Policy ENV2 - Historic Character and Local Distinctiveness

Our primary concern is ensuring that the Local Plan is informed by appropriate evidence and that where higher levels of growth are identified and policies and sites proposed, that these are informed by up to date and proportionate evidence. Table 1 on page 18 details the range of evidence base and which areas may need updating. Unfortunately, there is no reference to any historic environment evidence base within this table. What evidence base do the Council's have? Does it need updating? Are there areas missing? If sites are proposed through the Black Country Core Strategy review then we would expect a heritage impact assessment to be undertaken, or similar.

I attach a link below to some relevant advice notes to assist in the preparation of the Black Country Core Strategy Review:

Conservation Principles -

https://historicengland.org.uk/advice/constructive-conservation/conservation-principles/

Good Practice Advice Notes -

https://historicengland.org.uk/advice/planning/planning-system/

Site Allocations Advice Note -

https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/

Page 29 looks at the issue of a Green Belt Review and we would want to ensure that the historic towns purpose of the Green Belt is fully considered.

We would support the inclusion of a specific spatial objective for the historic environment.

Where growth is considered and there are options for amending boundaries to regeneration corridors, creating new sustainable urban extensions, allocating development sites, we would need to ensure that appropriate assessment has been undertaken on how this growth will impact the significance of heritage assets, including their setting. Please see advice notes above and also access Historic England's website for further information.

Question 16 raises the idea of what criteria to consider when choosing sites for development - we would request that the Council's consider what the impacts are for the historic environment and consider sites where there is no negative impact or impacts can be mitigated. There are also opportunities for development to positively enhance and better reveal the significance of heritage assets and we would also request that these opportunities are considered. This point is relevant for all types of development.

We would be happy to offer advice and comment on any proposals to amend Policy ENV2 on the historic environment and we are supportive of the policy being updated in line with national policy and guidance.

Page 66 raises the issue of building density and the need to look at increased density. As a result we would be keen to ensure that the Council's have appropriate design and building heights policies to ensure that there are specific policies to deal with issues that may arise because of increased density of sites.

Where sites are identified for Gypsy, Traveller and Travelling Showpeople, alongside other forms of development, we would expect these to be fully assessed against the potential negative impacts for the historic environment.

Where transport initiatives are proposed we would recommend that these are considered against the impact to the historic environment and that relevant avoidance, mitigation and enhancement measures are included within the Core Strategy.

We are content with the proposed amendment to Policy ENV2. We would recommend that a section is included on Heritage Statements and when they are required.

Historic England is currently preparing some additional advice on preparing minerals plans and the historic environment. We would recommend that the Council's consider all appropriate evidence base to ensure that the proposals are appropriate and compliant with the National Planning Policy Framework. Historic England does also have access to a number of studies that have looked at archaeology and aggregate minerals and we would be happy to share the relevant evidence with you

I write regarding the proposed Review of the Black Country Core Strategy 2017 as I strongly object to to Housing and Industrial Development in the Green Belt.

I oppose all development on designated Green Belt land, but my experience, and intimate knowledge, relates primarily to the Green Belt in close proximity to Halesowen and that separating Halesowen from Stourbridge. This includes countryside to the South of A456; that countryside at Lutley, Foxcote and around Wychbury Hill; the Green Belt that links to the countryside to the south via the line of the the Lapal Canal and includes The Leasowes and Coombeswood 'Wedge'.

You do not ask for a detailed representation, but I list some pertinent issues:

1. The Green Belt area that I have broadly defined is of exceptional quality in terms of history; landscape quality; character; nature conservation; informal recreation and it is an important component in the visual envelope of the wider countryside, including the Clent Hills and beyond, within Worcestershire. The character and qualities have been shaped by nature, farming and earlier owners, including the Premonstratensian Cannons of Halesowen Abbey; Viscount Cobham of Hagley Hall; Lord Dudley of the Grange; William Shenstone of The Leasowes; and the Canons of Wolverhampton. Much of the area has been identified by Dudley Council as a 'Landscape Heritage Area'. There are many recorded finds of archaeological significance on the lands of the former monastery, dating as far back as the Iron Age. Manor Farm, the site of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance, has the highest density of Public Rights of Way in Dudley Borough, reflecting its monastic importance, with paths from all directions leading to the Abbey. There are 'Green Lanes' of mediaeval origin. The area is extremely important with defendable Green Belt boundaries and the Lutley/Foxcote countryside, prevents major areas of Halesowen from coalescing with Stourbridge.

2. The 'Black Country Core Strategy', adopted in February 2011, recognises sufficient land for housing and industry to the year 2026, without development in the Green Belt.

