwater SPZ that could physically disturb an aquifer, whilst also outlining requirements for the inclusion of SuDS in development proposals which can play a role in improving water quality.
• Various SLP policies including Policies SNE1: Nature Conservation, SNE2: Protection and Enhancement of Wildlife Habitats, SNE3: Provision, retention and protection of trees, woodlands and hedgerows, SDM1: Design Quality and SDS7: Sandwell's Green Belt will help to increase green cover and protect biodiversity assets that will provide ecosystem services such as the filtration of air and water.
• Policy SNE6: Canals requires development proposals to protect and enhance the canal network, including the water quality of canals.

Commentary: Will the policies mitigate the identified adverse effects?

• Reduction in air quality: NO X The Local Plan policies will contribute towards general improvements in air quality within the borough; however, it is unlikely that the adverse effects associated with the poor air quality will be fully mitigated by these policies. Further interventions, such as the introduction of car-free zones, may be necessary to fully mitigate the effect of introducing new development, and associated traffic, into areas where baseline air quality is already poor.
• Exposure to air pollution from AQMAs and main roads: NO X These policies will help to minimise adverse impacts associated with the exposure of site end users to poor air quality associated with main roads and AQMAs. However, these policies would not be expected to fully mitigate these adverse impacts when considering the implications of delivering the large scale of proposed development all of which will lie within the Sandwell AQMA.
• Risk of contamination of groundwater Source Protection Zones: YES ✓ These policies are expected to mitigate negative impacts associated with development on groundwater SPZs.
• Risk of contamination of watercourses: NO X These policies may help to lessen adverse impacts on water quality associated with new development, however they would not be expected to fully mitigate these effects.

Identified adverse effects on waste

• Increase in waste: It is expected that new development proposed through the SLP will result in an increase in the local population, and consequently an increase in household waste generation. When considered individually, a total of 18 reasonable alternative sites have potential to increase waste in proportion to the Plan area by more than 0.1% compared to existing levels. Cumulatively, all reasonable alternative sites would contribute towards a significant increase in household waste if developed.

Policy mitigation for potential adverse effects associated with waste

• Policy SWA1: Waste infrastructure future requirements sets out the waste infrastructure requirements to be adhered to throughout the borough, seeking to reduce the generation of waste and associated pollution, promote re-use and recycling of waste in line with the waste hierarchy. The policy ensures the "minimisation of waste production and the re-use and recovery of waste materials" by providing sufficient waste facilities.
• Policy SWA5: Resource management and new development requires all new developments to "minimise waste as far as possible" and seeks to maximise the use of "secondary and recycled materials, renewable and locally sourced products and materials with low environmental impacts" wherever possible. The policy will help to promote sustainable and efficient waste management and use of materials across all new development in Sandwell and limit the generation of waste as much as is feasible.
• Policy SCC4: Embodied carbon and waste encourages building design to facilitate the re-use of and easy disassembly of materials which would contribute to reducing the need for demolitions when buildings are no longer required, reducing the quantity of waste produced in the construction and demolition of the proposed development.
• Policy SEC3: Local Employment Areas seeks to safeguard areas for "waste collection, transfer and recycling uses", supporting the efficient management and disposal of waste.
• Policy SID1: Infrastructure provision sets out the overarching requirement for the provision of new infrastructure to support new development proposed in the Sandwell area, which is expected to include utilities such as waste and recycling.
• Policies SWA2: Waste sites, SWA3: Preferred areas for new waste facilities and SWA4: Locational considerations for new waste facilities set out measures to ensure waste facilities meet the demand of the borough in regard to capacity. These make sure waste facilities are sustainable by nature/design, whilst being strategically located in suitable locations.

Commentary: Will the policies mitigate the identified adverse effects?

• Increase in waste: NO X These policies have potential to encourage recycling and appropriate waste disposal within new developments; however, the policies are not expected to fully mitigate the increase in household waste which is predicted to occur due to the increased number of dwellings in the Plan area.

Identified adverse effects on transport and accessibility

• Limited access to bus services: A small number of reasonable alternative sites were identified to be located beyond the sustainable distance of 800m to a bus stop providing regular services, potentially limiting access to sustainable transport options for site end users.
• Limited access to the railway network: A small number of reasonable alternatives sites were assessed as having poor access to the railway network in Sandwell, located over 1.2km away from the nearest railway or metro station.
• Limited access to local services: Sustainable access to local services (which includes centres and facilities providing fresh food) is limited in some areas, with a number of reasonable alternative sites located beyond the sustainable walking and/or public transport travel time of 15 minutes.
• Limited access to pedestrian footways and roads: A small number of sites are not connected to existing pedestrian footways and roads, potentially limiting accessibility to and from the site for site-end users.

