50600596 THE LOCAL FLOOD RISK MANAGEMENT STRATEGY STRATEGIC ENVIRONMENTAL ASSESSMENT

OCTOBER, 2015

THE BLACK COUNTRY LOCAL FLOOD RISK MANAGEMENT

STRATEGY THE BLACK COUNTRY LOCAL FLOOD RISK MANAGEMENT STRATEGY The Black Country Local Authorities

Project no: 50600596 Date: October, 2015

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QUALITY MANAGEMENT

ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3

Remarks Draft for Consultation

Date 28/10/2015

Prepared by Kim Bossingham

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Checked by Nic Macmillan

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Authorised by Nic Macmillan

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Project number 50600596

Report number V1

File reference \aaENVIRONMENTALP LANNING\04projects\50 600596 – Black Country SEA\3.SEA

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TABLE OF CONTENTS

ABBREVIATIONS ...... 3

1 INTRODUCTION ...... 4

2 STRATEGIC ENVIRONMENTAL ASSESSMENT ...... 8

3 APPRAISAL OF LFRMS ...... 25

4 NEXT STEPS ...... 33

APPENDICES

APPENDIX A REVIEW OF PLANS, PROGRAMMES AND SUSTAINABILITY OBJECTIVES APPENDIX B BASELINE DATA APPENDIX C SCOPING COMMENTS APPENDIX D LFRMS MEASURES AND ACTIONS APPENDIX E ASSESSMENT OF THE LFRMS

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ABBREVIATIONS AMR Annual Monitoring Report AONB Area of Outstanding Natural Beauty BAP Biodiversity Action Plan CRoW Countryside and Rights of Way Act cSAC candidate Special Areas of Conservation DCLG Department for Communities and Local Government DMBC Dudley Metropolitan Borough Council EA Environment Agency EIA Environmental Impact Assessment FMfSW Flood Map for Surface Water FCERM Flood and Coastal Erosion Risk Management HAPs Habitat Action Plans HLC Historic Landscape Characterisation HRA Habitats Regulations Assessment LAs Local Authorities LFRMS Local Flood Risk Management Strategy LLFAs Local Flood Risk Authorities LNR Local Nature Reserves LSOA Lower Super Output Areas NNR National Nature Reserves NPPF National Planning Policy Framework NTS Non Technical Summary NVZs Nitrate Vulnerable Zones ONS Office of Neighbourhood Statistics PFRA Preliminary Flood Risk Assessment pSPA potential Special Protection Areas RBMP River Basin Management Plan RSDF Regional Sustainable Development Framework SA Sustainability Appraisal SAC Special Areas of Conservation SAPs Species Actions Plan SEA Strategic Environmental Assessment SFRA Strategic Flood Risk Assessment SHLAA The Strategic Housing Land Availability Assessment SINCs Sites of Importance for Nature Conservation SMBC Solihull Metropolitan Borough Council SPA Special Protection Areas SSSIs Sites of Special Scientific Interest SuDS Sustainable Drainage Systems WC Council WCC Wolverhampton City Council WFD Water Framework Directive

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1 INTRODUCTION 1.1 BACKGROUND TO AND PURPOSE OF THIS REPORT

1.1.1 A Local Flood Risk Management Strategy (LFRMS) has been prepared for the Black Country Local Authorities (LA’s). The Black Country LA’s comprise Sandwell Metropolitan Borough Council (SMBC), Dudley Metropolitan Borough Council (DMBC), Walsall Council (WC) and Wolverhampton City Council (WCC).

1.1.2 As part of the production of the Black Country LFRMS, a Strategic Environmental Assessment (SEA) was undertaken. This report provides a summary of the SEA process so far and presents the findings and recommendations of the assessment of the Black Country LFRMS.

1.1.3 This SEA Report provides a summary of the SEA process so far and presents the findings and recommendations of the assessment of the LFRMS. The key aims of this SEA Report are to:

Æ Provide information on the LFRMS and the SEA process; Æ Present the key existing social, economic and environmental conditions within the Black Country, in the context of existing plans, programmes and sustainability objectives, together with relevant baseline information; Æ Identify, describe and evaluate the likely significant effects of the LFRMS; Æ Recommend measures to avoid, reduce or offset any potentially significant adverse effects; and Æ Propose an approach to monitoring that can be used to monitor the identified significant effects. 1.2 BACKGROUND TO AND PURPOSE OF THE BLACK COUNTRY LFRMS

1.2.1 Under the Flood and Water Management Act 2010, the Black Country LA’s have a key role in the management of flood risk and this includes a duty to develop and maintain a local strategy for flood risk management. The purpose of this strategy is to explain how they will manage flood risk from surface water, groundwater and ordinary watercourses, now and in the future. It will provide details of other organisations that are responsible for managing flood risk and what those responsibilities are.

1.2.2 The Act requires LFRMS’s to specify:

Æ The risk management authorities within the authority’s area (in the Black Country, these are the Environment Agency, SMBC, DMBC, WC and WCC (as the Lead Local Flood Authorities (LLFAs) and the Highway Authorities) and Severn Trent Water; Æ The flood and coastal erosion risk management functions that may be exercised by those authorities in relation to the area; Æ The assessment of local flood risk for the purpose of strategy; Æ The objectives for managing the local flood risk (including any objectives included in the authority’s flood risk management plan prepared in accordance with the Flood Risk Regulations 2009); Æ The measures proposed to achieve those objectives; Æ How and when the measures are expected to be implemented; Æ The costs and benefits of those measures, and how they are to be paid for;

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Æ How and when the strategy is to be reviewed; and Æ How the strategy contributes to the achievement of wider environmental objectives.

1.2.3 LLFA’s must consult risk management authorities that may be affected by the strategy as well as the general public about its LFRMS.

1.2.4 The Strategy provides a set of flood risk management objectives and actions that will ensure that these objectives are achieved within the Black Country. It will also help individuals, communities and businesses and understand flood risk and what action they can take to reduce the effects of flooding.

1.2.5 The Objectives for managing flood risk within the Black Country reflect the Government’s strategic objectives (set out in the ‘National Flood and Coastal Erosion Risk Management Strategy for ’, Environment Agency and Defra, 2011) at a local level and are detailed in Section 2.4.9

1.3 BACKGROUND TO AND PURPOSE OF THE SEA

1.3.1 SEA is a systemic process for evaluating the sustainability effects of plans and programmes to ensure that sustainability issues are integrated and assessed at the earliest opportunity in the decision-making process, and that sustainable development is at the heart of the plan-making process. Article 1 of the SEA Directive states that the aim is to:

‘provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development’

1.3.2 SEA became a requirement when the European Directive 2001/42/EC ‘on the assessment of the effects of certain plans and programmes on the environment’ (known as the ‘SEA Directive’) was implemented in Member States in July 2004. The Directive was transposed in England through the Environmental Assessment of Plans and Programmes Regulations, 2004, under which SEA is a mandatory requirement for certain plans and programmes which are likely to give rise to significant environmental impacts. Flood Risk Management Strategies do not clearly fall within the requirements of these regulations.

1.3.3 However, under the Flood and Water Management Act (2010) (‘the Act’), local authorities were given a new role to manage local flood risk in their area. The Act requires the LLFAs, which includes the Black Country LA’s, to produce an LFRMS. These strategies must be consistent with the National Flood and Coastal Erosion Risk Management Strategy. They will set out a vision for the management of flood risk and, although the Act specifies some of the key elements that must be included in the LFRMS, it is intended that they will be locally specific, reflecting key local issues and enabling communities to be more involved in decision-making regarding flood risk management. Guidance on the production of LFRMSs1 refers to the need for them to be subject to SEA, stating that “the local FRM Strategy is likely to require statutory SEA, but this requirement is something the LLFA must consider”.

1.3.4 Given the uncertainty around the need for SEA and the likely delays and costs associated with screening, the Black Country LA’s have decided to take a pragmatic approach and subject their emerging LFRMS to SEA. It is also noted that the guidance recognises that: “LLFAs should take a proportionate approach to applying SEA to local strategies particularly when environmental effects are not evident in the early stages of plan development. As the detail of plans develops, SEA should be reviewed”.

1 Framework to assist the development of the Local Strategy for Flood Risk Management ‘A Living Document’ 2nd Edition, November 2011

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1.3.5 The SEA has been undertaken in accordance with the Department for Communities and Local Government (DCLG) National Planning Practice Guidance (March 2014) on SEA and Sustainability Appraisal (SA). In addition, published Government guidance on SEA (referred to as the Practical Guide) has also been followed2.

1.3.6 The preparation of the LFRMS has been developed iteratively with the SEA process. An overall SEA Scoping Report was prepared in August 2015, which was consulted upon with statutory consultees (Natural England, English Heritage, Historic England and Environment Agency). Following confirmation of the scope of the SEA, an appraisal was undertaken of the LFRMS Objectives, Measures and Actions. This report presents details of the process and the assessment results. It is essential that the LFRMS is read in conjunction with this SEA Report.

1.4 HABITATS REGULATIONS ASSESSMENT

1.4.1 European Council Directive 92/43/EEC on the Conservation of natural habitats and of wild flora and fauna (the ‘Habitats Directive’) requires that any plan or programme likely to have a significant impact upon Natura 2000 site: Special Area of Conservation (SAC), candidate Special Areas of Conservation (cSAC), Sites of Community Importance (SCI), Special Protection Area (SPA), potential Special Protection Area (pSPA) and Ramsar site, which is not directly concerned with the management of the site for nature conservation, must be subject to Appropriate Assessment. The overarching process is referred to as Habitats Regulations Assessment (HRA).

1.4.2 A HRA screening exercise has been undertaken in parallel to the preparation of this SEA to determine whether the Black Country LFRMS (either in isolation and / or in combination with other plans or projects) would generate adverse impacts upon the integrity of Natura 2000 sites, in terms of its conservation objectives and qualifying interests. This process has been documented in a HRA Screening Report that has been submitted to Natural England.

1.4.3 The purpose of the HRA Screening report is it:

Æ Confirm the study area and the European sites that need to be considered; Æ Consider the policy contest within which the work will be undertaken; Æ Confirm the overall methodology; Æ Identify the issues to be considered; and Æ Contribute to an audit trail for HRA related work. 1.5 STRUCTURE OF THIS REPORT

1.5.1 Table 1.1 provides an outline of the contents and structure of this SEA.

Table 1.1 Contents and Structure of this SEA Report

SECTION OF THE SEA OUTLINE CONTENT REPORT Non-Technical Summary of the SEA process and SEA Report in plain English (a legislative Summary (separate requirement). document) Abbreviations Abbreviations used in this report.

2 Office of the Deputy Prime Minister (ODPM) et al. (2005) A Practical Guide to the Strategic Environmental Assessment Directive

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SECTION OF THE SEA OUTLINE CONTENT REPORT 1: Introduction Provides the background to, purpose of, and structure of the LFRMS and the SEA Report. 2: Strategic This section outlines the legal requirements for the SEA. It outlines the key elements Environmental of the SEA process and the approach adopted for appraising the effects of the Assessment LFRMS (including the SEA Framework), together with an overview of the consultation requirements. It identifies the links to other strategies, plans and programmes and sustainability objectives, and describes the baseline characteristics and the predicted future baseline for the topics identified in the SEA Directive. It also presents the main sustainability issues and problems identified. The difficulties in collecting baseline data and limitations of the data are identified. 3: Appraisal of the Outlines the alternative options to the LFRMS that were considered, and presents the LFRMS appraisal of the alternatives. Presents the full appraisal of the LFRMS against the SEA Framework including cumulative effects, including details of recommendations / mitigation measures that could be implemented to improve the performance of the LFRMS. 4: Next Steps and Identifies the next steps in the SEA process, following consultation on the SEA Monitoring Framework Report. Details of how to comment upon the SEA Report are also provided. Appendix A Presents the full analysis of relevant Plans, Programmes and Sustainability Objectives and their relationship / conflicts with the LFRMS. Appendix B Contains the baseline data, a summary of which is presented in Section 2. Appendix C Presents the Scoping Report Consultation outcomes. Appendix D Presents the LFRMS Measures and Actions. Appendix E Assessment of the SEA against the LFRMS Objectives, Measures and Actions.

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2 STRATEGIC ENVIRONMENTAL ASSESSMENT 2.1 INTRODUCTION

2.1.1 SEA is an essential tool for ensuring that the principles of sustainable development are inherent throughout the preparation of the LFRMS and that it complies with the relevant planning guidance. The overarching aim of the process is to contribute to better decision-making and planning. SEA is an iterative process and follows a series of prescribed stages (refer to Table 2.1) in which the elements of the LFRMS have been appraised against Sustainability Objectives (SEA Objectives), to encourage the selection of the most sustainable options and to ultimately improve the sustainability of the development that is brought forward.

2.2 STAGES IN THE SEA PROCESS

2.2.1 The Practical Guide subdivides the SEA process into a series of prescribed stages, through which the elements of the LFRMS have been appraised using a set of Sustainability Objectives. While each stage consists of specific tasks, the intention should be that the process is iterative. Table 2.1 presents the key stages in the SEA process, together with the SEA Directive requirements for each stage. Reference is given to where the requirements and specific tasks have been addressed within this SEA Report. The table also demonstrates how each of the SEA stages is linked to the preparation and development of the LFRMS.

Table 2.1 Stages in the SEA Process and SEA Directive Requirements

SEA STAGE KEY SEA DIRECTIVE REQUIREMENTS RELEVANT SECTION OF APPLICATION TO THE THE SEA REPORT LFRMS

Stage A: Setting the context and objectives, establishing the baseline and decided on the scope

A1: Identifying The environment report should provide Section 2 and Stage A corresponds to other relevant information on: Appendix A. the scoping stage of the policies, plans SEA and the findings of and “the relationship (of the plan or this stage are presented programmes programme) with other relevant plans and in the Scoping Report and programmes” (Annex 1 (a)) that was consulted upon sustainability in 2015. objectives “the environmental protection objectives, established at international (European) During this stage the Community or Member State level, which scope of the SEA for the are relevant to the plan or programme and LFRMS was defined. the way those objectives and any environmental considerations have been taken into account during its preparation” (Annex 1(e))

A2: Collecting The environment report should provide Section 2 and baseline information on: Appendix B information “relevant aspects of the current state of the

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SEA STAGE KEY SEA DIRECTIVE REQUIREMENTS RELEVANT SECTION OF APPLICATION TO THE THE SEA REPORT LFRMS

environment and the likely evolution A3: Identifying thereof without its implementation of the Section 2 sustainability plan or programme’ and, ‘the issues and environmental characteristics of the areas problems likely to be significantly affected” (Annex 1(b), (c))

“any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC” (Annex 1(c))

A4: Developing N/A Section 2 the SEA Framework

A5: Consulting The authorities referred to in Article 6(3) The scope of the on the scope of shall be consulted when deciding on the appraisal is the SEA scope and level of detail of the information presented in Section which must be included in the 2. environmental report. (Article 5.4) A Scoping Report was produced and consulted upon.

Stage B: Developing and Refining Options and Assessing Affects

B1: Testing the The environment report should consider Section 3 and Stage B of the SEA LFRMS “reasonable alternatives taking into Appendix E. process is linked to the objectives account the objectives and the overall production of the against the geographical scope of the plan or LFRMS which includes SEA programme” and give “an outline of the the development of plan Framework reasons for selecting the alternatives dealt options. with” (Article 5.1 and Annex I(h)) There has been a B2: Developing In the environmental report, “the likely considerable degree of the LFRMS significant effects on the environment of interaction between the Options implementing the plan or programme … plan-making and SEA and reasonable alternatives … are [to be] teams during this stage in identified, described and evaluated” (Article the process. This has 5.1) enabled potential adverse B3: Predicting effects of the LFRMS to the effects of be avoided / minimised the LFRMS and potential sustainability benefits maximised. B4: Evaluating the effects of Stage B is the primary the LFRMS assessment stage of the

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SEA STAGE KEY SEA DIRECTIVE REQUIREMENTS RELEVANT SECTION OF APPLICATION TO THE THE SEA REPORT LFRMS

SEA process and is the B5: Annex I (g) states that it should also main output of this report. Considering include “measures envisaged to prevent, ways of reduce and as fully as possible offset any mitigating significant adverse effects on the adverse effects environment of implementing the plan or and programme…” maximising beneficial effects

B6: Proposing The Environmental Report should provide measures to information on a “description of the monitor the measures envisaged concerning significant monitoring” (Annex I (i)) effects of implementing the LFRMS’s

Stage C: Preparing the Strategic Environmental Assessment

C1: Preparing Article 5.1 contains the requirement for an This SEA Report This SEA Report has the SEA environmental report to be produces where represents the been produced in line Report an assessment is required. The required Stage C with the requirements of environmental report “shall include the output. the SEA Directive for information that may reasonably be producing an SEA required taking into account current Report. A Non-Technical knowledge and methods of assessment, Summary is also the contents and level of detail in the plan provided. or programme, its stage in the decision- making process and the extent to which certain matters are more appropriately assessed at different levels in that process in order to avoid duplication…” (Article 5.2). Details of the information to be given in the Environmental Report are provided in Annex 1.

Stage D: Consultation on the Proposed Submission Documents and the SEA Report

D1: Public Article 6 contains the requirements for the Arrangements for The SEA Report and the participation on draft plan or programme and the consultation are LFRMS will be consulted the proposed environmental report to be made available indicated in Section upon in accordance with submission to statutory authorities and the public. They 4. Regulation 27 of the documents should be given an ‘early and effective Town and Country opportunity within time frames to express Planning (Local their opinions’ (Article 6.2). Development) (England) (Amendment) Regulations 2008.

D2: Appraising N/A N/A Following the receipt of significant representations, the SEA

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SEA STAGE KEY SEA DIRECTIVE REQUIREMENTS RELEVANT SECTION OF APPLICATION TO THE THE SEA REPORT LFRMS

changes Report may need to be resulting from updated to reflect representations comments received. The SEA Report will need to be updated to D3: Making accompany the decisions and Publication (Regulation providing 30) version of the information LFRMS. It will be essential for the SEA Report and the LFRMS to remain consistent.

Stage E: Monitoring the significant effects of implementing the LFRMS

E1: Finalising “Member States shall monitor the Monitoring will Monitoring will aims and significant environmental effects of the commence once the commence once the methods for implementation of plans and LFRMS has been LFRMS has been monitoring programmes…. in order, inter alia, to adopted. A draft approved and published. identify at an early stage unforeseen monitoring adverse effects, and to be able to framework is E2: undertake appropriate remedial action” included within Responding to (Article 10.1) Section 5 of this SEA adverse effects Report.

2.2.2 The following sections detail the activities that have been, and are proposed to be, undertaken at each stage of the SEA process. This provides context and background to the SEA to date including its agreed scope, the methodology for the appraisal of the LFRMS, and the technical limitations to the appraisal.

2.3 STAGE A: SETTING THE CONTEXT, ESTABLISHING THE BASELINE AND DECIDING ON THE SCOPE

REVIEW OF PLANS, POLICIES AND SUSTAINABILITY OBJECTIVES

2.3.1 A review of other plans and programmes that may affect the preparation of the LFRMS was undertaken to identify the relationship between them.

2.3.2 This included:

Æ Identification of any external social, environmental or economic objectives, indicators or targets that should be reflected in the SEA process; Æ Identification of any baseline data relevant to the SEA; Æ Identification of any external factors that might influence the preparation of the plan, for example sustainability issues; Æ Identification of any external objectives or aims that would contribute positively to the development of the LFRMS; and Æ Determining whether there are clear potential conflicts or challenges between other identified plans, programmes or sustainability objectives and the emerging LFRMS.

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2.3.3 The review included documents prepared at international, national, regional (sub-regional) and local scale. These documents cover a broad range of issues, not all of which apply directly to the LFRMS. The key principles of relevant plans, programmes and sustainability objectives were taken forward to positively influence the direction of the LFRMS. The initial review was undertaken during the preparation of the SEA Scoping Report. This has since been updated in accordance with consultee feedback on the Scoping Report and checked to ensure it includes any subsequent changes to the plan policy context. The full review is presented in Appendix A.

NATIONAL PLANS AND PROGRAMMES

2.3.4 A review was undertaken of relevant legislation, plans and strategies. The Government establishes the broad guidelines and policies for a variety of different topics in the National Planning Policy Framework (NPPF), which streamlines national planning policy into a consolidated set of priorities to consider when planning for and deciding on new development. The principle of sustainable development is at the heart of the NPPF.

REGIONAL, SUB-REGIONAL AND LOCAL LEVEL PLANS

2.3.5 A suite of plans and strategies have been produced at the regional, sub-regional and local level covering a variety of topics including: biodiversity; population; human health; soil and land quality; minerals and waste; transportation; cultural heritage; landscape and townscape; climate change and flood risk. All of the objectives of these plans as well as some of the challenges they raise need to be taken on board and driven forward as appropriate. However, it must be noted that the overarching goals of these plans and strategies may be outside the remit of the LFRMS which forms only an individual part of a number of different vehicles trying to deliver the regional and county level targets.