3. Under 'Sustainability', the adopted Core Strategy states, 'Brownfield First [for development] - Ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised over greenfield sites" It is considered that there are many more opportunities for redevelopment of sites than the Councils appear to have recognised in coming to their 'Review' conclusions. For instance, in Halesowen Town alone, 'windfall' sites for future housing include the former Law Courts; the defunct Police Station and the former Council House. It is premature to seek Green Belts sites at this juncture.

4. Under 'Spatial Objectives' the adopted Core Strategy promises an 'high quality environment' which "will protect and enhance the unique biodiversity and geodiversity of the Black Country .... ..... ..... whilst valuing its local character.' This is true of the contribution that the specific Green Belt locations listed above provide.

5. Policy CSP2 of the approved Strategy of 2011, states it will provide, 'A strong Green Belt to promote urban renaissance within the urban area and provide easy access to the countryside for urban residents where the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible.' Policy CSP2 then goes on to state that, 'Green Belt boundaries will be maintained and protected from inappropriate development'. These principles should be upheld in the present circumstances.

6. Proposals to fundamentally modify the adopted Strategy of 2011 by building houses and industry in the Green Belt, would be contrary to environmental policy, ENV2 - Historic Character and Local Distinctiveness, and ENV6 - Open Space, Sport and Recreation.

7. The Urban Regeneration Strategy deployed in the approved plan of 2011, works and encourages the redevelopment of more difficult sites for housing and industry by preventing development in the Green Belt and on other greenfield sites. This is good for the environment in all aspects. Releasing Green Belt now will be a failure to direct development attention where it is necessary and desirable. Failure to continue to follow the regeneration strategy will result in unnecessary loss of countryside; will undermine public confidence in the Green Belt and will cause irreversible environmental damage.

8. The obvious corollary of releasing Green Belt now is that the process of Green Belt release will be perpetual for future development. It is not accepted that we need to start that process at this juncture. The 'Review' proposals undermine the principle of Green Belts and are a retrograde step.

I write regarding the proposed Review of the Black Country Core Strategy 2017 as I strongly object to to Housing and Industrial Development in the Green Belt.

I oppose all development on designated Green Belt land, but my experience, and intimate knowledge, relates primarily to the Green Belt in close proximity to Halesowen and that separating Halesowen from Stourbridge. This includes countryside to the South of A456; that countryside at Lutley, Foxcote and around Wychbury Hill; the Green Belt that links to the countryside to the south via the line of the the Lapal Canal and includes The Leasowes and Coombeswood 'Wedge'.

You do not ask for a detailed representation, but I list some pertinent issues:

1. The Green Belt area that I have broadly defined is of exceptional quality in terms of history; landscape quality; character; nature conservation; informal recreation and it is an important component in the visual envelope of the wider countryside, including the Clent Hills and beyond, within Worcestershire. The character and qualities have been shaped by nature, farming and earlier owners, including the Premonstratensian Cannons of Halesowen Abbey; Viscount Cobham of Hagley Hall; Lord Dudley of the Grange; William Shenstone of The Leasowes; and the Canons of Wolverhampton. Much of the area has been identified by Dudley Council as a 'Landscape Heritage Area'. There are many recorded finds of archaeological significance on the lands of the former monastery, dating as far back as the Iron Age. Manor Farm, the site of Halesowen Abbey, which is a Scheduled Ancient Monument of National Importance, has the highest density of Public Rights of Way in Dudley Borough, reflecting its monastic importance, with paths from all directions leading to the Abbey. There are 'Green Lanes' of mediaeval origin. The area is extremely important with defendable Green Belt boundaries and the Lutley/Foxcote countryside, prevents major areas of Halesowen from coalescing with Stourbridge.

2. The 'Black Country Core Strategy', adopted in February 2011, recognises sufficient land for housing and industry to the year 2026, without development in the Green Belt.

3. Under 'Sustainability', the adopted Core Strategy states, 'Brownfield First [for development] - Ensuring that previously developed land, particularly where vacant, derelict or underused, is prioritised over greenfield sites" It is considered that there are many more opportunities for redevelopment of sites than the Councils appear to have recognised in coming to their 'Review' conclusions. For instance, in Halesowen Town alone, 'windfall' sites for future housing include the former Law Courts; the defunct Police Station and the former Council House. It is premature to seek Green Belts sites at this juncture.

4. Under 'Spatial Objectives' the adopted Core Strategy promises an 'high quality environment' which "will protect and enhance the unique biodiversity and geodiversity of the Black Country .... ..... ..... whilst valuing its local character.' This is true of the contribution that the specific Green Belt locations listed above provide.

5. Policy CSP2 of the approved Strategy of 2011, states it will provide, 'A strong Green Belt to promote urban renaissance within the urban area and provide easy access to the countryside for urban residents where the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible.' Policy CSP2 then goes on to state that, 'Green Belt boundaries will be maintained and protected from inappropriate development'. These principles should be upheld in the present circumstances.

