Sandwell Local Plan Main Modifications Consultation

Comment

Representation ID: 1694

Received: 26/02/2026

Respondent: Environment Agency

We are concerned that the main modification in retaining the current optional higher standard for Building Regulations of 110 l/p/d for housing is not in line with the Council's evidence base (WCS Phase 2, 2024). This in our view doesn't meet the 'justified' and 'consistent with national policy' tests of soundness, the latter with particular reference to paragraph 162 of the NPPF. We recommend the Council reconsiders and endorses the WCS recommendation of 100 l/p/d, even if Building Regulations are due to change as this would essentially pave the way and bring about water savings sooner.

Support

Representation ID: 1695

Received: 26/02/2026

Respondent: Environment Agency

We support this change, and thank the Council for taking into account our representation.

Comment

Representation ID: 1696

Received: 26/02/2026

Respondent: Environment Agency

We have no objections from the change in wording from 'easement' to 'distance' in relation to culverts in SCC5 6a. However, we would expect the same standards for culverted watercourses as that which is stipulated in part iv of the policy (10 metres for main river or as agreed with the EA) which we're unsure is clear from the wording in part iii.

Object

Representation ID: 1762

Received: 30/03/2026

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

This site is highly contaminated, and we are concerned that with the site's unusual characteristics and history of waste deposits (including the phosphorus waste lagoons) that this may prove costly and technically unfeasible to remediate, potentially leaving the Council with a site that is unable to deliver. We would recommend the Council withdraws the allocation or pauses until further investigation work determines its potential for redevelopment.