KEY RESULTS FROM THE REVIEW

2.3.6 There are many common themes emerging through the review of plans, programmes and sustainability objectives and the list below provides a summary of the main themes and issues identified:

Æ The need to reduce greenhouse gas emissions and increase energy efficiency; Æ The need to promote the use of renewable energy and renewable technologies in appropriate locations; Æ The need for the protection and enhancement of the quality and character of urban and more rural areas; Æ Recognising the need for development to be appropriate to the landscape and townscape setting and context; Æ The need to conserve and enhance biodiversity as an integral part of economic, social and environmental development; Æ The need to protect and enhance the historic environment; Æ Recognising the importance of open spaces, sport and recreation and the contribution that they make to enhancing quality of life; Æ The prudent use of natural resources; Æ The need to promote and protect the water environment including issues such as quality and resource use; Æ The need to adapt to the threat posed by climate change; Æ The need for long-term sustainable patterns of development that provide for the economic and social needs of all populations; Æ Raising levels of health and well-being and promoting greater levels of physical activity; and

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Æ Promoting higher levels of design quality including improvements to energy efficiency. ESTABLISHING THE BASELINE

2.3.7 Characterising the environmental and sustainability baseline, issues and context helps to define the SEA Framework. It involves the following key elements:

Æ Characterising the current state of the environment within the Black Country (including social and economic aspects as well as the natural environment); and Æ Using this information to identify existing problems and opportunities which could be considered in the LFRMS where relevant.

2.3.8 The baseline was characterised through the following methods:

Æ Review of relevant local, sub-regional, national and international plans, policies and sustainability objectives; Æ Data gathering using a series of baseline indicators developed from the SEA Directive topics, and the data available for the Black Country; and Æ Consideration of the scope and contents of the LFRMS.

2.3.9 A detailed description of the baseline characteristics of the Black Country is provided in Appendix B. Obtaining these datasets would help to further increase the knowledge of the areas and therefore the potential impacts of the LFRMS.

2.3.10 The baseline data has been used to identify the key sustainability issues and opportunities within the Black Country, a summary of which is presented in Table 2.2. Although these have been grouped by broad sustainability theme, many are indirectly or directly linked and are therefore closely related. As with the plan policy context, the baseline data has been reviewed and updated following consultation on the SEA Scoping Report.

Table 2.2 Summary of Key Sustainability Issues and Opportunities within the Black Country

SEA TOPIC KEY SUSTAINABILITY ISSUES KEY SUSTAINABILITY OPPORTUNITIES

Biodiversity, There are a number of designated sites for Management of the water environment Flora and nature conservation in the Black Country, should ensure benefits upon biodiversity, Fauna included Sites of Special Scientific Interest notably the area’s protecting species and (SSSI’s), SAC and National Nature Reserves habitats. The LFRMS has a role in ensuring (NNR), together with numerous Local Nature measures that have regard to potential Reserves (LNRs) and locally designated non- impacts on biodiversity flora and fauna. statutory sites. The management of flooding should be Any increase in flood risk may pose a threat to designed for the benefit of wildlife. There is the integrity of habitats and the distribution of a need to understand how flood risk areas species and habitats. correlate with designated areas.

There is an opportunity to improve water quality through control of surface water runoff and point discharges, from both existing and proposed development. Good habitat and riverine structure benefits biodiversity and water quality.

Use of Sustainable Drainage Systems (SuDS) in new development and on integrated green corridors would benefit

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SEA TOPIC KEY SUSTAINABILITY ISSUES KEY SUSTAINABILITY OPPORTUNITIES

biodiversity.

Population In 2001, Wolverhampton had a population of The LFRMS will have a role in reducing and Human 249,470 which grew by 5.17% in 2011. Walsall flood risk. It should help to ensure that the Health grew by 5.88% to a population of 269,323 in Black Country is able to accommodate 2011. Sandwell had a population of 308,063 in planned new development without 2001 and grew by 8.17%. Dudley had a increasing local flood risk. population of 312,925 and grew by 2% by 2011. Population growth is likely to place increasing There may be opportunities to improve the pressure on water resources in terms of water quality of river corridors as green links, supply. enhancing local environmental quality and helping to improve quality of life, especially Inappropriate development within flood plains in the most deprived neighbourhoods. must be avoided. Without a change in practices, higher levels of development are likely to SuDS should be incorporated into all new increase surface water runoff from urbanised developments wherever feasible to reduce areas and potentially contribute further to flood flood risk. risk, irrespective of the impacts of climate change.

Flooding can have a great impact on people’s psychosocial needs and mental health.

Soil and Land Flooding can lead to soil erosion, and in relevant The LFRMS will have a role in helping to Quality locations soil erosion can contribute to higher avoid damage to soils, for example as a phosphate levels in waterbodies. Any adverse result of rapid surface run-off causing soil impacts on its stability or fertility as a result of erosion. the LFRMS must be avoided.

Water Parts of the Black Country are susceptible to The LFRMS could have a role in achieving flood risk. Such areas are likely to increase over Water Framework Directive targets and time as a consequence of climate change. reflect the catchment approach to planning.

There are a range of water features within the Where possible, SuDS should be used to Black Country. It should be ensured that manage and reduce surface run-off rates inappropriate development (any development and further reduce flood risk. constructed against EA advice on flooding or which, by virtue of its location or operation, The LFRMS should promote the amenity would increase the risk of flooding to people or value of surface watercourses for property) is prevented. developing local environmental quality and creating a sense of place. It should also Water resources are likely to be susceptible to promote working with natural processes and increased pressure in the future. the avoidance of opening up culverts.

Water quality can be improved across the area. Control of surface water run off can reduce The Water Framework Directive target of ‘good flood risk as well as improve water quality. surface water status’ requires both the ecological status and the chemical status of a surface water body need to be at least ‘good’.

Climatic Many areas lie within floodplain associated with The LFRMS should seek to reduce the risk Factors the main rivers, e.g. the River Stour and River of flooding to help to ensure that Tame. development is directed outside of identified floodplains and flood paths. It will need to Climate change is anticipated to increase the take account of projected long – term

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SEA TOPIC KEY SUSTAINABILITY ISSUES KEY SUSTAINABILITY OPPORTUNITIES

risk of flooding, especially during the winter. changes in weather patterns and the potential for more frequent and severe More frequent and more sever summer droughts flooding. will place a greater strain on water resources. The LFRMS should promote more efficient and sustainable use of water. For example, it should promote more sustainable methods of surface drainage in order to adapt to more intense rainfall events and higher absolute precipitation totals.

Cultural The Black Country has a range of heritage Heritage assets and their settings should be Heritage assets, some of which may be at risk of flooding. protected and enhanced.

Development puts increasing pressure on Opportunities should be sought to reduce cultural heritage assets, and it is therefore flood risk to specific heritage assets. important that any new infrastructure development considers heritage issues and Consideration should be given to the ensures the protection of assets and the wider impacts of flood alleviation measures on the historic landscape / townscape. historic environment and heritage assets should be protected and conserved. New development / infrastructure has the potential to damage unknown buried Emphasis on preservation in situ should be archaeological remains. ensured. Archaeological preservation in situ should be undertaken if it is beneficial to the archaeology rather than as a matter of convenience.

Landscape Management of surface water can have a It is essential that landscape and townscape and significant impact upon landscape and character and quality is protected and Townscape townscape, particularly in relation to flood enhanced where possible. defences. Careful consideration must be given to the protection of the existing quality and character.

SCOPE OF THE APPRAISAL

2.3.11 The SEA process commenced in 2015 with the preparation of an SEA Scoping Report for the LFRMS. The Scoping Report contained:

Æ Characterisation of the environmental, social and economic baseline within the Black Country; Æ A review of relevant plans, programmes and sustainability objectives that could influence the SEA and the development of the LFRMS; Æ Identification of key sustainability issues and opportunities, together with recommendations for mitigation where required; and Æ The development of the SEA Framework against which the elements of the LFRMS have been assessed.

GEOGRAPHICAL SCOPE OF THE APPRAISAL

2.3.12 The Scoping Report set out the scope and approach to the assessment of the LFRMS. Geographically the scope of this SEA comprises the whole of the Black Country local authority

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areas. However, transboundary effects and cumulative effects of other plans may result in impacts occurring over a wider area, which have also been considered in the SEA.

TOPICS COVERED IN THE APPRAISAL

2.3.13 The SEA comprises the consideration of the environmental, social and economic effects of the LFRMS. The baseline characterisation has therefore reflected the topics set out in the SEA Directive, but also considers relevant additional social and economic topics as recommended in the SEA guidance. Table 2.3 identifies the topics covered, together with their relationship topics listed in Annex 1 of the SEA Directive.

Table 2.3 Topics Covered in the SEA and Relevant SEA Directive Topics

TOPICS COVERED IN THE SEA RELEVANT TOPICS LISTED IN ANNEX I OF THE SEA DIRECTIVE

Biodiversity, Flora and Fauna Biodiversity, Flora and Fauna

Material Assets

Population and Human Health Population and Human Health

Material Assets

Soil and Land Quality Soil

Material Assets

Water Water

Soil

Climatic Factors Climatic Factors

Water

Soil

Material Assets

Cultural Heritage Cultural Heritage

Material Assets

Landscape and Townscape Cultural Heritage

Landscape and Townscape

Material Assets

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2.3.14 Annex I of the SEA Directive also requires an assessment of secondary, cumulative and synergistic effects, the results of which are provided in Section 3. Transboundary effects on neighbouring authorities are considered inherently throughout the assessment.

THE SCOPING CONSULTATION

2.3.15 The Scoping Report was issued for public consultation in August 2015, for a five week consultation period. The aim of this was to obtain comment and feedback upon the scope and level of detail of the SEA.

2.3.16 It was issued to the statutory consultees (the Environment Agency, English Heritage, Historic England and Natural England). Comments are detailed in Appendix C.

THE SEA FRAMEWORK

2.3.17 The SEA Framework was developed at the scoping stage. It underpins the assessment methodology and comprises a series of 7 aspirational objectives (SEA Objectives) against which the LFRMS has been assessed. The SEA Objectives are intended to be overarching and focussed on the key aspects of the LFRMS.

2.3.18 The SEA Objectives have been developed using the review of other relevant plans, programmes and environmental objectives, the baseline data and the key issue and opportunities identified. Each of the SEA Objectives is supported by a series of sub-objectives to add further clarity and to assist the assessment process. These sub-objectives have been considered by the assessors when undertaking the appraisal in order to inform their decision.

2.3.19 The SEA Objectives and associated sub-objectives are presented in Table 2.4.

Table 2.4 The SEA Framework

SEA OBJECTIVE SEA SUB-OBJECTIVE

1 To protect and enhance To reduce flood risk to people and property human health, safety and wellbeing To ensure recreation opportunities are maintained and enhanced

To ensure surface water quality is maintained within statutory standards

2 To protect and enhance To protect and enhance designated sites of nature conservation biodiversity, key habitats and species To protect and enhance wildlife particularly protected and notable species

To protect and enhance habitats and wildlife corridors

To provide opportunities for people to come into contact with flourishing wildlife places and open green spaces, whilst encouraging respect for and raising awareness of the sensitivity of these sites

To ensure that new infrastructure incorporates ecological enhancements

3 To protect and enhance the To protect and enhance heritage assets and their settings, and also historic environment and

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SEA OBJECTIVE SEA SUB-OBJECTIVE

heritage assets historic landscape / townscape value

4 To protect and enhance To protect and enhance the distinctive character and quality of the landscape character and landscape / townscape townscape character and quality To promote sensitive design in new infrastructure

5 To maintain and improve the To improve the quality of groundwater and surface water quality and quantity of the Borough’s surface water To encourage sustainable use of water resources environment and groundwater resource To protect foul drainage, sewage treatment facilities and surface water drainage

6 To limit and adapt to climate To contribute positively to adaptation to climate change change To reduce or manage flooding

To ensure new infrastructure is able to withstand extreme weather events

To encourage the inclusion of flood mitigation measures such as SuDS

To encourage infrastructure that is energy efficient in design and construction

7 To ensure the sustainable To encourage development of brownfield land and outside of sensitive use of natural resources sites where possible

To promote the prudent use of land resources

To protect and enhance soil resources

To ensure that contaminated land will be guarded against

To protect and enhance geodiversity

SEA OBJECTIVE COMPATIBILITY

2.3.20 The seven SEA Objectives have been tested against each other to identify any potential areas of internal compatibility. The results are presented in Table 2.5 and summarised below. The numbers refer to the SEA Objectives detailed in Table 2.4.

2.3.21 The internal compatibility of the SEA Objectives was generally assessed as positive as all the SEA Objectives seek to improve the quality of the environment and human health.

2.3.22 No areas of potential conflict and no areas of uncertainty were identified.

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Table 2.5 Internal Compatibility of the SEA Objectives 1 2 3 3 3 3 4 3 3 3 5 3 3 3 3 6 3 3 3 3 3 7 3 3 3 3 3 3 1 2 3 4 5 6 7

Key

3 - Objectives are compatible;

- - Mutually incompatible;

0 – No clear impact on each other; and

? – Compatibility unknown.

2.4 STAGE B: DEVELOPING AND REFINING OPTIONS AND ASSESSING EFFECTS

ALTERNATIVE OPTIONS ASSESSMENT

2.4.1 Following consultation on the Scoping Report, the alternative options for the Black Country LFRMS were assessed. These options comprise:

Æ Option 1: Do nothing; Æ Option 2: Do minimum – legally required tasks; and Æ Option 3: Do something – enhanced LFRMS including measures over and above the legal requirements.

2.4.2 A high-level review of the options against the SEA Objectives was undertaken in the form of a simple matrix.

2.4.3 One table was produced for all three alternative options which compared the option against the seven SEA Objectives. Positive elements, negative elements and potential mitigation / enhancement of the options were identified and recorded. The notations used in the assessment are presented in Table 2.6.

Table 2.6 Notations used in the SEA of the Options

IMPACT DESCRIPTION SYMBOL

Major Positive Impact The Option contributes to the achievement of the SEA Objective and ++ is likely to deliver enhancements.

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IMPACT DESCRIPTION SYMBOL

Positive Impact The Option contributes partially to the achievement of the SEA + Objective but not completely.

No Impact / Neutral There is no clear relationship between the Option and / or the 0 achievement of the SEA Objective or the relationship is negligible.

Negative Impact The Option partially detracts from the achievement of some elements - of the SEA Objective

Major Negative Impact The Option detracts from the achievement of all elements of the SEA - - Objective.

Uncertain impact More information is required ?

2.4.4 The results of this exercise are presented in 3 along with an overall conclusion and identification of a preferred option.

2.4.5 The consideration of alternatives in SEA typically considers the hierarchy of alternatives:

2.4.6 This approach is most suited to plans that either have policies that will lead to specific development project, or allocate land for development. The LFRMS is a legislative requirement that acts borough-wide and doesn’t address the detailed implementation of measures ‘on the ground’. Rather it addresses strategic priorities. As such, the particular mode or process, or the ‘how it should be done?’ is where there are potential options. As assessment of all the options that were considered during the preparation of the LFRMS and the ‘do nothing’ option is presented in Section 4.

ASSESSING THE LFRMS OBJECTIVES, MEASURES AND ACTIONS

2.4.7 Good practice guidance recommends that the goals of a plan should be assessed against the SEA Objectives, in order to determine whether they accord with broad sustainability principles.

2.4.8 The Black Country LFRMS contains six overarching Local Objectives which reflect the Government’s strategic objectives locally. The Black Country’s Flood Management Authorities developed the following objectives for managing flood risk:

Æ Objective 1: Understanding and communicating flood risk in the Black Country; Æ Objective 2: Managing the likelihood and impacts of flooding;

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Æ Objective 3: Helping the Black Country’s citizens to manage their own risk; Æ Objective 4: Ensuring appropriate development in the Black Country; Æ Objective 5: Improving flood prediction, warning and post flood recovery; and Æ Objective 6: Work in partnership with others to deliver the Local Strategy.

2.4.9 In addition to these objectives there are 30 Measures, supported by a series of actions, listed under each of the Local Objectives. For the purpose of the assessment, the Actions within the Black Country LFRMS have been assessed by the overarching Local Objective heading they fall under within the strategy. Table 2.7. Appendix D present the Measures and Actions associated with the objectives assessed.

2.4.10 Table 2.7 below presents the Objectives and their associated Measures.

Table 2.7 LFRMS Objectives and Measures

OBJECTIVE MEASURE

Æ 1A Develop a Flood Risk Management Plan for the West Cluster; Objective 1 – Understanding and Æ 1B Investigate locally significant incidents of flooding identifying sources and communicating flood remedial actions with partners; risk in the Black Æ 1C Review and update the Preliminary Flood Risk Assessments for the Black Country Country; Æ 1D Develop and continue to maintain a register of flood risk management assets; Æ 1E Engage with local communities to gain information of flood risk issues; Æ 1F Share knowledge and information on local flood risk with the residents of the Black Country; and Æ 1G Ensure latest information is used in assessing local flood risk.

Æ 2A Work with partners to reduce the impacts of flooding by targeting and Objective 2 – prioritising maintenance at high risk locations and assets, enabling an efficient Managing the response to, and recovery from, flooding incidents; likelihood and impacts of flooding Æ 2B Develop flood risk management schemes led by the Black Country authorities, seeking to make best use of available funding; Æ 2C Work with partners to develop flood risk management schemes led by third parties, riparian landowners and stakeholders; Æ 2D Work to ensure ongoing management of existing flood risk and drainage assets; and Æ 2E Work to ensure compliance of all Local Authority owned assets with the Reservoirs Act.

Æ 3A Continue to work with community flood groups and other local stakeholders; Objective 3 – Helping the Black Æ 3B Work with residents to communicate the risks of flooding; Country’s citizens to manage their own Æ 3C Work with residents and landowners to educate them with regards to their risk responsibilities for watercourse management; Æ 3D Encourage local involvement in the development of flood risk management schemes; Æ 3E Encourage residents to share information on flooding incidents; and Æ 3F Share knowledge and information with communities and residents.

Æ 4A Develop a planning process to create clear advice and direction to developers Objective 4 –

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OBJECTIVE MEASURE

Ensuring appropriate on flood risk, drainage and SuDS; development in the Black Country Æ 4B Undertake consenting activities for ordinary watercourses; Æ 4C Promote the use of Sustainable Drainage Systems in new development; and Æ 4D Ensure compliance with Black Country Core Strategy (ENV5 Flood Risk) principals and objectives.

Æ 5A Work with partners to minimise the recovery time for residents and businesses Objective 5 – from flooding events; Improving flood prediction, warning Æ 5B Establish a co-ordinated approach to the provision of temporary flood risk and post flood management measures; recovery Æ 5C Work with partners to improve communications and advice given during flooding events; and Æ 5D Work with partners to understand trigger levels for flooding events and develop local flood warning systems.

Æ 6A Engage in regional networks for sharing of knowledge and best practice; Objective 6 – Work in partnership with Æ 6B Improve the mechanisms of sharing of data and information between partners; others to deliver the local strategy Æ 6C Engage with neighbouring LLFAs to facilitate a catchment based approach; and Æ 6D Continue to engage with flood action groups in the delivery of local flood risk management.

2.4.11 The assessment of the Local Objectives, measures and actions against the SEA Objectives has been undertaken using a matrix based approach. Positive elements, negative elements and potential mitigation / enhancement of the objectives were identified and recorded.

2.4.12 The notation used for the appraisal of alternative options was also used for the appraisal of the preferred option for the LFRMS (refer to Table 2.8 below). When undertaking the assessment, the symbols assigned in the matrix were justified in the commentary box along with any uncertainties. All effects are considered to be long term, indirect and reversible unless stated otherwise. This is due to the nature of the LFRMS, which does not include site specific proposals, rather it sets out a series of actions that could ultimately be withdrawn or amended.

Table 2.8 Notations used in the SEA Assessment

IMPACT DESCRIPTION SYMBOL

Major Positive Impact The Action contributes to the achievement of the SEA Objective and is ++ likely to deliver enhancements.

Positive Impact The Action contributes partially to the achievement of the SEA + Objective but not completely.

No Impact / Neutral There is no clear relationship between the Action and / or the 0 achievement of the SEA Objective or the relationship is negligible.

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IMPACT DESCRIPTION SYMBOL

Negative Impact The Action partially detracts from the achievement of the SEA - Objective.

Major Negative Impact The Action detracts from the achievement of all elements of the SEA - - Objective.

Uncertain impact – It is not possible to determine the nature of the impact as there may ? more information be too many external factors that would influence the appraisal or the required impact may depend heavily upon implementation at the local level.