Policy mitigation for potential adverse effects associated with transport and accessibility

• Policy STR1: Priorities for the development of the transport network states that "all new developments must provide adequate access for all modes of travel, including walking, cycling and public transport". The policy also identifies the "Midlands Rail Hub" and "West Midlands Core Bus Network corridors" as key transport priorities, amongst others.
• Policy STR2: Safeguarding the development of the Key Route Network (KRN) seeks to ensure the KRN is effectively managed in order to support the level of growth proposed in the SLP over the Plan period, and could potentially encourage coordination and streamlining of transport systems including public transport such as rapid transit and bus routes.
• By directing development towards the Strategic Centre (West Bromwich) and the hierarchy of Town, District and Local Centres, Policy SDS1: Spatial Strategy for Sandwell will be likely to facilitate more sustainable communities, by locating residents in close proximity to services, facilities and public transport.
• Policy SDS3: Regeneration in Sandwell highlights a number of transport infrastructure projects which will help to improve access to sustainable travel options, including the new Midland Metro Extension and Dudley Port railway station. Improvements to public transport connectivity / interchanges within regeneration areas and linking to these wider projects will be supported.
• Various SLP policies including Policies STR3: Managing transport impacts of new development, STR5: Creating coherent networks for cycling and walking, STR6: Influencing the demand for travel and travel choices, SHW2: Healthcare infrastructure, SHW3: Air quality and SDS5: Achieving well-designed places include measures that aim to improve accessibility to bus services, rail infrastructure, active travel routes and local services.
• Sandwell's Centres policies SCE1-SCE6 support appropriate uses within centres to meet day to day needs of residents and visitors to these areas, in accordance with the settlement hierarchy, including Policy SCE5: Provision of Small-scale local facilities not in centres which supports the provision of new small-scale local facilities outside of centres.
• Policy SDM9: Community facilities supports the retention of, and development of new, community facilities.

Commentary: Will the policies mitigate the identified adverse effects?

• Limited access to bus services: YES ✓ These policies encourage the expanded use of Sandwell's bus network and are expected to mitigate the restricted access to the bus services within the borough, which affects only a few reasonable alternative sites.
• Limited access to the railway network: YES ✓ These policies encourage the use of the railway network in the borough and are expected to mitigate the restricted access to the railway network, which affects only a few sites.
• Limited access to local services and facilities: YES ✓ These policies are expected to improve access to local services and facilities including via public transport.
• Limited access to pedestrian footways and roads: YES ✓ These policies are expected to ensure all sites are closely linked with the pedestrian and road networks, and that active travel networks are expanded and connectivity is improved.

Identified adverse effects on equality

• Growth in deprived areas: A number of reasonable alternative sites are located in Lower Super Output Areas (LSOAs) that fall within the 10% most deprived in England according to the Index of Multiple Deprivation (IMD). The proposed development within these locations could potentially exacerbate existing social pressures in the local area and increase demand on local services, without careful planning.

Policy mitigation for potential adverse effects associated with equality

• Policies SDS1: Spatial Strategy for Sandwell, SDS5: Achieving well-designed places, SCE5: Provision of small-scale local facilities not in centres, SDS3: Regeneration in Sandwell, SEC5: Improving access to the labour market and SID1: Infrastructure provision include measures that will ensure residents have access to local services, including employment opportunities, various public transport methods, shops, educational facilities, leisure and sport facilities and public open space, including for those living in the most deprived areas.
• Policy SDM9: Community facilities sets out support for new community facilities within centres, and will ensure that any security and crime issues associated with new community developments are identified and addressed. This has the potential to reduce crime and social deprivation.
• Policies SHO8: Education facilities and SHW2: Healthcare infrastructure state that educational and healthcare facilities should be "located to address accessibility gaps" which will help to reduce health inequalities and improve equal access to educational opportunities.
• Policy SHW5: Playing fields and sports facilities states that playing fields and sports facilities "will be encouraged, especially in areas where public provision is deficient".
• Policies SHO3: Housing density, type and accessibility, SHO4: Affordable housing and SHO10: Housing for people with specific needs aim to ensure that the Plan delivers an appropriate density and mix of housing, well-distributed affordable housing provision and for housing to meet the varied needs of current and future residents in Sandwell.
• Policy SHO5: Delivering accessible and self/custom build housing seeks to ensure an appropriate mix of accessible and adaptable homes are delivered across the Plan area, as well as the opportunity for self-build homes, in line with national policy and the Building Regulations.
• Policy SHO10: Accommodation for Gypsies, Travellers and Travelling Showpeople will ensure the SLP meets the identified pitch targets for Gypsies and Travellers and plot targets for Travelling Showpeople, as set out in the latest Gypsy and Traveller Accommodation Assessment (GTTA).