6. Proposals to fundamentally modify the adopted Strategy of 2011 by building houses and industry in the Green Belt, would be contrary to environmental policy, ENV2 - Historic Character and Local Distinctiveness, and ENV6 - Open Space, Sport and Recreation.

7. The Urban Regeneration Strategy deployed in the approved plan of 2011, works and encourages the redevelopment of more difficult sites for housing and industry by preventing development in the Green Belt and on other greenfield sites. This is good for the environment in all aspects. Releasing Green Belt now will be a failure to direct development attention where it is necessary and desirable. Failure to continue to follow the regeneration strategy will result in unnecessary loss of countryside; will undermine public confidence in the Green Belt and will cause irreversible environmental damage.

8. The obvious corollary of releasing Green Belt now is that the process of Green Belt release will be perpetual for future development. It is not accepted that we need to start that process at this juncture. The 'Review' proposals undermine the principle of Green Belts and are a retrograde step.

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills

6. Archaeology and Cultural Heritage


6.1 Introduction


6.1.1 Pegasus Group has produced a heritage appraisal on behalf of Gallagher Estates, which provides a high-level assessment of potential heritage issues which could constrain the development at Home Farm, Sandhills.

6.1.2 This appraisal will identify designated heritage assets within and in the vicinity of the proposed site. Where appropriate, non-designated assets will be identified. It will provide an initial assessment of the significance which will also include assessing whether the proposed development site contributes towards the significance of the assets through setting. The appraisal will conclude with a statement of whether the heritage may present a key constraint to development.

Designated Assets


6.1.3 Within a 1km search area from the site boundary there are four Listed Buildings, all at grade II and one Scheduled Monument. These are shown on Figure 6.1 below.



Figure 6.1 Location of listed buildings (scheduled monument located to the south)

N.B- Figure 6.1 has not been uploaded as full text please refer to the attachment.

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills

6.1.4 The Listed Buildings are:
* The Wyrley and Essington Canal Anglesey Branch Railway Aqueduct - 1077180 - 0.?km north-northwest of the site boundary;

* Wyrley and Essington Canal Footbridge at Ogley Junction - 1087076 - 0.2km north of the site boundary;

* Sandhills Pumping Station - 1421472 - 0.25km east of site boundary; and

* Fighting Cocks Farmhouse - 1374262 - 0.6km southeast of the site boundary.

6.1.5 The Scheduled Monument is Hillfort known as The Castle Fort at Castlebank Plantation (1017244) located 1km south of the site boundary. The majority of this asset is located beyond the 1km boundary, extending south towards Castlehill Road.

6.1.6 There are no Registered Parks and Gardens, Registered Battlefields, Conservation Areas or Wor ld Heritage Sites within the site, study area or in close proximity.

6.1.7 The Wyrley and Essington Canal Anglesey Branch Railway Aqueduct is located to the north of the proposed site boundary. It is an aqueduct carrying the Anglesey branch of the Wyrley and Essington Canal over the South Staffordshire Railway. The Canal was originally built in 1797 widened and made navigable in 1850,with the railway built in 1849. This aqueduct was constructed in 1856. The aqueduct was constructed by localengineers, Lloyds, Foster and Co from Wednesbury .

6.1.8 The significance of this asset lies primarily in its architectural and historic value. It is evidence of the emergence of the modern transport networks of both canal and railway. It provides evidence of the engineering skill of the area which came to prominence in the 19th-century. It also provides evidence of the growth in prosperity of the area in the industrial period, aided by the construction of
transportation networks.


6.1.9 The setting of this asset is provided by the railway and the canal, both of which provide the reason for the construction of the asset. The setting is also formed by the remainder of the canal, but with diminishing contributions to significance the greater the distance from the asset.

6.1.10 The site does not form part of the setting of the asset. Although located adjacent to a branch of the canal, there were numerous branches of the canal along its length and the site does not contribute to the significance and understanding of this asset. Therefore , development within this area would not result in any harm to the significance of this heritage asset.

6.1.11 The Wyrley and Essington canal Footbridge at Ogley Junction is located to the north of the proposed development. The footbridge carries the towpath of the Anglesey Branch over disused Ogley locks







T e c h n i c a I C o m p e n d i u m IHome Farm, Sandhills

section of the main canal which was closed in 1954. The bridge was constructed in 1829 and is of cast iron with brick abutments. It was constructed by Horsley Iron Works.

6.1.12 The significance of this asset lies in its historic and architectural value. It is constructed from cast iron, like a number of the other structures along the canal, lending it an aesthetic coherence and tying it into the contemporary industrial landscape. The historic value lies in the information it provides for the development of the canal system and the rise in industrial activity in this area in the 19th-century.

6.1.13 The setting of the asset is formed by the canal and the towpath. These provide the reason for the construction of the asset. There is some connection with the rest of the canal network however the contribution this makes to the significance of the asset diminishes the further away from the asset the canal reaches.