Positive and Negative The Action has a combination of both positive and negative +/- Impacts contributions to the achievement of the SEA Objective.

2.4.13 This assessment has enabled the identification of the key sustainability strengths and weaknesses, and the potential areas for improvement. Recommendations are made to offset or alleviate any adverse impacts that have been predicted, or to enhance any opportunities that have been identified.

2.4.14 A summary of the assessment of the Black Country LFRMS is provided in Section 3. The complete results of the assessment are presented in Appendix E.

2.4.15 As the objectives of the LFRMS have been assessed as a part of assessing the objectives and the actions, there is no need to undertake a compatibility test between the SEA objectives and the LFRMS objectives.

MITIGATION

2.4.16 Where appropriate, mitigation measures are recommended to avoid, reduce or offset the potential adverse impacts as a result of the Black Country LFRMS. In addition, potential opportunities to benefit and enhance the social, economic and environmental receptors improve are identified.

2.4.17 As the LFRMS has been developed in parallel to the SEA process, mitigation measures have been incorporated on a continual basis.

APPRAISAL OF CUMULATIVE AND SYNERGISTIC EFFECTS

2.4.18 The SEA Directive requires inter alia that cumulative effects should be considered. It stipulates consideration of “the likely significant effects on the environment….” and that “These effects should include secondary, cumulative, synergistic… effects” (Annex I). The Practical Guide sets out the following definitions for these terms:

Æ Secondary or indirect effects comprise effects which do not occur as a direct result of the proposed activities, but as a result of complex casual pathway (which may not be predictable); Æ Cumulative effects arise from a combination of two or more effects, for instance, where several developments each have insignificant effects but together have a significant effect; or where several individual effects of the plan or programme have a combined effect; and Æ Synergistic effects – synergy occurs where the joint effect of two or more processes is greater than the sum of individual effects.

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2.4.19 The potential for cumulative, synergistic or secondary or indirect effects as a result of the LFRMS has been inherently considered within the appraisal, the findings of which are presented in Section 3.

APPRAISAL OF TRANSBOUNDARY EFFECTS

2.4.20 The SEA Directive also requires SEAs to consider the transboundary effects of the plan on other EU member states. It is considered there the plan will not have any significant transboundary effects.

TECHNICAL LIMITATIONS AND UNCERTAINTIES

2.4.21 The LFRMS essentially acts as a guidance document for the future development of the Black Country. There is therefore reliance upon future decision-makers to ensure sustainable development is ensured.

2.5 STAGE C: PREPARATION OF THE SEA REPORT

2.5.1 This SEA Report presents the findings of the assessment to-date including the information collated in Stage A and during scoping, and documents the entire SEA process. The results of the appraisal together with any mitigation measures proposed are recorded in the remaining sections of this document.

2.5.2 The SEA Report also includes a separate Non-Technical Summary (NTS).

2.6 STAGE D: CONSULTATION ON THE BLACK COUNTRY LFRMS AND THE SEA REPORT

2.6.1 This final SEA Report has now been issued for consultation alongside the LFRMS to all key stakeholders (including statutory consultees and the public) for comment. Following the close of the consultation period, the Black Country will review feedback and revise the plan as appropriate. If significant amendments are made to the document, the SEA Report may also need to be updated to reflect the assessment of these amendments to the LFRMS being adopted.

2.7 STAGE E MONITORING THE SIGNIFICANT EFFECTS OF IMPLEMENTING THE LFRMS

2.7.1 The SEA Directive requires that the plan is monitored to test the actual significant effects of implementing the plan against those predicted through the assessment. This process helps to ensure that any undesirable environmental effects are identified and remedial action is implemented accordingly.

2.7.2 The approach to monitoring is presented in Section 4.

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3 APPRAISAL OF LFRMS 3.1 INTRODUCTION

3.1.1 This section outlines the results of the SEA appraisal of the Black Country LFRMS including details of recommendations / mitigation measures (where appropriate) that could be implemented to improve the performance of the strategy.

3.2 ASSESSMENT OF THE ALTERNATIVE OPTIONS

3.2.1 A requirement of the SEA is to consider “reasonable alternatives taking into account the objective and geographical scope of the plan or programme” and to “give an outline of the reasons for selecting the alternatives dealt with”.

3.2.2 Three alternative options have been identified for review:

Æ Option 1: Do nothing; Æ Option 2: Do minimum - legally required tasks; and Æ Option 3: Do something – do the enhanced version as presented in the Strategy.

3.2.3 The results of the SEA appraisal of the Black Country LFRMS alternative options are presented in Table 3.1.

Table 3.1 Assessment of Reasonable Alternatives

SEA OBJECTIVES THE BLACK COUNTRY LFRMS ALTERNATIVE OPTIONS

OPTION 1: DO NOTHING OPTION 2: DO MINIMUM – OPTION 3: DO SOMETHING – DO LEGALLY REQUIRED TASKS THE ENHANCED VERSION AS PRESENTED IN THE STRATEGY

1 To protect and Without the LFRMS in Although this option This option is likely to enhance human place, adverse effects includes and therefore a lead to beneficial effects health, safety upon surface water coordinated approach to on surface water quality and wellbeing quality may occur, flood management, it and transport / access which could generate would not include the problems associated access and transport Action Plan. Therefore, with flooding as the problems. This could this option, as option 1, LFRMS and Action Plan be due to flood may lead to adverse would provide a prediction and warning effects on surface water coordinated approach to

- - taking longer without a - quality which could lead + flood prediction, warning strategy in place. In to transport and access and recovery. Residents addition, recreation may issues as flood would also be made also be affected if areas prediction and warning better prepared and such as playing fields would take longer aware of how to protect were flooded. Adverse without an Action Plan themselves / their effects would arise over in place. properties from flooding. the medium to long term.

2 To protect and 0 It is unlikely that the ‘Do + A LFRMS that meets + Preparing an LFRMS enhance nothing’ option would current legislation would and Action Plan for the

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SEA OBJECTIVES THE BLACK COUNTRY LFRMS ALTERNATIVE OPTIONS

OPTION 1: DO NOTHING OPTION 2: DO MINIMUM – OPTION 3: DO SOMETHING – DO LEGALLY REQUIRED TASKS THE ENHANCED VERSION AS PRESENTED IN THE STRATEGY

biodiversity, key lead to any significant have the potential to Black Country has the habitats and effects on biodiversity offer benefits to potential to offer benefits species resources. biodiversity through to biodiversity resources habitat protection and through habitat enhancement. protection and enhancements.

3 To protect and With no LFRMS, the Similarly to Option 1, Preparing the LFRMS enhance the heritage assets within without an Action Plan, and Action Plan for the historic the Black Country are the LFRMS would not Black Country has the environment and more likely to be offer benefits to heritage potential to offer benefits heritage assets damaged through assets, to the historic flooding. There would environment and be no coordinated heritage assets. Better approach to managing management of flood flood risk and improving prediction / warning and

- - flood risk warning / - + recovery may also offer prediction. In addition, benefits to the Black inappropriate Country’s important development would not heritage features over be guarded against. the long-term. Effects have therefore been assessed as major negative over the medium to long-term.

4 To protect and It is unlikely that the ‘Do It is unlikely that this Landscape / townscape enhance nothing’ option would option would lead to any character and quality landscape and lead to any significant significant effects on could potentially benefit townscape effects on landscape / landscape / townscape from a LFRMS and character and townscape character or character or quality. Action Plan potentially quality 0 quality. 0 + committing to the protection and enhancement of assets such as landscape and townscape character and quality.

5 To maintain Not preparing an Effects would be similar The preparation of an and improve the LFRMS and Action Plan to the ‘Do nothing’ LFRMS and Action Plan quality and has the potential to lead option. Without the would provide quantity of the to adverse effects on Action Plan in place to, coordinated approach to Borough’s surface water and post flood recovery may support post flood surface water groundwater resource take longer and recovery and guard environment and - - and potentially - inappropriate + against inappropriate groundwater exacerbate current flood development may not development, which resource risk. Post flood recovery be guarded against. would offer benefits to may take longer without surface water and an LFRMS and Action groundwater. Plan in place and inappropriate development would not

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SEA OBJECTIVES THE BLACK COUNTRY LFRMS ALTERNATIVE OPTIONS

OPTION 1: DO NOTHING OPTION 2: DO MINIMUM – OPTION 3: DO SOMETHING – DO LEGALLY REQUIRED TASKS THE ENHANCED VERSION AS PRESENTED IN THE STRATEGY

be guarded against. Effects are therefore predicted as major negative over the medium to long term.

6 To limit and It is unlikely that the ‘Do It is unlikely that this The development of the adapt to climate nothing’ option would option would lead to any LFRMS and Action Plan change lead to any significant significant effects on is likely to lead to effects on climate climate change. beneficial effects on change issues. However, there would climate change issues in However, without a be a more co-ordinated the long-term. This is - Strategy and Action 0 approach associated + because there would be Plan in place, the Black with current activities a more co-ordinated Country may not be undertaken in the Black approach with respect to prepared to future flood Country that reduces predicting future flood events. flood risk. events, reducing flood risk and managing flood recovery efficiently.

7 To ensure the It is unlikely that the ‘Do It is unlikely that this The preparation of an sustainable use nothing’ option would option would lead to any LFRMS and Action Plan of natural lead to any significant significant effects upon would provide resources effects upon soil quality soil quality / resources coordinated approach to / resources and and ensuring the support post flood 0 ensuring the 0 sustainable use of + recovery and guard sustainable use of natural resources. against inappropriate natural resources. development, which could offer benefits to soil quality and resources.

Uncertainties in No uncertainties were recorded during the alternative options assessment. the Assessment

Overall The do nothing scenario would see none of the benefits of the proposed LFRMS as set out Conclusion and in Section 3 of this report. Given that flood risk in the Black Country presents a risk to Preferred Option people and property, proactive steps need to be taken to address flood risk in the borough. As such, the do nothing scenario is considered significantly less desirable in principal. In addition, the LFRMS is required to be prepared under the Flood Water Management Act 2012 and to not prepare the LFRMS would be in breach of this legislation.

The preferred option for the Black Country LFRMS would be Option 3. This Option would ensure environmental protection / enhancement along with a co-ordinated approach at the county level to flood risk.

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3.3 ASSESSMENT OF THE LFRMS PREFERRED OPTION THE LOCAL OBJECTIVES

3.3.1 As previously stated, the Black Country LFRMS contains six overarching Local Objectives which reflect the Government’s strategic objectives locally, as follows:

Æ Objective 1 – Understanding and communicating flood risk in the Black Country; Æ Objective 2 – Managing the likelihood and impacts of flooding; Æ Objective 3 – Helping the Black Country’s citizens to manage their own risk; Æ Objective 4 – Ensuring appropriate development in the Black Country; Æ Objective 5 – Improving flood prediction, warning and post flood recovery; and Æ Objective 6 – Work in partnership with others to deliver the Local Strategy.

3.3.2 These objectives and their associated measures and actions have been assessed against the SEA objectives. Table 3.2 below presents a brief summary of the outcomes of this assessment. The detailed assessment matrices are presented in Appendix E.

Table 3.2 Appraisal Summary of the LFRMS

SEA OBJECTIVES LOCAL OBJECTIVES

OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6

1 To protect and enhance human health safety and ++ ++ + + ++ 0 wellbeing

2 To protect and enhance biodiversity, key habitats 0 + 0 + 0 0 and species

3 To protect and enhance the historic environment 0 + 0 + + 0 and heritage assets

4 To protect and enhance landscape and townscape 0 + 0 + 0 0 character and quality

5 To maintain and improve the quality and quantity of the Borough’s surface 0 ++ + ++ + 0 water environment and groundwater resource

6 To limit and adapt to

climate change + + + ++ + 0

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SEA OBJECTIVES LOCAL OBJECTIVES

OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6

7 To ensure the sustainable

use of natural resources 0 0 0 + 0 0

Key

Major Positive Impact ++ Positive Impact + No Impact / Neutral 0 Negative Impact - Major Negative Impact - - Uncertain impact – more information required ?

DISCUSSION OF ASSESSMENT FINDINGS

3.3.3 Each of the Local Objectives and associated measures and actions were assessed against the SEA Objectives in an assessment matrix to determine potential sustainability effects and to identify any potential areas where new Local Objectives need to be established or the existing ones clarified.

OBJECTIVE 1: UNDERSTANDING AND COMMUNICATING FLOOD RISK IN THE BLACK COUNTRY

3.3.4 The measures and actions associated with this objective seek to improve the awareness and understanding of flood risk in the Black Country.

3.3.5 A key action for this objective is to engage with key members of the community to gain information on flood risk issues and to prepare such plans as the PFRA and LFRMS. A better understanding of flood risk would prepare all for future flooding risks with climate change, and ensure residents are better informed of potential events which may benefit local wellbeing and health. In addition, there is an action to develop the Flood Risk Management Plan for the Cluster.

OBJECTIVE 2: MANAGING THE LIKELIHOOD AND IMPACTS OF FLOODING

3.3.6 Key actions for this objective include the production of the PFRA, LFRMS, flood mitigation schemes, SuDS, Pre Flood Action Plan and on-site and off-site reservoir safety plans. Such actions and regular maintenance will control activates on watercourses that may result in adverse effects upon human health, climate change, biodiversity, the historic environment and heritage assets, landscape and townscape and the quality of the Borough’s surface water environment and groundwater resources, and therefore the assessment identified positive benefits against these SEA Objectives. All of these assets can be adversely affected by flooding, such as through damage to buildings are a direct risk to life. As such, actions to minimise these risks will have a beneficial effect.

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OBJECTIVE 3: HELPING THE BLACK COUNTRY’S CITIZENS TO MANAGE THEIR OWN RISK

3.3.7 Many neutral scores were recorded against the SEA Objectives as the measures and actions simply seek to help residents to manage flood risk incident reporting, flood warnings and advice. Therefore the measures and actions would not have any significant effects on biodiversity resources, heritage resources, surface water / ground water resources, landscape and townscape character or soils.

3.3.8 The actions that support this objective relate to engaging with key members of the community to gain information on flood risk issues and preparing such plans as PFRA, LFRMS and providing information about how citizens can minimise flood risk and protect themselves during flooding will positively meet this objective. As such the key benefit of the actions under this objective is in relation to protecting human health and climate change, as it will allow members of the local community to make informed decisions on how best to protect themselves from flooding.

OBJECTIVE 4: ENSURING APPROPRIATE DEVELOPMENT IN THE BLACK COUNTRY

3.3.9 Many beneficial effects have been recorded against the SEA Objectives as a result of implementing the measures and actions. The development of a consenting and approval process for work on watercourses, together with ensuring compliance with the Core Strategy, would indirectly ensure the protection of biodiversity resources, heritage assets, landscape / townscape, water quality and soil quality. Furthermore, encouraging appropriate development that does not increase flood risk and that promotes SuDS would reduce the risk of pollution to surface and groundwater resources from new development. This would protect current WFD status of local watercourses.

3.3.10 The actions which meet this objective are inclusive of an FRA and indicative flood risk maps, which area a requirement for new developments. By developments complying with the Local Plan’s principles and objectives, human health will have a positive impact. This objective is also important in tackling climate change as FRAs and indicative flood risk maps take into account climate change and are a key aspect when new development is cited.

3.3.11 Climate change and increased flood risk would be guarded against through ensuring Local Planning Authorities encourage new development that does not increase flood risk.

OBJECTIVE 5: IMPROVING FLOOD PREDICTION, WARNING AND POST FLOOD RECOVERY

3.3.12 Key actions to meet this objective are encouraging the public to sign up to the Floodline Warnings Direct service, keeping records of flooding events and developing a programme of flood mitigation schemes and initiatives will have a positive effect on human health and better prepare residents against future flooding events as a result of climate change. In addition, with better warnings in place, more time will be given to put measures in place, such as sandbags to protect heritage assets and landscape / townscape character and quality. Such measures may also reduce the risk of pollution to surface and groundwater resources following a flood.

OBJECTIVE 6: WORK IN PARTNERSHIP WITH OTHERS TO DELIVER THE LOCAL STRATEGY

3.3.13 Measures set out in the LFRMS around working in partnership with others focus on ensuring that the other direct and indirect actions identified in the LFRMS are realised. Whilst this is necessary and beneficial aspect of the plan, to attribute significant effects to it would be to risk double counting the benefits of the direct and indirect actions it seeks to deliver as already identified in the matrices for Objectives 1 – 5.

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3.4 RECOMMENDATIONS

3.4.1 The following recommendations have been made:

Æ The role of climate change adaptation could be given greater emphasis in the LFRMS; Æ The LFRMS could emphasise the need to consider environmental enhancements as a part of the management of flood risk infrastructure; Æ Need to highlight that other organisations should also consider the potential to contribute to wider sustainability objectives in fulfilling their responsibilities; Æ It should be ensured that new development does not adversely affect the current WFD status of local watercourses; and Æ More emphasis could be placed upon the need to protect and where possible enhance biodiversity, heritage assets and landscape / townscape character and quality. 3.5 APPRAISAL OF SECONDARY, CUMULATIVE AND SYNERGISTIC EFFECTS

3.5.1 Appendix 8 of the Practical Guide to the SEA Directive provides guidance on the assessment of such effects and regard has been had to this in undertaking the work. The work is reported separately for transparency but consideration has been given to the potential for such effects throughout the assessment. All of the effects associated with the LFRMS are considered to be indirect (or secondary) because of the nature of the actions.

3.5.2 The Practical Guide to the SEA Directive defines the three terms as follows:

Secondary effects or indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of a complex pathway. Examples of secondary effects are a development that changes a water table and thus effects the ecology of a nearby wetland; and construction of one project that facilitates or attracts other developments.

Cumulative effects arise, for instance, where several developments each have insignificant effects but together have a significant effect; or where several individual effects of the plan (e.g. noise, dust and visual) have a combined effect.

Synergistic effects interact to produce a total effect greater than the sum of the individual effects. Synergistic effects often happen as habitats, resources or human communities get close to capacity. For instance a wildlife habitat can become progressively fragmented with limited effects on a particular species until the last fragmentation makes the areas too small to support the species at all.

3.5.3 The potential for cumulative and synergistic effects is considered in Table 3.3:

Table 3.3 Cumulative and Synergistic Effects of the Black Country LFRMS

SEA OBJECTIVE POTENTIAL FOR CUMULATIVE / SYNERGISTIC EFFECT

1 To protect and enhance human health, Reducing flood risk and improving the ability of communities to safety and wellbeing respond to future events could have cumulative positive effects in relation to this objective.

2 To protect and enhance biodiversity, key It is expected that the management measures would have a habitats and species cumulative positive effect on biodiversity through the creation and enhancement of habitats associated with schemes to manage flood risk, taking into account the safeguards present

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SEA OBJECTIVE POTENTIAL FOR CUMULATIVE / SYNERGISTIC EFFECT

at the project stage.

3 To protect and enhance the historic A number of positive effects have been identified for this environment and heritage assets objective and there is the potential for these to act cumulatively.

4 To protect and enhance landscape and Measures could have a cumulative positive effect on the townscape character and quality landscape and urban areas, for example through the creation of ponds.

5 To maintain and improve the quality and There is the potential for cumulative benefits if a number of quantity of the Borough’s surface water measures combine to reduce or prevent, for example, pollution environment and groundwater resources to a watercourse.

6 To limit and adapt to climate change Primarily through improving the Black Country’s ability to deal with increased rainfall and in turn flooding events predicted to occur as a result of climate change, the management measures are expected to act cumulatively to achieve this objective.

7 To ensure the sustainable use of natural No significant effects have been identified for this objective and resources as such there is not expected to be a cumulative effect.

3.6 CONCLUSIONS

3.6.1 The assessment of the LFRMS has not identified any instances where potential significant negative effects are anticipated. The main positive effects identified were associated with flood risk, water quality and the protection of material assets.

3.6.2 The LFRMS operates at a strategic level, with the potential for different outcomes depending on how the measures and actions are implemented on the ground. Where measures and actions would be expected to lead to development, the development itself would be subject to technical assessments that will require planning permission, and if necessary Environmental Impact Assessment (EIA) and screening for Appropriate Assessment.

3.6.3 Due to the early assessment work undertaken for the LFRMS, the LFRMS team were able to take on board and action the key sustainability messages early on in the development of the LFRMS. As such there are not many outstanding recommendations from the SEA. The key recommendations from the assessment are:

Æ The role of climate change adaptation could be given greater emphasis in the LFRMS; Æ The LFRMS could emphasise the need to consider environmental enhancements as a part of the management of flood risk infrastructure; Æ Need to highlight that other organisations should also consider the potential to contribute to wider sustainability objectives in fulfilling their responsibilities; Æ It should be ensured that new development does not adversely affect the current WFD status of local watercourses; and

3.6.4 More emphasis could be placed upon the need to protect and where possible enhance biodiversity, heritage assets and landscape / townscape character and quality.