Commentary: Will the policies mitigate the identified adverse effects?

• Residents located in deprived areas: YES ✓ The SLP policies are likely to ensure that new development provides site end users with good access to services and facilities, and that new infrastructure is provided to address inequalities.

Identified adverse effects on health

• Limited access to healthcare facilities: Sustainable access to healthcare is limited for a small number of sites in Sandwell, with the majority of reasonable alternative sites located beyond 5km from a hospital providing an A&E service, and a small proportion of sites being located beyond a 15-minute journey via walking or public transport from a GP surgery.
• Limited access to the PRoW or cycle network: A small number of sites are located away from existing public rights of way (PRoW) and/or cycle paths, which may result in site end users relying upon less sustainable modes of transport for local travel including private car use.
• Loss of public greenspace: A small number of reasonable alternative sites coincide with existing public greenspaces, where there is potential for the proposed development to result in a net loss of greenspace across the borough.

Policy mitigation for potential adverse effects associated with health

• Policy SDS1: Spatial Strategy for Sandwell seeks to direct housing growth towards locations with the highest levels of sustainable transport access to services including healthcare facilities, and will ensure that new public open spaces are created to serve new housing developments.
• Policy SHW1: Health Impact Assessments sets out the requirement for certain development proposals to undertake an HIA to ensure that adverse effects associated with physical and mental health and access to and demand for health and social care services are addressed, and that opportunities for promoting healthy lifestyles are maximised.
• Policy SHW2: Healthcare infrastructure states that new healthcare facilities should "well-designed" and "well-served by public transport infrastructure". Furthermore, the policy requires any development that has unacceptable impacts upon the functionality of healthcare facilities to "contribute to the provision or improvement of such services", and will ensure there is sufficient capacity in healthcare infrastructure to serve new growth.
• Policy SDM9: Community facilities includes measures to increase provision for community and leisure facilities, which has potential to encourage site end users to live active and healthy lifestyles.
• Policies STR1: Priorities for the development of the transport network, STR2: Safeguarding the development of the KRN, STR5: Creating coherent networks for cycling and walking and SDS4: Achieving well-designed places provide measures that improve accessibility to healthcare and leisure facilities. These policies also promote the usage of sustainable and active methods of transport and improved opportunities for outdoor exercise and recreation, including through improving accessibility to the pedestrian and cycle networks.
• Policies SHW5: Playing fields and sports facilities and Policy SHW4: Open space and recreation will ensure sufficient greenspace and recreational space is available in Sandwell through addressing any shortfalls. These policies encourage wider community use of school playing fields and sports facilities as well as maintaining/enhancing the accessibility, quality and quantity of open spaces.

Commentary: Will the policies mitigate the identified adverse effects?

• Limited access to healthcare facilities: YES ✓ The SLP policies will help ensure that residents across Sandwell have sustainable access to healthcare and leisure facilities whilst improving the quality of these services.
• Limited access to the pedestrian or cycle network: YES ✓ These policies are expected to mitigate adverse impacts associated with restricted access to the pedestrian, PRoW and cycle networks, and help encourage the uptake of these sustainable transport options.
• Loss of public greenspace: YES ✓ These policies are expected to ensure that development proposals do not result in the net loss of public greenspace across the Plan area.

Identified adverse effects on the economy

• Net loss of employment floorspace: Where reasonable alternative sites coincide with existing employment areas, there is potential for a net decrease in employment floorspace across the Plan area, leading to adverse effects on the local economy and provision of jobs.
• Limited access to employment opportunities: In some areas of the borough, sustainable access to key employment areas and the range of employment opportunities they provide may be more limited, owing to a small number of sites being located beyond a 20-minute journey by foot or public transport.