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4 NEXT STEPS 4.1 INTRODUCTION

4.1.1 This section discusses monitoring and next steps.

4.2 MONITORING

4.2.1 The SEA Directive requires monitoring to identify unforeseen adverse effects and to enable appropriate remedial action to be taken (Article 10.1). The factors to be monitored include:

Æ Biodiversity; Æ Population; Æ Human Health; Æ Fauna; Æ Flora; Æ Soil; Æ Water; Æ Climatic factors; Æ Material Assets; Æ Cultural Heritage; and Æ Landscape and Townscape.

4.2.2 The LFRMS is closely related to the Local Plan and there may be potential to co-ordinate monitoring requirements between these documents.

4.2.3 It is proposed that the review should be undertaken of the LFRMS in 2017. This will follow the review of the National Strategy in 2016, coinciding with the review of the Black Country Preliminary Flood Risk Assessment required under the Flood Risk Regulations and follow a review of the River Basin Management Plan. This review will provide the opportunity to monitor the outcomes of the SEA.

4.3 POST-CONSULTATION ISSUES

4.3.1 These matters will be discussed in the Post-Adoption Statement that is produced at the end of the SEA process.

4.3.2 This Draft SEA Report will be consulted on and a final version of the report produced in light of comments on the draft and any further changes to the LFRMS that have a bearing on the findings of the SEA.

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4.4 HOW TO COMMENT

Please send comments to:

Dudley Council [email protected] Roger Morgan Dudley Metropolitan Borough Council Directorate of the Urban Environment Environmental Management Civil Engineering Group Lister Road Depot Lister Road Dudley MBC West Midlands DY2 8JW Telephone 01384 814431

Wolverhampton City Council [email protected] Keith Rogers Wolverhampton City Council Highway Assets Culwell Street Depot Culwell Street Wolverhampton WV10 0JN

Walsall Council [email protected] John Roseblade Walsall Council Engineering and Transportation Economy & Environment Civic Centre Walsall West Midlands WS1 1DG Telephone 01922 654391

Sandwell Council [email protected] Nigel Wilkins Sandwell Metropolitan Borough Council Council House Freeth Street Oldbury West Midlands B69 3DE

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4.4.1 Telephone 0845 352 1878If you would like to discuss any aspects of this report before responding, please contact Nic Macmillan, Principal Consultant, WSP | Parsons Brinckerhoff on 077 8538 8256.

The Black Country Local Flood Risk Management Strategy WSP | Parsons Brinckerhoff The Black Country Local Authorities Project No 50600596 October, 2015

Appendix A

REVIEW OF PLANS, PROGRAMMES AND SUSTAINABILITY OBJECTIVES

SUMMARY OF NATIONAL PLANS

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA Planning Act (2008) The Act created amendments to the functioning of the planning system, following There are no specific targets or The preparation of the The SEA should consider recommendations from the Barker Review first proposed in the 2007 White Paper: Planning indicators of relevance. strategy should consider the means by which the for a Sustainable Future. The two principal changes are: the recommended measures in the Act may actions in this document. enable the plan to Æ The establishment of an Infrastructure Planning Commission to make decisions on contribute towards nationally significant infrastructure projects; and sustainable development Æ Creation of the Community Infrastructure Levy, a charge to be collected from developers by local authorities for the provision of local and sub-regional infrastructure.

The Natural Environment and Rural Communities Act (2006) The act created Natural England and the Commission for Rural Communities and, amongst There are no specific targets or The Act places a duty on The SEA Framework other measures, it extended the biodiversity duty set out in the Countryside and Rights of indicators of relevance. flood authorities to have should include objectives Way (CRoW) Act to public bodies and statutory undertakers to ensure due regard to the regard, so far as is relating to the protection conservation of biodiversity. consistent with the proper and enhancement of The Duty is set out in Section 40 of the Act, and states that every public authority must, in exercise of their biodiversity resources. exercising its functions, have regard, so far as is consistent with the proper exercise of functions, to conserve Potential conflicts could those functions, to the purpose of conserving biodiversity. The Duty applies to all local biodiversity, including arise if the Black Country authorities, community, and town councils, police, fire and health authorities and restoring or enhancing LA’s fail in their duty to utility companies. species populations or have, so far as is The aim of the biodiversity duty is to raise the profile of biodiversity in England and Wales, habitats. consistent with the proper so that the conservation of biodiversity becomes properly embedded in all relevant policies exercise of their functions, and decisions made by public authorities. to conserve biodiversity, Fifty-six habitats of principal importance are included on the S41 list, and 943 species. including restoring or These were identified as requiring action in the UK Biodiversity Action Plan (UK BAP) and enhancing species continue to be regarded as conservation priorities in the subsequent UK Post-2010 populations or habitats. Biodiversity Framework. In accordance with Section 41(4) the Secretary of State will, in consultation with Natural England, keep this list under review and will publish a revised list if necessary. The S41 list is used to guide decision-makers such as public bodies, including local and regional authorities, in implementing their duty under section 40 of the Natural Environment and Rural Communities Act 2006, to have regard to the conservation of biodiversity in England, when carrying out their normal functions. Water Environment (Water Framework Directive) (England and Wales) Regulations (2003) The purpose of this Directive is to establish a framework for the protection of inland surface Objectives for surface waters: Water quality and The SEA Framework

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA waters, transitional waters, coastal waters and groundwater which: Æ Achievement of good quantity is linked to the should include objectives (a) prevents further deterioration and protects and enhances the status of aquatic ecological status and good LFRMS as flooding that consider effects upon ecosystems and, with regard to their water needs, terrestrial ecosystems and wetlands surface water chemical events can lead to water water quality and resource. directly depending on the aquatic ecosystems status by 2015 pollution and changes in (b) promotes sustainable water use based on a long-term protection of available water water levels. resources Æ Achievement of good ecological potential and (c) aims at enhanced protection and improvement of the aquatic environment, inter alia, good surface water through specific measures for the progressive reduction of discharges, emissions and chemical status for heavily losses of priority substances and the cessation or phasing-out of discharges, emissions modified water bodies and and losses of the priority hazardous substances artificial water bodies (d) ensures the progressive reduction of pollution of groundwater and prevents its further pollution Æ Prevention of deterioration (e) contributes to mitigating the effects of floods and droughts from one status class to another The WFD is designed to improve and integrate the way water bodies are managed throughout Europe. Member States must aim to reach good chemical and ecological Æ Achievement of water- status in inland and coastal waters by 2015 subject to certain limited exceptions. related objectives and The WFD establishes a strategic framework for managing the water environment. It standards for protected requires a management plan for each river basin to be developed every 6 years. The plans areas are based on a detailed analysis of the impacts of human activity on the water environment Objectives for groundwater: and incorporate a programme of measures to improve water bodies where required. In December 2009 the Environment Agency (the “competent authority” responsible for Æ Achievement of good implementation of the WFD) published the first set of River Basin Management Plans for groundwater quantitative England and Wales. and chemical status by 2015 Æ Prevention of deterioration from one status class to another Æ Reversal of any significant and sustained upward trends in pollutant concentrations and prevent or limit input of pollutants to groundwater Æ Achievement of water related objectives and standards for protected

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA areas

Future Water: The Government’s Water Strategy for England (2008) Defra’s vision for the state of the water environment in 2030 is for: The Strategy contains few The LFRMS should help The SEA Framework quantitative targets. It sets out to support the aims of this should contain objectives Æ an improved quality of the water environment and the ecology which it supports, and broad ambitions for Strategy through related to water resources, continued high levels of drinking water quality; improvements in the areas of requiring high levels of flooding and climate Æ sustainably managed risks from flooding and coastal erosion, with greater water demand, supply, quality, protection for the water change. understanding and more effective management of surface water; surface water drainage, environment. flooding, greenhouse gas Æ sustainable use of water resources, and implemented fair, affordable and cost emissions, water charging and reflective water charges; the regulatory framework. Æ reduced greenhouse gas emissions; and One headline target is to reduce per capita consumption Æ an embedded continuous adaptation to climate change and other pressures across the of water to an average of 130 water industry and water users. litres per person per day by 2030, or possibly even 120 litres per person per day depending on new technological developments and innovation. Water for People and the Environment: A Strategy for England and Wales (2009) This is a strategy produced by the Environment Agency (EA) and applies to both England There are no specific targets or The strategy should The SEA Framework and Wales. It forms the EA’s strategy for water resource management for the next 25 indicators of relevance. consider how the water should include objectives years. environment can be that consider effects upon The focus of the strategy is understanding the present state of water resources and protected and enhanced, water quality and resource, planning for the management of water resources to prevent long-term environmental and include policies that and that promote the damage and degradation. The strategy highlights where water abstractions are promote the sustainable protection of the water unsustainable and where further water is needed. The issue of climate change and its use of water resources. environment. impact upon our water resources is also considered. 30 action points are identified to deliver the strategy, which include developing leakage control, encouraging good practice when using water and promoting the value of water. Flood and Water Management Act (2010) The Act will provide better, more comprehensive management of coastal erosion and flood Requires Lead Local Flood The strategy should The SEA Framework risk for people, homes and businesses. It also contains financial provisions related to the Authorities to produce a consider flood risk issues. should include objectives, water industry. LFRMS. It should seek to avoid targets and indicators that siting new development address flooding risk and

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA The Act will give the EA an overview of all flood and coastal erosion risk management and in floodplain and ensure the need to manage runoff unitary and county councils the lead in managing the risk of local floods. It will also enable the sustainable use of effectively. better management of water resources and quality, and will help to manage and respond to water resources. severe weather events such as flood and drought. Under this strategic role, the duties and powers of the Environment Agency, the lead Competent Authority under the EU Floods Directive, includes: Æ Setting out of a national strategy for flood and coastal erosion risk management; Æ Developing the methods, framework and tools to understand and manage flooding from all sources; Æ Supporting the roles of local authorities and others in flood and coastal erosion risk management (FCERM), by providing them with information and guidance; Æ Assessing flood and coastal erosion risk on a national basis and determine spending priorities to manage those risks as well as allocating relevant funding in accordance with the priorities; Æ Consenting and enforcement powers in relation to any works or activities by any person which may directly impact on flooding from main rivers and the sea; and Æ Responsibility for flood warning for all forms of flood risk.

National Planning Policy Framework (March 2012) The NPPF sets out the Government’s economic, environmental and social planning There are no specific targets or The strategy should The SEA Framework policies for England. Taken together, these policies articulate the Government’s vision of indicators of relevance. adhere to the principles should include objectives sustainable development, which should be interpreted and applied locally to meet local of the Planning Policy relating to economic, aspirations. Framework. environmental and social The NPPF is based around the presumption in favour of sustainable development. issues. Sustainable development, for the planning system, is defined as: Æ Planning for prosperity – using the planning system to build a strong, responsive and competitive economy; Æ Planning for people – using the planning system to promote strong, vibrant and healthy communities; and Æ Planning for places – using the planning system to protect and enhance the natural, built and historic environment. The NPPF contains several changes from the suite of policy guidance notes and statements that it is replacing:

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA Æ Replacing the local development framework with the local plan, that contain both policies and site allocations; Æ Discouraging the long term protection of employment land or floor space; Æ Removing the sequential test for offices; Æ Permission should be granted for housing where a 5 year supply (plus 20% contingency) is not in place – though this would be still subject to other policies and parts of the NPPF; and Æ Local communities will be able to designate local green space.

The Natural Environment White Paper (The Natural Choice: Securing the Value of Nature) (2011) The first Government White Paper dealing with the natural environment in over 20 years, There are no specific targets or The LFRMS should take The SEA Framework marking the most significant shift in environmental policy for a generation “by 2060, our indicators of relevance. into account the elements should include objectives essential natural assets will be contributing fully to robust and resilient ecosystems, of this framework and be relating to the protection providing a wide range of goods and services so that increasing numbers of people enjoy used to manage any and enhancement of the benefits from a healthier natural environment." increased risk of flooding. natural environment, The Natural Environment White Paper sets out how together we can start to tackle the particularly as there is challenges ahead, for example, by: potential for conflicts if the LFRMS impacts on green Æ Giving local people more involvement in the natural environment and helping them to space provision and/or realise the benefits; biodiversity. Æ Helping to develop a thriving green economy, developing payments for ecosystem services and addressing barriers to using green infrastructure to promote sustainable growth; Æ Helping to deliver the Government’s ambitions for resilient ecological networks, biodiversity recovery, sustainable agriculture, healthy woods and forests, an improved water environment and a better protected marine environment; Æ Taking action to address the risks and consequences of climate change and other pressures; Æ Delivering conservation at the landscape scale, including through Nature Improvement Areas; and Æ Further improving how we monitor progress and provide access to environmental information.

Wildlife and Countryside Act 1981

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA Introduced in October 1981, The Countryside and Wildlife Act is An Act to repeal and re- There are no specific targets or The strategy should The SEA framework should enact with amendments the Protection of Birds Acts 1954 to 1967 and the Conservation of indicators of relevance. adhere to the principles adhere to the principle Wild Creatures and Wild Plants Act 1975; to prohibit certain methods of killing or taking wild of the Guidance in terms objectives of the Act. animals; to amend the law relating to protection of certain mammals; to restrict the of protecting birds, wild introduction of certain animals and plants; to amend the Endangered Species (Import and animals and plant life. Export) Act 1976; to amend the law relating to nature conservation, the countryside and National Parks and to make provision with respect to the Countryside Commission; to amend the law relating to public rights of way; and for connected purposes. Biodiversity 2020: A strategy for England’s Wildlife This strategy will guide our conservation efforts in England over the next decade, including Relevant Objectives are as The LFRMS should follow The SEA Framework setting ambitions to halt the overall loss of England’s biodiversity by 2020. In the longer follows : the priority action should adhere to the term, the ambition is to move progressively from a position of net biodiversity loss to net principles outlined in the principles of the Guidance Æ Halt bio-diversity loss; gain. We need to build a wider network of places across England which enables wildlife to document. to improve and conserve thrive and natural processes to be sustained, alongside other land uses such as farming. Æ Support healthy, well- existing wildlife. This will help nature to better withstand future pressures such as climate change – and set functioning eco-systems; our continuing conservation efforts for particular important species into a wider context. Æ Establish coherent ecological networks; and Æ Create better places for the benefit of nature and people.

Flooding and Historic Buildings (2010) This English Heritage advisory note provides guidance for home-owners, owners of small There are no specific targets or The LFRMS should take The SEA Framework businesses and others involved with managing historic buildings on ways to establish flood indicators of relevance. into account the should include objectives risk and prepare for possible flooding by installing protection measures. It also provisions of this relating to the protection recommends actions to be taken during and after a flood so as to minimise damage and document. and enhancement of the risks. historic environment. Although most historic structures are inherently durable and are relatively resistant to flooding compared with much modern construction, they are still vulnerable. Many of these buildings are not only at risk from flood damage but also damage from inappropriate remedial works carried out by contractors who have little understanding of historic fabric. This can result in unnecessary removal and disposal of significant finishes and fittings as well as the use of unsuitable materials for the repairs. Too often like-for-like replacement is not carried out when repair works are put in hand. This document advises on preparing for and dealing with a flood, and the correct procedures for minimising damage after a flood.

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA National Flood and Coastal Erosion Risk Management Strategy (2011) The risk of flooding and coastal erosion in England is predicted to increase due to climate There are no specific targets or The LFRMS is required to The SEA Framework change and development in areas at risk. It is not possible to prevent all flooding or coastal indicators of relevance. be in conformity with this should include objectives erosion, but there are actions that can be taken to manage these risks and reduce the Strategy. relating to the management impacts on communities. This flood and coastal erosion risk management (FCERM) of flooding. strategy for England builds on existing approaches to managing risk. It aims to encourage the use of all of the available measures in a co-ordinated way that balances the needs of communities, the economy and the environment. This strategy sets out a national framework for managing the risk of flooding and coastal erosion. It will help risk management authorities and communities understand their different roles and responsibilities and will be particularly relevant to LLFAs which have new responsibilities under the Flood and Water Management Act (2010). It addresses all forms of flooding and coastal erosion consistent with the definitions in the Act. To do this it considers: Æ How the current risk of flooding and coastal erosion may change; Æ The measures that can be used to manage these risks; Æ The functions of those involved in flood and coastal erosion risk management and how these organisations can work together better; Æ How work will be paid for and the costs and benefits of the measures used; and Æ The guidance and advice available to help manage flood risk and coastal erosion. This strategy aims to make sure that Defra, the Environment Agency, local authorities, water companies, internal drainage boards and other FCERM partners work together to: Æ Maintain and over time improve standards of protection against flood and coastal erosion risks where it is affordable to do so; Æ Increase the overall level of investment in flood and coastal erosion risk management to supplement central government expenditure; Æ Help householders, businesses and communities better understand and manage any flood and coastal erosion risks that they face; Æ Ensure fast and effective responses to and recovery from flood events when they do occur; Æ Give priority to investment in actions that benefit those communities which face

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA greatest risk and are least able to afford to help themselves; Æ Encourage and support local innovation and decision making within the framework of river catchments and coastal cells; and Æ Achieve environmental gains alongside economic and social gains, consistent with the principles of sustainable development. The strategy also aims to clarify the responsibilities and roles of all the organisations involved in flood and coastal erosion risk management. Guidance for Risk Management Authorities on Sustainable Development in Relation to their Flood and Coastal Erosion Management Functions (2011) Section 27 of the Flood and Water Management Act 2010 requires certain flood and coastal There are no specific targets or The guidance applies to The SEA Framework erosion risk management authorities to aim to make a contribution towards the indicators of relevance. LLFAs. It provides should include objectives achievement of sustainable development when exercising their flood and coastal erosion background context relating to the management risk management functions. It also requires the Secretary of State to issue guidance on how about the application of of flooding. those authorities are to discharge this duty and explain the meaning of sustainable sustainable development development in this context – this document does that. principles when discharging their duties to manage flood risk. Floods Directive and the Flood Risk Regulations, 2009 These Regulations transpose Directive 2007/60/EC of the European Parliament and of the There are no specific targets or The LFRMS is required to The SEA Framework Council on the assessment and management of flood risks for England and Wales. indicators of relevance. be in conformity with this should include objectives It imposes a duty on the local authorities to prepare a flood risk management plan for each Strategy. relating to the management area which has been identified as being at significant risk of flooding. The plan must set of flooding. objectives for the purpose of managing the flood risk and propose measures for achieving those objectives. It aims to provide a consistent approach to flood risk management across all of Europe. National Planning Practice Guidance (2014) This Guidance was launched by the Government in March 2014, with the aim of making the There are no specific targets or The strategy should The SEA Framework planning system simpler, clearer and easier for people to use, allowing local communities to indicators of relevance. adhere to the principles should include objectives shape where development should and should not go. It also commits to ensuring that of the Guidance. relating to economic, countryside and environmental protections continue to be safeguarded, and devolving environmental and social power down not just to local councils, but also down to neighbourhoods and local residents. issues. The SEA will be The Guidance contains 41 categories, including guidance in relation to SEA and SA. undertaken in accordance with this Guidance. Historic Environment Good Practice Advice in Planning, Notes 1, 2 and 3, 2015 The Good Practice Advice Notes aim is to provide information to assist local authorities, There are no specific targets or The strategy should The SEA Framework

NATIONAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA planning and other consultants, owners, applicants and other parties in implementing indicators of relevance. adhere to the principles should include objectives historic environment policy in the NPPF and the related guidance given in the National of the Guidance. relating to the protection of PPG. the historic environment. The SEA will be undertaken in accordance with this Guidance.

SUMMARY OF REGIONAL, SUB-REGIONAL AND LOCAL PLANS

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA A Sustainable Future for the West Midlands –Regional Sustainable Development Framework (RSDF) (2006) The document provides four priorities and long term goals: The objectives are supported The LFRMS objectives need The SEA Framework by a suite of indicators, some to be broadly compatible should be compatible Æ Sustainable production and consumption, ensuring energy and resources are used of which include: with the priorities and long with RSDF. Detailed both efficiently and effectively by all; term goals of the RSDF. objectives should be Æ Value, protect, enhance consistent with the Æ Climate change and energy, reduce overall energy use through increased energy and restore the Region’s efficiency; overarching RSDF environmental assets, objectives. Æ Natural resource protection and environmental enhancement; and including the natural, built and historic environment Æ Sustainable communities. and landscape; Æ Minimise air, water, soil, light and noise pollution levels and create good quality air, water and soils; and Æ Encourage land use and development that creates and sustains well- designed, high quality built environments that incorporate green space, encourage biodiversity, and promote local distinctiveness and sense of place.

West Midlands Regional Climate Change Action Plan (2007) The vision for the plan is ‘of a sustainable, low carbon West Midlands, well adapted to the There are no specific targets or The LFRMS must recognise The SEA Framework impacts of climate change and supported by a low carbon economy’ indicators of relevance. the need to reduce carbon should echo the vision The priorities of the plan are to: and greenhouse gas and objectives of the emissions. plan. It should include Æ Substantially reduced emissions and resilience to likely climate change and impacts; an objective to adapt to Æ Adapt to and support local businesses adapt to unavoidable climate change; unavoidable climate change. Æ Providing appropriate support and incentives for regional, subregional and local

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA delivery agents to ensure the delivery of substantial carbon reductions and climate change adaptation measures by removing barriers; Æ Ensure that regional partners lead by example by significantly reducing carbon emissions and by ensuring that their assets and services are resilient to likely climate change impacts; Æ Increase awareness and understanding of the implications of Climate Change and appropriate mitigation and adaptation actions for the West Midlands amongst regional policymakers, public sector organisations and businesses; and Æ Establish appropriate regional carbon reduction targets and adaptation goals, and a robust and transparent framework for monitoring and reviewing progress where gaps are identified.

River Severn Catchment Flood Management Plan (2009) The plan is a high level strategic planning tool which will be used to explore and define long The Plan does not contain The LFRMS should consider The SEA Framework term sustainable policies for flood risk management. They are essential plans to enable a specific targets or indicators. potential flood risk, and should include strategic, proactive and risk-based approach to flood risk management. It provides an prevent development within objectives that promote overview of the flood risk in the River Severn catchment and sets out the preferred plan for the floodplain. the reduction and sustainable flood risk management over the next 50 to 100 years. management of flood risk. Catchment Flood Management Plan (2010) The plan is a high level strategic planning tool which will be used to explore and define long The Plan does not contain The LFRMS should consider The SEA Framework term sustainable policies for flood risk management. They are essential plans to enable a specific targets or indicators. potential flood risk, and should include strategic, proactive and risk-based approach to flood risk management. It provides an prevent development within objectives that promote overview of the flood risk in the River Trent catchment and sets out the preferred plan for the floodplain. the reduction and sustainable flood risk management over the next 50 to 100 years. management of flood risk. River Basin Management Plan for the Severn River Basin District (2009) This plan is about the pressures facing the water environment in the River Severn Basin Relevant targets include: The LFRMS should consider The SEA Framework District, and the actions that will address them. It has been prepared under the Water how the water environment should include Framework Directive, and is the first of a series of six-year planning cycles. Æ By 2015, 17% of surface can be protected and objectives that consider waters (rivers, lakes River Basin Management Plans aim to protect and improve the water environment and enhanced. effects upon water estuaries and coastal quality and resource. have been developed in consultation with organisations and individuals. They address the waters) are going to main issues for the water environment and the actions needed to deal with them. improve for at least one River basin management is a continuous process of planning and delivery. The Water biological, chemical or Framework Directive introduces a formal series of six year cycles. The first cycle will end in physical element,

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA 2015 when, following further planning and consultation, this plan will be updated and measured as part of an reissued. assessment of good The Environment Agency has worked extensively with local stakeholders to identify the status according to the actions needed to address the main pressures on the water environment. Water Framework Directive. Æ 34% of surface waters will be at good or better ecological status and 17% of groundwater bodies will be at good overall status by 2015. Æ At least 38% of assessed surface waters will be at good or better biological quality by 2015.

River Humber Basin District: River Basin Management Plan (Environment Agency, 2009) As for the above Severn RBMP discussed above, this plan is about the pressures facing Relevant targets include: The LFRMS should consider The SEA Framework the water environment in the River Humber Basin District, and the actions that will address how the water environment should include Æ By 2015, 22% of surface them. can be protected and objectives that consider waters (rivers, lakes enhanced. effects upon water estuaries and coastal quality and resource. waters) are going to improve for at least one biological, chemical or physical element, measured as part of an assessment of good status according to the Water Framework Directive. Æ 25% of surface waters will be at good or better ecological status and 17% of groundwater bodies will be at good overall status by 2015.

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA Æ At least 30% of assessed surface waters will be at good or better biological quality by 2015.

Humber Flood Risk Management Strategy, 2008 To manage the risk of flooding around the Humber Estuary in ways that are sustainable for The Plan does not contain The LFRMS should consider The SEA Framework the people who live there, the economy and the environment, taking into account: specific targets or indicators. potential flood risk, and should include prevent development within objectives that promote Æ Natural estuary processes; and the floodplain. the reduction and Æ Future changes in the environment (built or natural), sea levels or the climate. management of flood risk. To ensure that all proposals are technically feasible, economically viable, environmentally appropriate and socially beneficial. Severn Estuary Flood Risk Management Strategy, 2013 The strategy is the EA’s plan to manage tidal flood risks in the Severn Estuary. The main The Plan does not contain The LFRMS should consider The SEA Framework objectives are to specific targets or indicators. potential flood risk, and should include prevent development within objectives that promote Æ Define a 100 year plan of investment for flood defences by the EA and local authorities; the floodplain. the reduction and Æ Priorities other flood risk management measures such as providing advice to utility management of flood companies to protect critical infrastructure, development control advise and flood risk. warning investment Æ Decide where we should create new inter-tidal wildlife habitats to compensate for losses of habitat caused by rising sea levels.

River Tame Flood Risk Management Strategy, 2011 The objectives of the strategy are to: The Plan does not contain The LFRMS should consider The SEA Framework specific targets or indicators. potential flood risk, and should include Æ Understand and raise awareness of the risk of flooding on the River Tame; prevent development within objectives that promote Æ Develop a plan for the management of flood risk that is sustainable, taking in to the floodplain. the reduction and account future changes in the environment and the climate; management of flood risk. Æ Ensuring all proposals are technically feasible, economically viable, socially acceptable and environmentally appropriate; Æ Seeking opportunities for environmental improvements wherever possible through the recommendation of integrated flood risk management measures; and

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA Æ Working in partnership with and encouraging co-operation between stakeholdrers.

Cotswolds AONB Management Plan April 2013 - 18 The Cotswolds AONB Management Plan April 2013 – 18 is the statutory plan which sets The Management Plan The LFRMS needs to The SEA Framework out the policies for the management of the Cotswolds AONB and for the carrying out of its contains many indicators for include policies that seek to should include functions in relation to it. the monitoring of key issues. protect (and enhance where objectives that seek to The Plan informs public bodies of the means by which they can demonstrate compliance Some of the most relevant possible) the AONB and ensure the protection with their statutory duty to “have regard to” the purpose of designation of the AONB when include: other sensitive landscapes and enhancement within the Borough. where possible of undertaking their functions. Æ Water Resources; and It also guides the engagement of public bodies, landowners, businesses and individuals in sensitive landscapes. the management of the AONB. Æ Water quality of rivers (GQA/WFD)

Birmingham and The Black Country Biodiversity Action Plan (2010) The plan comprises a series of action plans for habitats and species. For each of the For each habitat type/species The LFRMS needs to The relevant objectives, habitats and species information is provided about current national, regional and local a series of objectives, actions incorporate policies which targets and indicators status. and timescales for support and promote the should be integrated The main objectives are to: implementation are identified. enhancement of biodiversity. into the SEA The LFRMS could have a Framework. Æ maintain and increase the biodiversity of key sites and landscapes through appropriate role in helping achieve the protection and management; BAP targets. There is Æ restore degraded habitats and key species populations by restoring key areas; potential for conflict if flood prevention measures Æ link key areas with ecological corridors to reconnect wildlife populations and make damage biodiversity. them less vulnerable; Æ promote and support the use of the natural environment to mitigate against, and adapt to, the effects of climate change; and Æ enable the sustainable use of the natural environment to benefit health and wellbeing of residents, workers and visitors as well as improving the local economy.

The Black Country Geodiversity Action Plan (2006/7)

Seven objectives are identified which reflect the wide range of interests’ involved in There are no specific targets or The strategy should include The SEA should seek to conserving the county’s geology and landforms: indicators of relevance. policies which relate to protect and enhance geoconservation interests. geodiversity in Æ To ensure geodiversity is identified and included as an integral part of all Black Country There is potential conflict if Sandwell, Dudley, sub-regional and local strategies, plans and policies; flood prevention measures Walsall and damage Local geological Wolverhampton. Æ To develop and maintain comprehensive geodiversity data resources integrated with

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA other data sets; sites. Æ To protect and enhance the geodiversity resource by appropriate designation of geological sites and features commensurate with their local, regional, national or international importance; Æ To manage existing geodiversity resources and create new features and opportunities in association with partners; Æ To increase public awareness and appreciation of the Black Country Geodiversity Heritage; Æ To maximise the opportunities for Black Country geodiversity, and Æ To establish appropriate mechanisms to secure the continuity, sustainability and effectiveness of the BCGAP process.

The Black Country Strategic Flood Risk Assessment (2009) A Strategic Flood Risk Assessment (SFRA) is a technical document that provides an The Plan does not contain The LFRMS should consider The SEA Framework assessment and overview of flood risk considerations by collating and appraising available specific targets or indicators. potential flood risk, and should include information sources on flood risk. This includes rivers, surface water, groundwater, large prevent development within objectives that promote reservoirs/lakes and sewers. The SFRA builds upon existing Council knowledge of flood the floodplain. the reduction and risk within the Borough and that sourced through consultation with the Environment management of flood Agency, Thames Water and local Town and Parish Councils. The SFRA informs the risk. preparation of the Local Development Framework and gives essential information for the allocation of land for development. The SFRA also helps to inform future planning decisions, including those made on planning applications. The Black Country SFRA was prepared in 2009 as a supplementary planning document to enable the Black Country Local Authorities to have a suitable evidence base for the development of appropriate planning policies with regards flood risk. Dudley Preliminary Flood Risk Assessment (2011) The Dudley PFRA was produced in compliance with the Flood Risk Regulations 2009 to The Plan does not contain The LFRMS should consider The SEA Framework provide a high level screening on historic and potential future flooding from surface water, specific targets or indicators. potential flood risk, and should include groundwater and ordinary watercourses. PFRAs were produced for every LLFA, based on prevent development within objectives that promote existing information including historical flood records, the Flood Map for Surface Water the floodplain. the reduction and (FMfSW) and the previous plans described above. management of flood risk. Walsall Preliminary Flood Risk Assessment (2011) The Walsall PFRA was produced in compliance with the Flood Risk Regulations 2009 to The Plan does not contain The LFRMS should consider The SEA Framework

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA provide high level screening on historic and potential future flooding from surface water, specific targets or indicators. potential flood risk, and should include groundwater and ordinary watercourses. PFRAs were produced for every LLFA, based on prevent development within objectives that promote existing information including historical flood records, the FMfSW and the previous plans the floodplain. the reduction and described above. management of flood risk. Wolverhampton Preliminary Flood Risk Assessment (2011) The Wolverhampton PFRA was produced in compliance with the Flood Risk Regulations The Plan does not contain The LFRMS should consider The SEA Framework 2009 to provide high level screening on historic and potential future flooding from surface specific targets or indicators. potential flood risk, and should include water, groundwater and ordinary watercourses. PFRAs were produced for every LLFA, prevent development within objectives that promote based on existing information including historical flood records, the FMfSW and the the floodplain. the reduction and previous plans described above. management of flood risk. Sandwell Preliminary Flood Risk Assessment (2011) The Sandwell PFRA was produced in compliance with the Flood Risk Regulations 2009 to The Plan does not contain The LFRMS should consider The SEA Framework provide high level screening on historic and potential future flooding from surface water, specific targets or indicators. potential flood risk, and should include groundwater and ordinary watercourses. PFRAs were produced for every LLFA, based on prevent development within objectives that promote existing information including historical flood records, the FMfSW and the previous plans the floodplain. the reduction and described above. management of flood risk. Sandwell Surface Water Management Plan (2013) The Surface Water Management Plan (SWMP) for Sandwell follows central government The Plan does not contact The LFRMS should consider The SEA Framework funding to tackle locations with expected surface water flooding problems. The SWMP specific targets or indicators. potential flood risk, and should include builds on the work completed in the PFRA, 2011 to better analyse the risk to properties and prevent development within objectives that promote people within the borough. the floodplain. the reduction and management of flood risk. Sandwell Borough Council Local Plan (including the Black Country Core Strategy, 2011) The Local Plan provides detailed strategic planning guidance for the area. The Core There are no specific targets or Unless carefully sited and The SEA Framework Strategy forms the basis of the Local Plan, and has been prepared conjointly with the other indicators of relevance. designed, new development should include Black Country local authorities. can increase run-off by the objectives that promote The Core Strategy is a ‘spatial planning document’ which will guide the transformation and addition of impermeable the reduction and regeneration of the Black Country by promoting economic growth through improving the surfaces. This can result in management of flood quality of employment land and aiding the delivery of a broad mix of new homes between increased risk of flooding risk. now and 2026, supported by new shops, offices, leisure, transport and environmental downstream and to improvements. surrounding areas, as well as damage to the water

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA environment. Development will be restricted in areas liable to flood and in locations that would result in an increased flood risk in surrounding areas and downstream. Dudley Borough Council Local Plan (including the Black Country Core Strategy, 2011) The Local Plan provides detailed strategic planning guidance for the area. The Core There are no specific targets or Unless carefully sited and The SEA Framework Strategy forms the basis of the Local Plan, and has been prepared conjointly with the other indicators of relevance. designed, new development should include Black Country local authorities. can increase run-off by the objectives that promote The Core Strategy is a ‘spatial planning document’ which will guide the transformation and addition of impermeable the reduction and regeneration of the Black Country by promoting economic growth through improving the surfaces. This can result in management of flood quality of employment land and aiding the delivery of a broad mix of new homes between increased risk of flooding risk. now and 2026, supported by new shops, offices, leisure, transport and environmental downstream and to improvements. surrounding areas, as well as damage to the water environment. Development will be restricted in areas liable to flood and in locations that would result in an increased flood risk in surrounding areas and downstream. Wolverhampton City Council Local Plan including the Black Country Core Strategy, 2011) The Local Plan provides detailed strategic planning guidance for the area. The Core There are no specific targets or Unless carefully sited and The SEA Framework Strategy forms the basis of the Local Plan, and has been prepared conjointly with the other indicators of relevance. designed, new development should include Black Country local authorities. can increase run-off by the objectives that promote The Core Strategy is a ‘spatial planning document’ which will guide the transformation and addition of impermeable the reduction and regeneration of the Black Country by promoting economic growth through improving the surfaces. This can result in management of flood quality of employment land and aiding the delivery of a broad mix of new homes between increased risk of flooding risk. now and 2026, supported by new shops, offices, leisure, transport and environmental downstream and to improvements. surrounding areas, as well as damage to the water environment. Development will be restricted in areas liable to flood and in

REGIONAL, SUB-REGIONAL AND LOCAL PLANS

KEY OBJECTIVES RELEVANT TO PLAN AND SEA KEY TARGETS AND INDICATORS IMPLICATIONS FOR LFRMS IMPLICATIONS FOR SEA RELEVANT TO PLAN AND SEA locations that would result in an increased flood risk in surrounding areas and downstream. Walsall Council Local Plan ( including the Black Country Core Strategy, 2011) The Local Plan provides detailed strategic planning guidance for the area. The Core There are no specific targets or Unless carefully sited and The SEA Framework Strategy forms the basis of the Local Plan, and has been prepared conjointly with the other indicators of relevance. designed, new development should include Black Country local authorities. can increase run-off by the objectives that promote The Core Strategy is a ‘spatial planning document’ which will guide the transformation and addition of impermeable the reduction and regeneration of The Black Country by promoting economic growth through improving the surfaces. This can result in management of flood quality of employment land and aiding the delivery of a broad mix of new homes between increased risk of flooding risk. now and 2026, supported by new shops, offices, leisure, transport and environmental downstream and to improvements. surrounding areas, as well as damage to the water environment. Development will be restricted in areas liable to flood and in locations that would result in an increased flood risk in surrounding areas and downstream.

Appendix B

BASELINE DATA

BIODIVERSITY/FLORA AND FAUNA

The following baseline indicators have been used to characterise conditions across the Black Country:

Æ Number and distribution of designated sites (MAGIC, www.magic.gov.uk; iGIS, SMBC, DMBC, WC and WCC websites); Æ Condition of SSSIs (data from Natural England, 2014); Æ Areas of woodland, including ancient woodland (www.magic.gov.uk); and Æ Key Biodiversity Action Plan (BAP) species and habitats present ( and Black Country BAP).

The Boroughs have a number of nationally designated sites of conservation importance (refer to Figures 1 and 2).

National Nature Reserves (NNR’s)

Wolverhampton, Walsall and Sandwell do not have any NNR’s within their district boundaries. However, adjacent to the east of the Walsall district boundary is Sutton Park, which is also a SSSI. Wren’s Nest NNR (also SSSI) is situated in the north of the Dudley borough.

Sites of Special Scientific Importance (SSSI)

There are no SSSIs in the Wolverhampton City or Sandwell Borough.

There are 8 SSSIs in the Walsall area3. The Cannock Extension Canal SSSI is also an SAC extending from the Cannock Chase District into the north of Walsall District, and is approximately 5.1ha in size and is categorised as Standing Open Water and Canals. The Chasewater and The Southern Coalfield Heaths SSSI is approximately 530ha in size with its most southern area in the north of Walsall and has categories of Dwarf Shrub Heath, Lowland; Fen Marsh and Swamp, Lowland; and Standing Open Water and Canals. Clayhanger SSSI has an approximate area of 27.2ha and is categorised as Neutral Grassland – Lowland. Jockey Fields SSSI is approximately 17.9ha in size and categorised as Neutral Grassland – Lowland and M23 – Juncus effuses / acutiflorus – Galium palustre rush pasture. Swan Pool and The Swag SSSI is approximately 6ha in size and is categorised as Fen, Marsh and Swamp – Lowland. Stubbers Green Bog SSSI is approximately 2.7ha in size and is categorised as Fen, Marsh and Swamp – Lowland. Daw End Railway Cutting SSSI is approximately 8ha in size and is categorised as Earth Heritage. Hay Head Quarry SSSI is approximately 5.5ha in size and is categorised as Earth Heritage.

According to Natural England’s website5 a portion of Cannock Extension Canal SSSI is unfavourable – recovering and the remainder favourable. The majority of The Chasewater and The Southern Staffordshire Coalfield Heaths Dwarf Shrub Heaths SSSI is unfavourable – recovering with the Fen, Marsh and Swamp and Standing Open Water and Canals SSSI being favourable. The Clayhanger SSSI has areas which are unfavourable - recovering; however, the majority of areas are unfavourable – declining. The Neutral Grassland – Lowland areas of Jockey Fields SSSI are Unfavourable – recovering, however the M23 – Juncus effuses / acutiflorus – Galium palustre rush pasture is Unfavourable – No change. Swan Pool and The Swag SSSI is Unfavourable – No change. Stubbers Green Bog is Unfavourable – declining. Around half of Daw End Railway Cutting is Favourable, with the other half being Unfavourable – declining. Hay Head Quarry is Favourable.

There are 8 SSSIs in the Dudley Borough5. Wren’s Nest SSSI is situated in the north of the borough and is approximately 34ha in size; Turner’s Hill SSSI is approximately 1.6ha in size; Barrow Hill and Tansey Green SSSI is approximately 15ha in size; Ketley Claypit is approximately 1.6ha in size; Brewin’s Canal Section is approximately 1.3ha in size; and Doulton’s Claypit is approximately 3ha in size; Road Cutting, Tenterfields SSSI is approximately 0.18ha in size. All SSSI’s located within Dudley

3 http://www.dudley.gov.uk/resident/environment/conservation/ecological--geological-services/

are categorised as Earth Heritage apart from Fens Pools, approximately 38ha in size, is categorised as Standing Open Water and Canals. According to Natural England’s website4, Wren’s Nest, Ketley Claypit, Brewin’s Canal Section and Fens Pools are all Favourable. Turner’s Hill is Unfavourable – Recovering. Barrow Hill and Tansey Green is mainly Favourable with a small percentage of the SSSI as Unfavourable – No change. Doulton’s Claypit and Bromsgrove Road Cutting, Tenterfields is Unfavourable – No Change.

Local Nature Reserves (LNRs)

LNR's reflect areas of locally important nature conservation or amenity value and give access to the public. Wolverhampton has 1 LNR: Smestow Valley, which lies to the west of the borough and is approximately 51ha in size5. There are 11 LNRs within Walsall, comprising Barr Beason and Pinfold Lane Quarry, Cuckoo’s Nook and the Dingle, Fibbersley, Hay Head Wood, Mill Lane, Merrions Wood, Moorcroft Wood, Park Lime Pitts, Pelsall Common North, Rough Wood Chase and Shire Oak Park6. Sandwell has 10 LNRs, comprising Holly Wood, Gorse Farm Wood, Forge Mill Lake, Priory Woods, Sot’s Hole with Bluebell Wood, Sheepwash, Codsall Coppice, Mousesweet Brook, RSPB Sandwell Valley and Warrens Hall7. A further 6 LNR’s lie in Dudley, comprising Cotwall End, Barrow Hill, Buckpool and Fens Pool and Saltwells and Bumble hole and Warrens Hall8.