Policy mitigation for potential adverse effects associated with the economy

• Policy SDS1: Spatial Strategy for Sandwell aims to provide 1,206ha of employment land throughout the Plan period, which also includes measures to retain existing employment areas.
• Policy SDS3: Regeneration in Sandwell states that the defined Regeneration Areas will provide high-quality employment land and will be the principal location for new industrial/logistics development, with likely benefits in terms of economic growth and providing opportunities for developing a skilled workforce.
• Policy SEC1: Providing for economic growth and jobs also supports the renewal and regeneration of existing employment areas and sets out the provision of employment land to be delivered. This is supported by Policy SDM9: Community facilities which ensures any proposals for community facilities will not be permitted should it involve the loss of premises or sites located within a strategic or local employment area.
• Policy SEC2: Strategic Employment Areas ensures these spaces will be defined primarily by commercial uses, businesses and services with "excellent accessibility". Alongside this, Policy SEC3: Local Employment Areas characterises these spaces as being predominantly having industrial, warehouse or services in accessible locations for local markets and employees. Policy SEC4: Other Employment Sites supports this by providing new industrial employment or extensions to existing industrial employment uses.
• Policy SEC5: Improving access to the labour market supports major developments for new jobs that will be readily available for residents of Sandwell, specifically those living in the most deprived areas.
• Policies SDM1: Design Quality, STR1: Priorities for the development of the transport network, STR2: Safeguarding the development of the KRN, STR3: Managing transport impacts of new development and STR5: Creating coherent networks for cycling and walking ensure that residents have sustainable access to employment opportunities through well-designed places and strong transport infrastructure.
• Policies SID2: Digital infrastructure and SDM10: Telecommunications will aim to improve access to employment opportunities, including home working, through the provision of a strong fibre network and telecommunications infrastructure.

Commentary: Will the policies mitigate the identified adverse effects?

• Net loss of employment floorspace: YES ✓ The SLP policies are expected to mitigate the potential adverse impacts associated with the loss of existing employment uses associated with the reasonable alternative sites, and ensure enough employment land is delivered to meet

the identified needs for the Plan period.

• Limited access to employment opportunities: YES ✓ The SLP policies are expected to improve sustainable access to a varied range of employment opportunities across the Plan area, including for those in deprived areas.

Identified adverse effects on education, skills and training

• Limited access to educational opportunities: A small number of reasonable alternative sites are located over a 15-minute walk to a primary school, whereas a slightly larger proportion of sites are located over 25-minutes away either by foot or public transport from a secondary school. This is likely to lead to a greater reliance on less sustainable modes of transport to reach local schools.

Policy mitigation for potential adverse effects associated with education, skills and training

• Policy SHO8: Education facilities supports the development or expansion of education facilities and states that nurseries, schools and higher education facilities should be "well- designed" and "well-served by public transport infrastructure".
• Various SLP policies, including Policies SDM1: Design quality, SCE1: Sandwell's Centres, STR1: Priorities for the development of the transport network, STR2: Safeguarding the development of the KRN, STR3: Managing transport impacts of new development and STR5: Creating coherent networks for cycling and walking will help to ensure that residents have sustainable access to education opportunities through well-designed places and strong transport infrastructure.
• Policy SID1: Infrastructure provision sets out the overarching requirement for the provision of new infrastructure to support new development proposed in the Sandwell area, which is expected to include residential services such as education.
• Policy SID2: Digital infrastructure may help to provide additional access to online educational opportunities by the provision of a strong fibre network and telecommunications.
• Policies SWB2: Development in West Bromwich and SCE3: Town Centres (tier-two centres) include measures that support the development of educational facilities.
• Policy SDS1: Spatial Strategy for Sandwell seeks to direct housing growth towards locations with the highest levels of sustainable transport access to services including schools.

Commentary: Will the policies mitigate the identified adverse effects?

• Limited access to educational opportunities: YES ✓ The SLP policies are expected to improve access to schools and education facilities across the Plan area, including transport connectivity to encourage sustainable and active modes of transportation, and encourage the development / expansion of schools which will help to ensure there is sufficient capacity to serve new growth.

SEC3-181

SEC4-1

SEC3-9

SEC3-99

SH1

SEC3-113

SEC3-46

SEC3-175

SEC3-36

SEC3-29

SEC3-148

SH2

SEC4-4

SEC3-191

SEC4-3

SEC3-133

SEC3-189

SEC3-22

SEC3-40

SEC1-4

SH3

SH4

SH5

SH6

SH7

SH8

SH9

SH62

SH10

SH11

35

36

38

40

42

43

44

45

46

SH13

SH14

SH15

SEC3-79

SH16

SH17

SH18

SEC3-193

SH19

SH20

SH21

SH22

SH23

63

SH24

SH25

SH26

SH27

SH28

SH29

71

74

SH30

SH31

SH32

SH33

SH34

SH35

SH36

SH37

SEC3-66

SH38

SM1

SH40

SH41

SH42

SEC1-3

110

118

120

132

137

140

142

SH43

SH44

SH47

SM3

SH49

SM4

SH50

SH51

SM5

SM6

SM7

SH52

SM8

SH53

SH54

SH55

SH56

SH57

SH58

SG1