There are numerous non-statutory sites in the Black Country, referred to as Sites of Importance for Nature Conservation (SINCs)9. There are 103 located within the Black Country10 covering a total area of 160ha. There have recently been some net losses to such nature conservation sites in recent years within the Black Country region11.

4 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001404&ReportTitle=BROMSGROVE ROAD CUTTING, TENTERFIELDS 5 http://www.wolverhampton.gov.uk/article/3355/Smestow-Valley-Local-Nature-Reserve 6 http://cms.walsall.gov.uk/index/nature_reserves.htm 7 http://www.sandwell.gov.uk/info/200248/parks_and_green_spaces/2313/nature_reserves 8 http://www.dudley.gov.uk/resident/environment/countryside/nature-reserves/ 9 http://www.wildlifetrust.org.uk/urbanwt/ecorecord/bap/html/ptables.htm 10 http://www.wildlifetrust.org.uk/urbanwt/ecorecord/bap/html/ptables.htm 11 Sandwell Annual Monitoring Report

Figures 1 and 2 – International, National and Local Nature Conservation Designations (Source: iGIS)

The UK Government published ‘Biodiversity: The UK Action Plan’ in 1994. The plan combined new and existing conservation initiatives with an emphasis on a partnership approach. It contains objectives for conserving and enhancing species and habitats as well as promoting public awareness and contributing to international conservation efforts. Following on from the initial strategy publication, Species Action Plans (SAPs) and Habitat Action Plans (HAPs) were published for the UK’s most threatened (i.e. “priority”) species and habitats. In addition Local Biodiversity Action Plans have been produced at county level. These plans usually include actions to address the needs of the UK priority habitats and species in the local area, together with a range of other plans for habitats and species that are of local importance or interest (Biodiversity Action Reporting System12).

The Birmingham and the Black Country BAP is made up of many individual species and habitat plans. Each plan gives information on the status and threats to the species or habitat. The most important section of the plan details the conservation action required and the organisations responsible. Birmingham and the Black Country BAP species and habitats include the following13:

Æ Habitat Action Plans;

Ancient broad-leaved (semi-natural);

Lowland neutral and base-rich grassland;

Lowland dry acid grassland;

Lowland wet grassland;

Rivers and streams;

Canals;

Arable Fields; and

Field margins and beetle banks; Æ Urban Habitat Plans;

Urban “Wasteland”;

Managed Greenspace; and

Building / Built Environment; Æ Species Plans;

Deadwood habitats (invertebrates and fungi);

Badger;

Bluebell;

Green hairstreak;

Dingy skipper;

Orchids;

Vaccinium spp.;

White-clawed Crayfish;

Amphibians;

Great Crested Newts;

Snipe;

Floating water-plantain;

12 http://www.ukbap-reporting.org.uk/ 13 http://www.wildlifetrust.org.uk/urbanwt/ecorecord/bap/html/main.htm

Water vole

Hedgerows;

Brown hare;

Tree sparrow;

Grey partridge;

Skylark;

Little ringed plover;

Wall butterfly;

Garden ponds;

Eutrophic urban pools;

Song thrush;

Bats;

Black redstart; and

Kestrel.

There are a number of areas of ancient woodland across the Black Country. Figure 2 shows the locations of these. Although these are considerably scattered throughout the boroughs, there are an increased number of larger areas of ancient woodland to the east and west of the Black Country.

Figure 2: Ancient Woodland in the Black Country

Source: iGIS

POPULATION

The following baseline indicators have been used to identify key population trends and characteristics:

Æ Total population and density (2011 Census); Æ Age structure of the population (2011 Census); and Æ Ethnic groups represented in the population (Black Country Contextual update, 2012 – 2013)

Table 1 shows the percentage increase of population across the Black Country between 2001 and 2011. Population has increased in all the Black Country areas and is mainly consistent with the West Midlands and England and Wales increases. Dudley has had the smallest increase of 2% in contrast to Sandwell where the population increased by 8.17%.

Table 1: Population change 2001 – 2011

REGION 2011 POPULATION CHANGE IN POPULATION SINCE 2001 Number Percentage Wolverhampton 249,470 +12,888 +5.17% Walsall 269,323 +15,824 +5.88% Sandwell 308,063 +25,159 +8.17% Dudley 312, 925 +7,770 +2% West Midlands 5,601,847 +334,539 +6% England and Wales 53,012,456 +3,873,625 +7.3%

Source: Neighbourhood Online Statistics

The change in the proportion of young people between the ages of 10 and 14 from 2001 and 2011 was decreased substantially in Wolverhampton (-8.6%) and Dudley (-6.1%) which is comparable to the West Midlands (-6.1%), yet Sandwell (-2.4%) and Walsall (-2%) had a much lower decline. Sandwell has a significantly higher percentage of residents aged 20-29 than the other areas in the Black Country, West Midlands and England. Dudley has a higher percentage of residents from age 60+ than the other areas in the Black Country and West Midlands as a whole. Dudley and Walsall have experienced a decline in residents between the ages of 30-39 which is much higher than Wolverhampton, Sandwell, West Midlands as a whole and England. Wolverhampton has a significant decline of population of the age of 85+ of -29%, in contrast to the rest of the Black Country, West Midlands and England which all have increases of 23.7% or more.

Table 2 breaks down the above analysis for the Black Country more comprehensively by quinary age groups and compares with the regional and English average.

Table 2: Population change for 2011 in quinary age groups

AGE CHANGE IN POPULATION SINCE 2001

GROUP

N N N

O S O 1 O I T T D T 1 1

P P A N 0 1 1

L A M M 2 1 % N N N E E 0

L U A A % 0 S S 2 O L O O % L

I I I P D H H L L A I A 2 E % E E E L L D T T T O E E R R E E S S S S L L A A Y A Y N M E E A A P R R A A A A L L L W W E E A

V V E E T S C S E C E L L L U U U D D 1 L L L L S R R N R N R P P D P D G N N 1 I I O A O A E

C C C C U U O A O O A N 0 N N N N W 2 W P S P D P W % W I S I D I W % E I

0-4 16,687 18,373 22,669 18,867 17.7% 12% 24.8% 11.2% 11.2% 13.4% 5-9 14,442 16,971 20,194 17,934 -7.9% -3% 2.4% -4.8% -4.8% -4.8% 10-14 15,095 17,266 19,333 18,539 -8.6% -2% -2.4% -6.1% -6.1% -4.6% 15-19 16,728 17,667 20,220 19,863 8.8% 9% 11.9% 8.7% 8.7% 10.1% 20-24 17,988 17,504 20,793 18,141 18% 27% 33.3% 23.3% 23.3% 21.8% 25-29 17,947 17,690 23,085 18,947 14% 12% 19.8% 10.7% 10.7% 11.7% 30-34 16,436 16,184 21,326 18,024 -10% -14.8% -5.4% -12.6% -12.6% -7.3%

AGE CHANGE IN POPULATION SINCE 2001

GROUP

N N N

O S O 1 O I T T D T 1 1

P P A N 0 1 1

L A M M 2 1 % N N N E E 0

L U A A % 0 S S 2 O L O O % L

I I I P D H H L L A I A 2 E % E E E L L D T T T O E E R R E E S S S S L L A A Y A Y N M E E A A P R R A A A A L L L W W E E A

V V E E T S C S E C E L L L U U U D D 1 L L L L S R R N R N R P P D P D G N N 1 I I O A O A E

C C C C U U O A O O A N 0 N N N N W 2 W P S P D P W % W I S I D I W % E I

35-39 16,744 16,906 21,168 19,798 -3.5% -10% -2% -9.8% -9.8% -8.6% 40-44 18,219 19,503 22,411 23,848 17% 16.6% 21.5% 13% 13% 12.3% 45-49 17,370 19,087 21,398 23,248 22.8% 24% 30% 21.5% 21.5% 24.7% 50-54 14,949 16,464 17,991 19,583 3% 0.3% 5.4% -2.7% -2.7% 0.5% 55-59 13,255 14,672 15,495 18,389 5.9% -2% 1% 2.3% 2.3% 7.6% 60-64 12,981 15,221 15,230 19,547 10.6% -7.9% 28.3% 25.6% 25.6% 32.6% 65-69 10,853 13,227 13,139 17,255 2% 6% 1.2% 16.4% 16.4% 18.6% 70-74 9,712 11,439 11,381 14,247 6.4% 6.23% -4.2% 5.6% 5.6% 4.9% 75-79 8,146 9,194 9,186 11,379 5% 9.6% -7.4% 2.1% 2.1% 1.5% 80-84 6,322 6,558 6,950 8,418 12.9% 23% 0.2% 14.8% 14.8% 13.8% 85+ 5,596 5,397 6,185 6,898 -29% 33.5% 27.4% 30% 30% 23.7% Source: Neighbourhood Online Statistics

In 2011, the Local Authority areas in the Black Country had a significantly higher population density compared to West Midlands as a whole (4.3 people per hectare), with Sandwell being the highest density of 36 people per hectare, then Wolverhampton with 35.9 people per hectare, Dudley at 31.9 people per hectare and Walsall with 25.9 people per hectare14.

According to the Black Country contextual update (2012-13), Wolverhampton has the greatest proportion of minority groups (defined as non-White British) at 35.5%, with Sandwell having 34.2%, Walsall 23% and Dudley 11.5%. Asian groups are the largest minorities in each area; Pakistani in Dudley and Indian in the other three districts15.

HUMAN HEALTH

The following baseline data has been used to identify key trends:

Æ Percentage of the resident population who consider themselves to be in good health (ONS); Æ Number of wards with Lower Super Output Area (LSOA) in the bottom 10% most deprived for health deprivation and disability ( Local Health Profiles); Æ Life expectancy at birth for males and females for the period 2005 – 2009 and for 2013 (ONS); Æ Contextual information for mortality and mortality rates for circulatory disease and cancer (Local Council’s Health Profile and the council’s websites); and Æ Conception rate of under-18 year olds (per 1,000 15-17 year olds) (The local Health Profiles).

At the time of the 2011 census, the residents of the Black Country considered themselves relatively healthy with at least 76% stating that their health was ‘good’ or better within each local authority area, which is slightly better than the West Midlands (80%), but lower than England at 81.4% (refer to Table 3 below).

14 http://www.ons.gov.uk/ons/index.html 15 http://cms.walsall.gov.uk/black_country_contextual_update_2012-13.pdf

Table 3: Health of the Black Country according to 2011 census 16

WOLVERHAMPTON % WALSALL % SANDWELL % DUDLEY % WEST MIDLANDS % ENGLAND % Very good 41% 42.2% 41% 42.4% 45.1% 47.2% health Good health 35.3% 35.1% 34.8% 35.8% 34.8% 34.2% Fair health 15.7% 15.5% 15.6% 15.3% 14% 13.1% Bad health 5.5% 5.6% 5.9% 5.1% 4.7% 4.3% Very bad 1.7% 1.7% 1.8% 1.4% 1.4% 1.3% health Source: Office for National Statistics

Life expectancy for males and females has gradually increased across the Black Country between 2005 and 2009. Table 4 presents this data. During all three periods life expectancy for both males and females in Sandwell is lower compared to the rest of the Black Country, West Midlands and England averages.

Table 4: Life Expectancy at Birth for Males and Females

YEAR Indicator 2005-2007 2006-2008 2007-2009 Life Expectancy at Birth (Males) Wolverhampton 75.7 75.7 76.3 Walsall 75.7 75.9 76.3 Sandwell 74.2 74.3 74.9 Dudley 77.1 77.2 77.8 West Midlands 76.9 77.2 77.5 England 77.6 77.9 78.3 Life Expectancy at Birth (Females) Wolverhampton 80.3 80.5 81.0 Walsall 81.3 81.3 81.9 Sandwell 80.0 80.0 80.7 Dudley 81.6 81.9 82.2 West Midlands 81.4 81.6 81.9 England 81.8 82.0 82.3

Source: Office for National Statistics

The Wolverhampton Health Profile shows that over the last 10 years, all cause mortality rates have fallen within the city. Early death rates from cancer and from heart disease and stroke have fallen but remain worse than the England average.

According to the Walsall Health Profile, over the last 10 years, all cause mortality rates have slightly fallen within in the area and are only slightly worst than the England average. Early death rates from heart disease and stroke and cancer have fallen but remain worse than the England average.

According to the Sandwell Health Profile, over the last 10 years, all cause mortality rates have fallen within the borough. Early death rates from cancer and from heart disease and stroke have fallen but remain worse than the England average.

16 http://www.neighbourhood.statistics.gov.uk/dissemination/

The Dudley Health Profile shows that over the last 10 years, all cause mortality rates have fallen within the borough and are similar to the England average. Early death rates from cancer and heart disease and stroke have also fallen and remain fairly consistent with the England average.

The census also asked people if they were providing unpaid care to family, friends or neighbours with long term physical or mental health problems. All of the areas within the Black Country are substantially higher than the 10.2% in England: Wolverhampton – 10.9%, Walsall – 11.1%, Sandwell – 11% and Dudley – 12.1%. In Wolverhampton, in 2001, 25,707 people stated that they provided unpaid care, compared to 27,136 in 2011, an increase of 5.6% people over ten years. In Walsall, 27,941 people stated that they provided unpaid care in 2001, increasing by 9.6% in 2011 to 30,632. Sandwell’s population declared that 30,086 people provided unpaid care, increasing by 11.5% to 33,530 in 2011. In Dudley, in 2001, 35,030 people stated that they provided unpaid care, compared to 37,974 in 2011, an increase of 8.4%17.

According to ‘The Black Country Contextual Update’ document15, Wolverhampton is ranked the 21st most deprived local authority out of 326 LAs in England, Walsall is ranked 30th, Sandwell 12th and Dudley is 104. In the 2010 Indices of Deprivation shows that 9.4% of Dudley’s LSOA were amongst the 10% most deprived in England, compared to 24.3% in Walsall, 23.6% in Wolverhampton and 30.5% in Sandwell.

SOIL AND LAND QUALITY

The following baseline indicators have been used to characterise the soil and land quality conditions across the Black Country:

Æ Distribution of best and most versatile agricultural land (iGIS and www.magic.gov.uk); Æ Soil types within the Black Country (Soilscapes website); Æ Percentage of housing completions on previously developed land (ONS); Æ The Black Country Core Strategy; Æ The Strategic Housing Land Availability Assessment’s (SHLAA) for the local authorities; Æ Key sources of Contaminated Land (local authorities websites); and Æ Area of previously developed vacant land, vacant buildings and derelict land and buildings (ONS).

The Black Country Core Strategy and the SHLAA’s for each of the local authorities, state that at least 95% of residential development should be located on previously developed, brownfield land. In 2010/2011, Sandwell exceeded this with 97% of completions18, exceeding the targets set out. Dudley further exceeded the target by 98.1% of development completions19. Walsall also exceeded the targets with 98% in 2011/201220. Wolverhampton did not meet the target in 2011/201221 with 93% of development completions.

Contaminated Land documents are not available; however 83 sites are on the public register for contaminated sites22. In the 18th Century, the metal trades were the main manufacturing industries of Walsall due to its location. The main employment within this area was in the making of bits, stirrups, buckles, chains, mining, engineering, decorative leather goods, harnesses and saddlery, nails, locks and iron founding. Due to the historical land use of the area it is envisaged that there are numerous potential sources of ground contamination. A known database of potentially contaminated sites in the area shows nearly 9,000 areas that are potentially contaminated23.

17 Office for National Statistics (2011) Neighbourhood Statistics http://www.neighbourhood.statistics.gov.uk 18 http://www.sandwell.gov.uk/ 19 http://www.dudley.gov.uk/ 20 http://cms.walsall.gov.uk/local_plan_monitoring_report_2012__final_.pdf 21 http://www.wolverhampton.gov.uk/CHttpHandler.ashx?id=1474&p=0 22 http://www.wolverhampton.gov.uk/article/3372/Contaminated-land 23 http://cms.walsall.gov.uk/contaminated_land.pdf

In Sandwell, the key potential sources of contamination within the Borough are those associated with the legacy of land contamination arising from a range of past activities including industrial processes, mining and waste disposal, and sites such as petrol stations, railway land and transport depots, scrap yards and sewage treatment works / waste water treatment works24.

Dudley is situated at the heart of The Black Country, and is an intensely industrialised area that was at the forefront of the industrial revolution. It has strong industrial heritage, built upon its mineral wealth of coal, ironstone, limestone, fireclay and sand. Numerous sites have become contaminated due to human activities involving the use, manufacture, storage and disposal of toxic or hazardous substances. In addition, land contamination as a result of substances such as arsenic, methane and carbon dioxide occur naturally due to the geology of the Borough. Contamination can also be present as a result of accidents, spillages, aerial deposition or migration. The nature of the borough’s industrial past has also resulted in other hazardous ground conditions associated with unstable land, shallow coal workings, mineshafts and limestone caverns being present. The key potential sources of contamination within the Borough are those associated with the legacy of land contamination and sites such as petrol stations, railway land and transport depots, scrap yards and sewage treatment works / waste water treatment work25.

According to Agricultural Land Classification, the majority of the Black Country is classified as urban (Figure 3). Grade 3 (good to moderate quality) land lies to the north of Wolverhampton, the north and east of Walsall and the north of Dudley. Small pockets of Grade 2 (very good quality) agricultural land can be found in the north west of Wolverhampton and the west of Dudley. In addition, there are areas of Grade 4 (poor quality) to the north of Wolverhampton, north of Walsall, east of Sandwell and north of Dudley.

Figure 3: Agricultural Land Classification

Source: iGIS

The amount of vacant land, derelict land and buildings and vacant buildings across The Black Country is fairly high when compared to other parts of West Midlands26 . In 2010, the areas of derelict land and buildings and vacant buildings within Wolverhampton were 120ha. Sandwell (140ha) and Walsall

24 SMBC Contaminated Land Inspection Strategy, January 2013 25 DMBC Contaminated Land Inspection Strategy, 2015 26 Office for National Statistics

(130ha) were similar to Wolverhampton, however Dudley was significantly lower with only 40ha of derelict land and buildings and vacant buildings.

According to Natural England, the geology of the West Midlands is dominated by the South Staffordshire Coalfield, which has contributed greatly to the industrial and economic development of the area through exploitation. Upper Carboniferous Coal Measures underlie the main conurbation of Wolverhampton, Walsall, West Bromwich and Dudley, with sandstones and mudstones surrounding (Triassic aged rocks) and underlying much of Birmingham and forming the solid geology up to Sutton Coldfield. Within the main mass of the Coal Measures there are a number of isolated outcrops of older Silurian rock, which are shallow water limestones and shales containing a wide range of marine fossils and form the famous outcrops at Wren’s Nest and Hill. There are also a number of igneous intrusions into the Coal Measures. Much of the area has been mantled in thick deposits of boulder clay and sands and gravel deposited by ice sheets and meltwaters during the Ice Ages of the last two million years27.

According to the Soilscapes28 website (Figure 4), the main soil type within the Black Country is ‘slowly permeable, seasonally wet, slightly acid but base-rich loamy and clayey soils’ within the north of Wolverhampton, Walsall, the majority of Sandwell and a small portion in the south of Dudley. These areas are of moderate fertility. The majority of Dudley is classified as ‘slowly permeable, seasonally wet, acid loamy and clayey soils’ with low fertility. The east of Dudley and west of Sandwell comprises soil type of ‘slightly acid, loamy and clayey soils with impeded drainage’ with a moderate to high fertility. In addition, there are smaller areas of ‘freely draining slightly acid sandy soils’ to the south of Sandwell, ‘naturally wet very acid sandy and loamy soils’ to the east of Sandwell, ‘freely draining acid loamy soils over rock’, to the east of Dudley, ‘loamy soils with naturally high groundwater’ to the east of Wolverhampton and ‘loamy and clayey floodplain soils with naturally high groundwater’ to the south of Walsall.

Figure 4: Soil Types

Source: Soilscape

27 http://www.naturalengland.org.uk/ourwork/conservation/geodiversity/englands/counties/area_ID38.aspx 28 https://www.landis.org.uk/soilscapes/

WATER

The following baseline indicators have been used to characterise the water environment in the Black Country:

Æ River catchment areas (Environment Agency Catchment Flood Management Plans); Æ Distribution of areas at risk of fluvial flooding (Environment Agency Flood Map); and Æ Number of planning applications granted permission contrary to Environment Agency advice (AMR’s for the Black Country Boroughs).

Water is an essential resource required for domestic and industrial use. The Black Country is at the watershed of two major rivers. The majority of the Black Country drains into the River Trent via the River Tame. Many watercourses, particularly in the River Tame catchment, are culverted or in concrete channels through the urban areas29.

The main watercourses (i.e. managed by the EA and the Canal and River Trust) in the Black Country are Stourbridge Canal, River Stour (Warks), River Tame, Birmingham to Wolverhampton Canal, Wyreley and Essington, Daw End and Rushall Canals, Titford Feeder, Titford Canal, Walsall Canal, Coseley Catchtrib and Hockley Brook Catchment.

The Black Country has mostly a moderate to good record of water quality (Figure 5) which is fairly consistent with the rest of the County.

Figure 5: Current Ecological Quality of rivers in The Black Country

Source: Environment Agency

The Environment Agency has identified a risk of flooding on land adjacent to Rivers Stour, Tame and Coseley Catchtrib and the Smestow Brook and Sneyd Brook (Environment Agencies online Flood

29 http://cms.walsall.gov.uk/black_country_contextual_update_2012-13.pdf

Map). Flooding remains a risk within the Black Country with communities located adjacent to, or near, these watercourses.

During 2011/2012, there were no applications granted by WCC contrary to EA advice on flooding and water quality. One application with an EA objection has yet to be determined30. During 2011/2012, there were no planning applications approved by WC that were contrary to the advice of the EA on flood risk grounds or water quality grounds31. During financial year 2011/2012, no applications were approved by SMBC contrary to EA advice on flooding and water quality32. During the year 2011 no applications were approved by DMBC contrary to EA advice on flooding and water quality33, although one application was granted permission with a relevant condition.

High levels of nitrates are found in areas of poor water quality. The whole of the Black Country is covered by a Surface Water Nitrate Vulnerable Zones (NVZs), according to the Environment Agency website34. NVZs apply to areas where surface and/or groundwater contains nitrate concentrations in excess of 50mg/l.

Water resources within the Black Country are managed by South Staffordshire Water, apart from in Wolverhampton, which is managed by Severn Trent Water.

ENERGY AND CLIMATE CHANGE

The following baseline indicators have been used:

Æ Changing weather patterns (Met Office); and Æ Annual average domestic gas and electricity consumption per consumer (www.gov.uk).

Action to avoid the most serious effects of climate change, and to minimise the emission of greenhouse gases needs to occur at a local level. The Black Country will not be immune to the impacts of climate change, either directly or as a result of policy responses at the national and international levels.

Changing weather patterns may be seen as direct indicators of climate change. The Met Office’s average figures for the Midlands for 1981-2010 indicate that minimum daily temperatures ranged from 0.8°C in February to a minimum of 11.5°C in July, while maximum temperatures ranged from 6.7°C in January to 21.1°C in July. Average monthly rainfall in the Midlands varies from 54.0mm in February, to 82.0mm in October, with an average annual total of 798.3mm35. All regions of the UK have experienced an increase over the past 45 years in the contribution to winter rainfall from heavy precipitation events; in summer all regions except NE England and N Scotland show decreases.

Table 5 below represents the average domestic energy usage per year per customer. Over the years, trends show that energy consumption has decreased fairly substantially. Walsall’s average gas consumption has decreased the most from 2010-2013 with a reduction of 1,625kWh per consumer, with Sandwell consumers reducing the least (1,326kWh). Between 2010 and 2013, the electrical consumption across the Black Country has been fairly consistent between 177kW and 187kW; however, Dudley has decreased significantly more with a reduction of 223kW per year.

30 http://www.wolverhampton.gov.uk/CHttpHandler.ashx?id=1474&p=0 31 http://cms.walsall.gov.uk/local_plan_monitoring_report_2012__final_.pdf 32 http://www.sandwell.gov.uk/downloads/download/441/annual_monitoring_reports 33 http://www.dudley.gov.uk/resident/planning/planning-policy/local-development-framework/annual-monitoring-report/ 34 http://maps.environment- agency.gov.uk/wiyby/wiybyController?topic=nvz&ep=map&scale=7&lang=_e&layerGroups=default&layerGroupToQuery=1 &x=411374.9996&y=314125.00035&textonly=off 35 Met Office (2013) Average Tables. http://www.metoffice.gov.uk/public/weather/climate/hill-top-west-midlands- conurbation#?tab=climateTables

Table 5: Average energy consumption per customer since 201036

LOCAL ENERGY 2010 2011 2012 2013 AUTHORITIES Wolverhampton Gas (kWh) 15,289 14,493 14,222 13,735 Electric (kW) 3,972 3,919 3,838 3,785 Walsall Gas (kWh) 15,350 14,488 14,219 13,725 Electric (kW) 4,029 3,988 3,892 3,854 Sandwell Gas (kWh) 14,148 13,459 13,213 12,822 Electric (kW) 3,828 3,759 3,683 3,651 Dudley Gas (kWh) 14,876 14,027 13,935 13,510 Electric (kW) 4,003 3,920 3,817 3,780

MINERALS AND WASTE

The following baseline indicator has been used to characterise the existing conditions:

Æ Amount of household waste collected and recycled (Government Statistical Data Sets); Æ Proportion of fly tipping incidents (local authorities Annual Monitoring Reports); and Æ Amount of waste produced (Environment Agency, 2010).

The emerging Black Country Core Strategy for Minerals and Waste will contain mineral and waste specific policies for use in determining planning applications for waste or quarry developments. It will set out the strategy for future minerals and waste development and addresses issues including mineral extraction; waste management and recycling; protecting mineral resources and restoring minerals and waste sites.

Across the Black Country, collected waste per household has increased, with the smallest increase of 5.99kg in Sandwell, and the largest increase in Wolverhampton of 16.73kg. This is shown in Table 6 below37.

Table 6: Collected household waste per person

BOROUGH 2012/2013 (KG) 2013/2014 (KG) Wolverhampton 418.35 435.08 Walsall 390.99 407.71 Sandwell 379.29 385.28 Dudley 380.92 390.69

The aim within the Black Country is to have sufficient waste recycling and waste management facilities in locations which are the most accessible and have the least environmental impact38. The Black Country will have zero waste growth in managing waste and will have an increased variety of waste management facilities that will enable the management of a wider range of wastes locally, move waste up the waste hierarchy and address waste as a valuable resource.

The 2012 AMR states that the number of reported fly-tipping incidents has decreased Dudley, Sandwell and Wolverhampton since 2006/7, whereas the number of incidents in Walsall has

36 https://www.gov.uk/government/publications?keywords=gas&publication_filter_option=all&topics%5B%5D=all&departments %5B%5D=department-of-energy-climate- change&official_document_status=all&world_locations%5B%5D=all&from_date=&to_date= 37 https://www.gov.uk/government/statistical-data-sets/env18-local-authority-collected-waste-annual-results- tables 38 The Black Country Core Strategy, 2012

increased. The proportion of such incidents in the Black Country in 2011/12 was higher than the national average (65.3% of all incidents reported in England 2011/12). The Black Country’s target is to not increase the total number of fly-tipping incidents or number Household, Commercial and Construction, Demolition and Waste Incidents.

The proportion of incidents involving fly-tipping of CD&EW waste was also higher than the national average, 7.4% in the Black Country compared to 6% of all incidents reported in England. However, the percentage of incidents involving fly-tipping of commercial waste was lower than the national average – 5.8% in the Black Country compared to 6.6% in England. The Dudley and Walsall areas fall below the Black Country average, being below the national average for fly tipping of Household Waste, whilst Sandwell and Wolverhampton statistics are higher than the Black Country and national averages. In terms of CD&EW, Dudley falls below the Black Country and national average, however, Sandwell, Walsall and Wolverhampton exceed these. Sandwell, Walsall and Wolverhampton are substantially lower than the Black Country and national averages in terms of Commercial waste fly tipping, whereas Dudley is significantly higher39.

To reduce the need for natural resources, recycled and secondary materials should be used where feasible in construction projects and new developments that occur in the Borough. The successful implementation of sustainable design and construction techniques will reduce emissions from the domestic and commercial sectors and will assist in tackling the impacts of climate change. In addition, the promotion of renewable energy technologies at the micro and macro levels will help to reduce the need for energy from sources that contribute to climate change and will go towards meeting the renewable energy targets at the national, regional and local level. The Local Plan for each of the LA’s, of which the Black Country Core Strategy is the lead document, is one of the mechanisms through which emission reductions will be put into action.

There are four Active Waste Schemes in the Black Country. This comprises the Wolverhampton Incinerator with a capacity of 8.35MW, Himley Wood (1.82MW), Edwin Richards (1.78MW) and Dudley Incinerator (6.2MW). There is one proposed / planned Energy to Waste Scheme, which would be the Foxyards Waste to Energy Plant.

Source: Renewables Map40 TRANSPORTATION

The following baseline indicators have been used to characterise the existing conditions across the Black Country:

Æ Distribution of major transport systems – roads, airports, ports, rail etc. (Ordnance Survey mapping); and Æ Journey to work by mode (2011 Census). The Black Country is served by effective communication links that provide access to the rest of the country. The M5 runs along the south-eastern boundary of Dudley connecting through Sandwell to the M6 linking in to Walsall and Wolverhampton. The areas within the Black Country have additional inter- connections via A roads, which also connect to outside the Black Country including to Birmingham City Centre. In addition, the Black Country is connected by local and national rail services and local bus services.

Figures 7 and 8 below show the cycle paths in the Black Country. National Routes run from the centres of the boroughs, effectively creating a connection between them, and Walsall and Wolverhampton are connected b y a

39 Sandwell AMR, 2012 40 http://www.renewables-map.co.uk/index.asp?Status=2&passlat=52.411&passlong=-1.777&passzoom=9

Local Route, both on and off road. There are no cycle routes to the west of Wolverhampton, to the east of Walsall and the south of Sandwell. Figure 7: Designated Cycle Paths for Wolverhampton and Walsall

Source: iGIS

Figure 8: Designated Cycle Paths for Sandwell and Dudley

Source: iGIS

Travel to work statistics indicate that Walsall residents (7%) and Dudley residents (6.5%) use methods of public transportation at a similar level to the West Midlands (6.5%), whereas the residents of Wolverhampton (9%) and Sandwell (10.7%) are similar to England (11%). Compared to 2001, the residents in Wolverhampton using public transportation has increased by 1.12%, Walsall by 1%, Sandwell by 0.9%, Dudley by 0.1%, West Midlands has stayed the same and England has increased by 1.6%41. These statistics also show that a substantially higher proportion of all residents in the UK travel by private transport, inclusive of driving a car, van, motorcycle or as a passenger in the former. In 2011, Wolverhampton’s residents using private transportation was at 39.6%, Walsall at 43%, Sandwell at 39.8%, Dudley at 47.8%, West Midlands at 45.8% and England at 40.7%. Since 2001, the use of private transportation in Wolverhampton has increased by 0.39% which is substantially less than in England at +1.5%. Sandwell is at +3.6% and Dudley at +2.4% which are more in line with West Midlands at +3.8%. The increase for Walsall residents is significantly higher at +6.3%.

Data from the 2001 Census revealed that the majority of residents in the Black Country as a whole travel up to 10km to work. It is recognised that out-commuting by the resident population occurs on a daily basis for employment reasons42.

The West Midlands Local Transport Plan (2006) objectives are:

Æ To improve safety; Æ To promote accessibility; Æ To contribute to an efficient economy; and Æ To promote integration and to protect the environment.

The Local Transport Plan aims to provide greater choices for all residents to access the services and facilities they need. Improving travel choice will bring about a change in people’s travel habits, signalling a shift away from reliance on the private car, particularly in terms of single occupancy car use, in favour of more sustainable modes.

CULTURAL HERITAGE

The following baseline indicators have been used to characterise the cultural heritage baseline:

Æ Number and distribution of Listed Buildings, Scheduled Monuments, Conservation Areas and Registered Parks and Gardens (iGIS, www.magic.gov.uk, Historic Environment website); Æ Eligible open spaces managed to Green Flag standards (The Black Country LA AMRs); and Æ Historic Landscape Characterisation (Black Country Historic Landscape Characterisation).

Table 7 shows the number of Listed Buildings, Scheduled Monuments, Conservation Areas and Registered Parks and Gardens within the Black Country, which has a range of cultural heritage assets.

41 Office for National Statistics 42 Office for National Statistics

Table 7: Summary of cultural heritage assets in the Black Country

BOROUGH LISTED BUILDINGS SCHEDULED MONUMENTS CONSERVATION AREAS REGISTERED PARKS AND GARDENS Wolverhampton43 429 4 30 2 Walsall44 155 5 18 3 Sandwell45 195 9 9 4 Dudley46 344 11 22 2

Figure 9: Scheduled Monuments and Listed Buildings in the Black Country

Source: iGIS

43 http://www.wolverhampton.gov.uk/home 44 https://www.walsall.gov.uk/ 45 http://www.sandwell.gov.uk/ 46 http://www.dudley.gov.uk/

The Scheduled Monuments in Wolverhampton are fairly interspersed across the city and consist of Lady Godiva's churchyard cross in St Bartholomew's churchyard, Churchyard cross in St Bartholomew's churchyard, Cross in St Mary’s churchyard and Anglian cross 25m south of St Peter's Collegiate Church. Walsall Scheduled Monuments are more central and north of the area and consist of Hillfort known as The Castle Fort at Castlebank Plantation, Cross in All Saints churchyard, Medieval fortified house at Rushall Hall, Hlaew 12m north west of Rushall Hall and Moated site, 15m south of Moat Farm. The Scheduled Monuments in Sandwell are situated to the east of the borough and consist of a Benedictine monastery, Chances Glassworks, Smeaton’s Summit Bridge, Engine Arm Aquaduct, Smethwich Engine House and the Remains of the Boulton and Watt Soho foundry and mint. The larger of the Scheduled Monuments situated in Dudley are to the north of the borough, although there are also a couple around the southern boundary. The Scheduled Monuments in Dudley consist of and associated water control features, Wychbury Ring, The Redhouse Whitehouse and Newhouse glassworks, Coal mining remains at Saltwells Wood, Medieval settlement at Cooper’s Bank Farm, St James’ Priory, Lime working remains in Dudley and Dudley Castle.

Conservation areas within the Black Country are fairly scattered. In Wolverhampton the majority lie to the centre and west of the city with a few to the east. In Walsall they are scattered throughout the area. Sandwell has fewer conservation areas with the majority situated in the east of the borough. Dudley’s conservation areas are more interspersed across the borough with a slightly larger cluster to the west.

The majority of Registered Parks and Gardens are clustered to the centre of the Black Country, the largest being to the south of Walsall – Hall. A small number are located towards to the boundaries of the Black Country.

The Civic Trust and DCLG administer the Green Flag Award, given for the quality and management of parks and other public open spaces. Despite its predominantly urban character area Sandwell has many areas of open space which includes seven award winning green flag parks and approximately 820ha of Green Belt, which contribute to its environmental quality and attractiveness47. During the monitoring period 1st April 2011 to 31st March 2012, The Green Flag Award Scheme has been awarded to 3 separate parks within the Dudley borough, notably Silver Jubilee Park in Coseley, Netherton Park and The Leasowes Historic Park in Halesowen48. Palfrey Park and Willenhall Memorial Park in Walsall are green flag parks, with an award for atleast 6 years49. No information is available for Wolverhampton.

In addition to the designated built heritage resource it is also important to recognise the historic character of the landscape in the Black Country. In 2009, the Black Country Historic Landscape Characterisation (HLC) project50 took place, which aims to be a tool in understanding the landscape as it exists today, by placing it firmly in a context of the historical development of its constituent parts, in order to assist the sensitive management of the built environment in the future. The result of this process was the division of the district into 15 Historic Character Areas, each of which has a similar landscape history and evolution as well as geographical characteristics.

47 Sandwell AMR 2012 48 Dudley AMR 2012 49 Walsall Council 50 http://archaeologydataservice.ac.uk/archieves/view/blackcountry_hlc_2009/

LANDSCAPE

The following baseline indicators have been used to characterise the existing conditions:

Æ Distribution and area of National Parks and Areas of Outstanding Natural Beauty (AONB) (www.magic.gov.uk and iGIS); and Æ Landscape Character (iGIS).

There are no AONB’s in the Black Country. The nearest one is Cannock Chase which borders the Walsall boundary. No National Parks are located within the Black Country boundaries.

The majority of the Black Country lies within Cannock Chase and Cank Wood character area, Natural England Character Area 67. A small area of the south of the Sandwell borough and the south east of the Dudley borough lies within the Arden character area, Natural England Character Area 97. The west of the Wolverhampton city area and the south west of the Dudley borough lie within Mid Severn Sandstone Plateau character area, Natural England Character Area 66.

According to the Black Country Core Strategy Scoping Report, the Black Country contains a wealth of historic landscapes which, without heritage-led regeneration, are at risk of losing their identities due to replacement of historic buildings with modern architecture51.

51 http://blackcountrycorestrategy.dudley.gov.uk/evidencesa/sa/

Appendix C

SCOPING COMMENTS

CONSULTEE COMMENT RESPONSE The SEA scoping report references the EU Water Framework Directive (WFD) which is good to see. Any schemes within the LFRMS should be assessed against their impact on WFD and identify mitigation measures. Schemes should consider the relevant River Basin Management Plan and identify opportunities for restoration and enhancement of water bodies to prevent the Æ Noted deterioration and promote recovery of water bodies. The opportunity for creating priority habitat should be a material consideration within a scheme Consultation Question (c) Do you consider that the structure of the report is appropriate? The scoping report should not just see WFD as a measure of water quality but also as ecological health, making sure that the Æ Noted impact on riverine habitat is considered as well. We would expect to see links made between the Biodiversity, Fauna & Flora sections and the Water section of the report. Are there any key emerging plans, initiatives & sustainability objectives that should be identified as part of the assessment process? Æ Trent Catchment Flood Management Plan Æ Included Æ Severn Catchment Flood Management Plan Æ Included Æ Humber River Basin Management Plan Æ Included Æ Severn River Basin Management Plan Æ Included Environment Agency Æ Humber Flood Risk Management Plan Æ Updated Æ Severn Flood Risk Management Plan Æ Updated Æ River Tame Flood Risk Management Strategy Æ Updated

The second cycle of the river basin management planning will be published in late 2015 and will provide new baseline data for WFD water bodies on which to work on instead of the current 2009 baseline. The development of the LFRMS should recognise Æ Noted within the this and look to use the 2015 baseline and objectives on which to assess schemes against as well as looking for opportunities to LFRMS. improve water body status. Both the Humber and the Severn River Basin Management Plans are relevant for the Black Country LFRMS. Can you recommend any important sources to supplement the baseline data we are collating, that will inform the assessment process? The Environment Agency holds monitoring data for the rivers in the Black county which includes ecological (fish, invertebrates & Æ Included macrophyte surveys) as well as chemical data which are used to determine WFD classifications of watercourses. This data could be used to provide a baseline for the LFRMS and associated schemes and to monitor any improvements or deteriorations of water courses.

Æ Increase in flood risk may, in some cases, be beneficial to habitats and species. Æ Noted Æ Control of surface water runoff can reduce flood risk as well as improve water quality. Æ Noted

CONSULTEE COMMENT RESPONSE Æ Use of SuDS – retrofitting to existing developments can also be beneficial. Æ Included Æ The Biodiversity, Flora and Fauna section should consider any change of hydrology at a site, not just an increase in flooding. Æ Included E.g. A decrease in flooding frequency as a result of a flood risk scheme at a site valuable for flood plain meadows could change the nature conservation value of the site. Æ As mentioned above, there needs to be a link made between the water and the biodiversity section as good habitat and Æ Updated riverine structure benefits biodiversity and water quality.

Water: Æ The Environment Agency advises on fluvial (river) flooding. Lead Local Flood Authorities (LLFAs) advise on surface water Æ Noted flooding. Æ Updated Æ The LFRMS should promote working with natural processes and the avoidance and opening up of culverts. Æ Noted within the Æ The LFRMS should have an objective to manage flood risk and drainage of new development so that no new flood risk is LFRMS created and, wherever possible, any opportunities to reduce flood risk are taken.

It would be of benefit to look at existing indicators already collected by the local authorities. For the biodiversity section the number of local wildlife sites in positive management could be used. We’d also recommend that the WFD data is utilised and that the strategy looks to positively contribute towards the achievement of WFD objectives. Æ Included

Appendix A Æ Updated Æ Suggest that include reference to the Floods Directive and the Flood Risk Regulations 2009.

Æ The Flood Risk Regulations transpose the EU Floods Directive into law in England and Wales. The EU Floods Directive aims to provide a consistent approach to flood risk management across all of Europe. Æ Under the Flood Risk Regulations 2009 the Environment Agency and LLFAs had to prepare preliminary flood risk assessments by December 2011. Completed by LLFAs, these PRFAs are published by the Environment Agency. Æ There is also a duty on LLFAs with an agreed Flood Risk Area to publish flood hazard and flood risk maps for all sources of flooding by December 2013 and flood risk management plans by December 2015. These flood risk management plans should set objectives for flood risk management and outline measures for achieving these objectives. Æ Updated Æ Flood Risk Management Plans for both the Humber and Severn River Basin Districts will be published by the Environment Agency in December 2015. Æ The West Midlands Flood Risk Area, which includes a large part of the Black Country, is included in the Humber Flood Risk Management Plan.

CONSULTEE COMMENT RESPONSE Appendix B Water nd Æ 2 paragraph – The majority of the Black Country drains into the River Trent via the River Tame Æ Updated rd Æ 3 paragraph – there seems to be some confusion between rivers and canals. Canals are overseen by the Canal and River Æ Updated Trust not the Environment Agency.

Paragraph 3.2.7states what will happen in the event of uncertain effects being identified. Historic England consider that identifying effects as ‘uncertain’ should be avoided as it will not be possible for avoidance or mitigation measures to be incorporated into the Local Flood Risk Management Strategy and harm to heritage assets could then occur in the implementation Æ Noted stages. All efforts should be taken to ascertain what effects may occur and how they can be overcome.

Æ Paragraph 4.4 we support the reference to the need to protect and enhance the historic environment, as a key issue. Æ Noted

Table 5.1 we suggest the following amendments – Cultural Heritage Æ The settings of cultural heritage features the significance of heritage assets, including their settings should be considered Æ Updated and preserved protected and enhanced. Æ Updated Æ There may be opportunities to reduce flood risk to specific heritage features. Opportunities should be sought to reduce flood

risk to specific heritage assets. Æ Added Æ Consideration should be given to the impacts of flood alleviation measures on the historic environment and heritage assets should be protected and conserved. Historic England Landscape Æ It is essential that landscape character and quality is protected and enhanced. Æ Updated

Æ Table 6.1, clause 3 – To protect and enhance historic assets heritage assets and their settings, and also historic Æ Updated landscape/townscape value.

Æ Appendix A – National Plans – we recommend that you include a reference to the recently adopted Good Practice Advice Æ Updated Notes 1, 2 and 3 that are available on Historic England’s website and would be relevant here.

Æ We would also encourage that the SEA process has regard to Historic England’s advice on SEA and the historic environment. https://historicengland.org.uk/images-books/publications/strategic-environ-assessment-sustainability-appraisal- Æ Noted historic-environment/

In relation to ‘local plans’ we recommend that you consult each local authority and specifically their historic environment staff to Æ Included ascertain which plans may be relevant. Evidence base relating to Historic Landscape Characterisation and Conservation Area

CONSULTEE COMMENT RESPONSE Appraisals as examples, may be of relevance.

Æ Appendix B – Baseline - with regards to baseline information for the section on Cultural Heritage we would recommend that Æ At this strategic you liaise with historic environment staff at each authority. We would recommend including information about locally listed level, such heritage assets as well as information relating to non-designated archaeology, of which information should be contained on consultation has not the Historic Environment Record, per authority. Additionally, we recommend using the Heritage at Risk register and been undertaken. considering whether there are any heritage assets at risk as a result of flooding issues, where this particular strategy may be However relevant able to address these at risk issues. consultees will be engaged during the consultation process. Æ No Heritage at Risk due to flooding.

Æ The description of heritage assets under Figure 9 is welcome. It would be useful to include a reference to local flood issues Æ Not deemed within the context of the historic environment and what the current issues are. appropriate at this high level stage.

Æ Under the Landscape heading we consider it would be beneficial to include information from the Historic Landscape Æ Incorporated and Character report. Considered

Appendix D

LFRMS MEASURES AND ACTIONS

MEASURE(S) ACTION(S)

Objective 1 - Understanding and communicating flood risk in the Black Country

1A Develop a Flood Risk Management Æ Align aims, objectives and outcomes of the Humber and Severn RBMP with the Local Flood Risk Management Strategy and Plan for the West Midlands Cluster other relevant policies, strategies and procedures. Æ Undertake further assessment of local flood risk with detailed hydraulic modelling where appropriate. Æ Identification of flood hotspot areas where flood risk management solutions could be developed. Æ Ensure that local authority planning and development strategies, development plans, Area Action Plans and Supplementary Planning Polices are aligned with the Black Country LFRMS

1B Investigate locally significant incidents Æ Undertake flood investigations in line with Flood Investigation procedures. of flooding identifying sources and remedial actions with partners Æ Publish the results of flood investigations on local authority websites. Æ Incorporate all locally significant and other flood risk incidents into a GIS database.

1C Review and update the Preliminary Æ Black Country LLFA’s complete review of the Dudley PFRA. Flood Risk Assessments for the Black Country Æ Black Country LLFA’s complete review of the Sandwell PFRA. Æ Black Country LLFA’s complete review of the Walsall PFRA. Æ Black Country LLFA’s complete review of the Wolverhampton PFRA.

1D Develop and continue to maintain a Æ Develop a GIS based register of structures, with details of ownership, state of repair, and the designation of such structures or register of flood risk management assets features which may affect flood risk. Æ Develop a procedure for review and update of the asset register.

1E Engage with local communities to gain Æ Key stakeholder workshops. information of flood risk issues

1F Share knowledge and information on Æ Develop the relevant sections of the local authorities’ websites to provide clear advice and guidance on flood risk and local flood risk with the residents of the associated issues. Black Country

1G Ensure latest information is used in Æ Adopt the latest version of the Environment Agency’s Risk of Flooding form Surface Water mapping as the locally agreed assessing local flood risk. surface water flood risk information.

Objective 2 – Managing the likelihood and impacts of flooding

MEASURE(S) ACTION(S)

2A Work with partners to reduce the Æ Formalise relationships with the EA and Severn Trent Water, and take opportunities for collaborative and partnership working. impacts of flooding by targeting and prioritising maintenance at high risk Æ Develop a multi-agency preparedness plan to respond to flood events under the West Midlands Conurbation Local Resilience locations and assets, enabling an efficient Forum. response to, and recovery from, flooding Æ Prepare a Pre Flood Action Plan activated by Met Office weather warning alerts. Once activated officers to inspect high risk incidents. assets and arrange emergency works if possible in time available.

2B Develop flood risk management Æ Develop a programme of flood mitigation schemes and initiatives which are likely to be funded through the National schemes led by the Black Country Programme or Local Levy. authorities, seeking to make best use of available funding Æ Identify and maximise all other funding sources including CIL, Council, partners and other external organisations, and maximise match-funding.

2C Work with partners to develop flood risk Æ Make available council funds and services where appropriate to provide partnership contributions to flood risk management management schemes led by third parties, schemes. riparian landowners and stakeholders.

2D Work to ensure ongoing management Æ Develop an affordable and suitable flood asset maintenance regime based on risk. Target and prioritise inspections and of existing flood risk and drainage assets. maintenance to high flood risk locations. Æ Preparation of a pre flood action plan identifying inspections and works required at critical locations.

2E Work to ensure compliance of all Local Æ Produce on-site and off-site reservoir safety plans for reservoirs owned by local authorities. Authority owned assets with the Reservoirs Act

Objective 3 – Helping the Black Country’s citizens to manage their own risk

3A Continue to work with community flood Æ Support and attend local flood forums. groups and other local stakeholders Æ Support and work with community volunteer groups wherever possible. Æ Support community groups in developing local flood risk plans.

3B Work with residents to communicate Æ Raising public awareness of and encouraging sign up to Floodline Warnings. the risks of flooding Æ Provide information about how citizens can minimise flood risk and protect themselves during flooding. Æ Issue guidance to help local communities to protect their home and valuables and understand what to do before a flood, during flooding and afterwards. Æ Provide guidance and assistance to the public on Flood risk insurance matters.

MEASURE(S) ACTION(S)

3C Work with residents and landowners to Æ Provide guidance and information to those living near watercourses that have a responsibility for on-going maintenance educate them with regards to their (Riparian Owners). responsibilities for watercourse management Æ Enforce riparian responsibilities where appropriate.

3D Encourage local involvement in the Æ Give local communities a greater stake in project design and delivery at an early stage of flood risk management schemes. development of flood risk management schemes

3E Encourage residents to share Æ Develop a web-based flood incident reporting tool to allow efficient notification of the relevant LLFA to incidents of flooding. information on flooding incidents

3F Share knowledge and information with Æ Develop a flood risk knowledge and information section on the council’s website providing links to key advisors including the communities and residents EA, the National Flood Forum and LLFA officer contacts.

Objective 4 – Ensuring appropriate development in the Black Country

4A Develop a planning process to create Æ Work with Local Planning Authorities to ensure flood risk and SuDS are properly considered during the planning application clear advice and direction to developers on process. flood risk, drainage and SuDS. Æ LLFA’s to provide statutory consultee response on surface water drainage for major planning applications. Æ Produce developer guidance on the use of SuDS in the Black Country to be available on the local authorities’ websites. Æ Develop a SuDS Handbook for the Black Country. Æ Develop a policy on Urban Creep to ensure it is accounted for in new developments.

4B Undertake consenting activities for Æ Develop a consenting and approval process with accompanying guidance for work to ordinary watercourses. ordinary watercourses Æ Make ordinary watercourse consenting guidance available on local authorities’ websites.

4C Promote the use of Sustainable Æ Ensure that developers make necessary contributions to the cost of SuDS and flood risk management activities through Drainage Systems in new development Section 106 agreements and/or the Community Infrastructure Levy. Æ Undertake the LLFA’s statutory consultee role on new major developments. Æ Develop SuDS handbook for the Black Country.

4D Ensure compliance with Black Country Æ Include specific requirements in the SuDs developer guidance and SuDS Handbook. Core Strategy (ENV5 Flood Risk) principals and objectives

MEASURE(S) ACTION(S)

Objective 5 – Improving flood prediction, warning and post flood recovery

5A Work with partners to minimise the Æ Develop recovery contingency plans in case the local area is impacted by flooding (including business and economic recovery). recovery time for residents and businesses from flooding events

5B Establish a co-ordinated approach to Æ Develop a co-ordinated approach to the supply of sandbags across the Black Country. the provision of temporary flood risk management measures. Æ Explore the potential for the use of alternatives to sandbags for provision of temporary flood defences.

5C Work with partners to improve Æ Incorporate council emergency contact numbers in community flood plans. communications and advice given during flooding events. Æ Make appropriate use of social media to give advice during flood events. Æ Make use of alerts and news updates in the council’s websites to give advice during flood events.

5D Work with partners to understand Æ Monitor rainfall and flow conditions in smaller catchments to enable flooding trigger levels to be established. trigger levels for local flooding events and develop local flood warning systems Æ Work with local communities to establish local flood warning systems.

Objective 6 – Work in partnership with others to deliver the local strategy

6A Engage in regional networks for sharing Æ Learning best practice and sharing experiences through the EA Network Meetings. of knowledge and best practice. Æ Continue with Black Country collaborative work.

6B Improve the mechanisms of sharing of Æ Develop strategy for flood risk data and information sharing for officers, partners, stakeholders and the public. data and information between partners.

6C Engage with neighbouring LLFAs to Æ Formalise engagement process with neighbouring LLFAs with quarterly meetings. facilitate a catchment based approach

6D Continue to engage with flood action Æ Formalise engagement process with flood action grounds through bi-annual meetings. groups and other community groups in the delivery of local flood risk management

Appendix E

ASSESSMENT OF THE LFRMS

Key to Matrices Potential major positive effect ++ Potential minor positive effect + No negligible effect 0 Potential minor negative effect - Potential major negative effect - - Uncertain Impact – more information required ?

Objective 1 Understanding and communicating flood risk in the Black Country

SEA OBJECTIVES SCORE COMMENTARY Engaging with key members of the community through workshops to gain information on flood risk issues, preparing such plans as the PFRA and LFRMS and developing the Flood Risk Management Plan for the West 1 To protect and Midlands Cluster is likely to have a positive impact on protecting and enhance human health, ++ enhancing human health, safety and wellbeing. safety and wellbeing The Flood Risk Management Plan will include identification of flood hotspot areas where flood risk management solutions could be developed, potentially leading to reduction in flooding and subsequently reducing risk to human health. 2 To protect and Measures set out in the LFRMS around improving knowledge and enhance biodiversity, understanding of local sources of flood risk are unlikely to have an effect on key habitats and 0 biodiversity. species 3 To protect and Measures set out in the LFRMS around improving knowledge and enhance the historic understanding of local sources of flood risk are unlikely to have an effect on environment and 0 the historic environment and heritage assets. heritage assets 4 To protect and Measures set out in the LFRMS around improving knowledge and enhance landscape and understanding of local sources of flood risk are unlikely to have an effect on townscape character 0 landscape and townscape. and quality 5 To maintain and improve the quality and Measures set out in the LFRMS around improving the understanding and quantity of the communication of flood risk in the Black Country are unlikely to have an Borough’s surface water 0 effect on maintaining and improving the quality and quantity of the Black environment and Country’s surface water environmental and groundwater resources. groundwater resource A better understanding of flood risk may enable the Black Country Local 6 To limit and adapt to Authorities to better inform residents of potential flood events which may climate change + benefit adaptation to climate change in the long term. 7 To ensure the Measures set out in the LFRMS around improving the understanding and sustainable use of 0 communication of flood risk in the Black Country are unlikely to have an natural resources effect on the sustainable use of natural resources.

Objective 2 Managing the likelihood and impacts of flooding

SEA OBJECTIVES SCORE COMMENTARY The measures set out in the LFRMS around managing the likelihood and 1 To protect and impacts of flooding, such as producing a Pre Flood Action Plan, SuDS and enhance human health, ++ on-site and off-site reservoir safety plans are likely to have a positive effect safety and wellbeing on protecting and enhancing human health, safety and wellbeing. Mitigating environmental impacts of flood risk management activities 2 To protect and through managing the likelihood and impacts of flooding is likely to have a enhance biodiversity, positive effect on protecting biodiversity, key habitats and species. In key habitats and + addition, the actions would control activities on watercourses that may species result in adverse effects upon biodiversity. 3 To protect and Producing the LFRMS, through provisions such as SuDS, managing and enhance the historic reducing flood risk, and PFRA would help protect the Black Country’s environment and + historic environment and heritage assets from the damaging effects of heritage assets flooding. 4 To protect and Producing the LFRMS, through provisions such as SuDS, managing and enhance landscape and reducing flood risk, and PFRA would help protect the Black Country’s townscape character + historic environment and heritage assets from the damaging effects of and quality flooding. Measures set out in the LFRMS around managing the likelihood and 5 To maintain and impacts of flooding such as the preparation of flood maps for surface water improve the quality and and locally agreed surface water information is likely to have a positive quantity of the impact of maintaining and improving the quality of the Black Country’s Borough’s surface water ++ surface water environment and groundwater resource. In addition, the environment and actions would control activities on watercourses that may result in adverse groundwater resource effects upon water resources. Measures set out in the LFRMS around managing the likelihood and 6 To limit and adapt to impacts of flooding such as the preparation of flood maps for surface water climate change + and locally agreed surface water information is likely to have a positive impact on adapting to climate change. 7 To ensure the Measures set out in the LFRMS around Managing the likelihood and sustainable use of 0 impacts of flooding are unlikely to have an effect on ensuring the natural resources sustainable use of natural resources.

Objective 3 Helping the Black Country’s citizens to manage their own risk

SEA OBJECTIVES SCORE COMMENTARY Engaging with key members of the community to gain information on flood 1 To protect and risk issues and preparing such plans as PFRA, LFRMS and providing enhance human health, + information about how citizens can minimise flood risk and protect safety and wellbeing themselves during flooding is likely to have a positive impact on protecting and enhancing human health, safety and wellbeing. 2 To protect and Measures set out in the LFRMS around helping the Black Country’s citizens enhance biodiversity, to manage their own risk are unlikely to have an effect on protecting and key habitats and 0 enhancing biodiversity, key habitats and species. species 3 To protect and Measures set out in the LFRMS around helping the Black Country’s citizens enhance the historic to manage their own risk are unlikely to have an effect on protecting and environment and 0 enhancing the historic environment and heritage assets. heritage assets 4 To protect and Measures set out in the LFRMS around helping the Black Country’s citizens enhance landscape and to manage their own risk are unlikely to have an effect on protecting and townscape character 0 enhancing landscape and townscape character and quality. and quality 5 To maintain and Engaging with key members of the community to gain information on flood improve the quality and risk issues and preparing such plans as PFRA, LFRMS and developing the quantity of the Flood Risk Management Plan for the West Midlands Cluster is likely to Borough’s surface water + have a positive impact on maintaining and improving the quality and environment and quantity of the Black Country’s surface water environment and groundwater groundwater resource resources. Preparing the public to better prepare their properties against future flood 6 To limit and adapt to events would help them to adapt to future flooding events associated with climate change + climate change.

7 To ensure the Measures set out in the LFRMS around helping the Black Country’s citizens sustainable use of 0 to manage their own risk are unlikely to have an effect on ensuring the natural resources sustainable use of natural resources.

Objective 4 Ensuring appropriate development in the Black Country

SEA OBJECTIVES SCORE COMMENTARY Complying with the Black Country’s Local Authorities Local Plan’s 1 To protect and principles and objectives for mitigating flood risk and improving the water enhance human health, + environment is likely to have a positive impact on protecting and enhancing safety and wellbeing human health, safety and wellbeing. 2 To protect and Encouraging the use of SuDS in developments and ensuring that enhance biodiversity, developers make necessary contributions to the cost of SuDS and flood key habitats and + risk management activities are likely to have a positive impact on protecting species biodiversity, key habitats and species. 3 To protect and Encouraging the use of SuDS in developments and ensuring that enhance the historic developers make necessary contributions to the cost of SuDS and flood environment and + risk management activities are likely to have a positive impact on protecting heritage assets heritage assets. 4 To protect and enhance landscape and Guarding against inappropriate development would preserve landscape townscape character + and townscape in the long term. and quality 5 To maintain and improve the quality and Using available information on flood risk to identify appropriate quantity of the development potential and steer growth towards suitable areas will have a Borough’s surface water ++ positive impact on maintaining and improving the quality and quantity of the environment and Black Country’s surface water environment and groundwater resources. groundwater resource 6 To limit and adapt to FRAs and indicative flood risk maps take into account climate change and climate change ++ are a key aspect when new development is cited. Encouraging the use of SuDS in developments and ensuring that 7 To ensure the developers make necessary contributions to the cost of SuDS and flood sustainable use of + risk management activities are likely to have a positive impact on protecting natural resources natural resources such as soils.

Objective 5 Improving flood prediction, warning and post flood recovery

SEA OBJECTIVES SCORE COMMENTARY Developing recovery contingency plans, raising public awareness, the 1 To protect and implementation of flood mitigation schemes, sandbag provision and using enhance human health, ++ social media to make carry out flooding alerts will have a positive effect on safety and wellbeing human health, safety and wellbeing by getting the public better prepared to protect their properties against flood events. 2 To protect and Measures set out in the LFRMS around improving flood prediction, warning enhance biodiversity, and post-flood recovery are unlikely to have an effect on protecting and key habitats and 0 enhancing biodiversity, key habitats and species. species 3 To protect and With better warning systems in place, there will be more time to put enhance the historic protective measures in to place, such as deploying sandbags and therefore environment and + protecting heritage assets. heritage assets 4 To protect and Measures set out in the LFRMS around improving flood prediction, warning enhance landscape and and post-flood recovery are unlikely to have an effect on protecting and townscape character 0 enhancing the landscape and townscape character and quality. and quality 5 To maintain and improve the quality and quantity of the Post flood recovery plans may help to reduce the risk of pollution to surface Borough’s surface water + and groundwater resources after a flood. environment and groundwater resource Preparing the public to better prepare their properties against future flood 6 To limit and adapt to events would help them to adapt to future flooding events associated with climate change + climate change. 7 To ensure the Measures set out in the LFRMS around improving flood prediction, warning sustainable use of 0 and post-flood recovery are unlikely to have an effect on ensuring the natural resources sustainable use of natural resources.

Objective 6 Work in partnership with others to deliver the local strategy

SEA HEADLINE SCORE COMMENTARY OBJECTIVES 1 To protect and enhance human health, safety and wellbeing 2 To protect and enhance biodiversity, key habitats and species 3 To protect and enhance the historic environment and heritage assets Measures set out in the LFRMS around working in partnership with others are focusing on ensuring that the other direct and indirect actions identified 4 To protect and in the LFRMS are realised. enhance landscape and townscape character 0 Whilst this is a necessary and beneficial aspect of the plan, to attribute and quality significant effects to it would be to risk double counting the benefits of the direct and indirect actions it seeks to deliver as already identified in the 5 To maintain and matrices for objectives 1 – 5. improve the quality and quantity of the Borough’s surface water environment and groundwater resource 6 To limit and adapt to climate change 7 To ensure the sustainable use of natural resources