6.1.14 The site does not form part of the setting of the asset. Although another branch line of the canal does cut across the site, the site does not contribute towards the significance or understanding of the asset. If the canal arm crossing the site was still extant, the contribution would be greater, but it no longer is. Change within the site would create change within the immediate surrounds of the asset, but would not cause any harm.

6.1.15 The Sandhills Pumping Station is a water pumping station built in 1935 by F. J . Dixon for the South Staffordshire Waterworks Company and was constructed by Thomas Lowe and Sons Ltd. It was constructed in response to the growing population of South Staffordshire and the increased demand for a clean water supply. Sandhills Pumping Station was constructed in a stripped-classical style and pumps water via two boreholes. The original pumping engine has been replaced but the machinery is still in use today.

6.1.16 The significance of this asset lies in its architectural and historic value. It is a good quality design and example of an inter-war pumping station. Although the machinery is lost, the fabric of the building has seen little change and the purpose is still legible. It has historic value in the information it provides for the social history of the area.

6.1.17 The setting of this asset is its location. It was placed to take advantage of the water table and proximity to settlements. There is no connection with the site and the site does not form part of its setting. Change within the site resulting from the development will not cause any harm to the significance of the asset.

6.1. 18 Fighting Cocks Farmhouse is a late 18th-century farmhouse, of typical L-shaped plan. The name of the farmhouse suggests it may have been the site of cock-fighting in the post-medieval periods.

6.1.19 The significance of this asset lies within its historic and architectural value. It is a good example of the local vernacular and provides evidence for the rise of the agrarian economy and sustaining of that economy in an area which was becoming increasingly industrial.

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills


6.1.20 The setting of this asset is the agricultural surroundings of the asset. This contributes to the significance of the asset. The site does not form part of the setting of this asset. Any changes within the site will not harm the significance of the asset.

6.1.21 The Scheduled Monument of the hillfort known as The Castle Fort at Castlebank Plantation is located to the south of the proposed development. It consists of the earthwork remains of the univallate hillfort at Castlebank Plantation, on the crown of the hill, northwest of Castle Hill Road. The remains comprise a bank and outer ditch enclosing an oval area orientated southeast to northwest and is 170m long and 140m wide. The northwest corner of the hillfort a clay pit has been excavated which is now filled with water. This clay pit has removed all traces of the bank and ditch and ancillary works associated with the pit has also removed earthworks on the southwestern portion. There are also quarry pits located to the southeast outside the banks. It is likely that the entrance was located to the northeast with a break in the ditch and the slightly more gentle slope on the hillside beyond.

6.1.22 The significance of this asset lies in its archaeological and historic value. It provides evidence of the construction of hillforts and information into the design and evolution of defensive forts. It also has the potential to provide information on the material culture of the occupants. It has historic value as is it a rare example of a late Bronze Age, early Iron Age hillfort. It provides evidence of how the contemporary society utilised the landscape.

6.1.23 The setting of the asset is the landscape within which it sits. As a fort, it is defensive in nature and therefore the views from this asset add to the significance of the asset. The landscape around the fort would have supported the inhabitants of the fort and therefore this also contributes to the setting of the asset.

6.1.24 The site may fall within the setting of the fort, however the contribution it makes to the significance is very low. In addition, although the entrance of the fort may face towards the site, this view is now blocked by woodland and there is no apprec iable visual relationship between the site and the fort. Change within the site is unlikely to cause harm to the significance of the scheduled monument.

Non-designated Assets


6.1.25 A search was undertaken of the Wolverhampton and Walsall Historic Environment Record (HER) via Heritage Gateway. This identified a small number of assets within the site and in close proximity.
The assets are identified with their HER number.


6.1.26 The line of the Sandhills Arm of the Wyrley and Essington canal once bisected the site, crossing form the main canal running northeast towards Sandhills Farm and is identified as a non-designated asset (5893). It can be seen on the 1889 Ordnance Survey map and the line of this arm is shown until the late 20th-century mapping. The appearance of the canal arm on the 1st edition maps indicates that at

T e c h n i c a I C o m p e n d i u m I Horne Farm, Sandhills

this time, Sandhills Farm was a small industrial complex, with the canal constructed to help transport the goods. The 1st edition Ordnance Survey map shows the canal arm terminating at Sandhills with a wharf area and possibly loading bay. This complex of industrial buildings and the canal wharf are also identified as a non-designated asset. The actual date of construction of this arm of the canal is unknown, however it was marked as out of use on the 1902 Ordnance Survey map. But this time, the entire northern portion of the site, north of the canal arm and two fields to the south of Sandhills (labelled here as The Sandhills) is shown as covered in a vast orchard.

6.1.27 Located within the site and visible on the 1st edition Ordnance Survey is Sandhills House. This is a non-designated heritage asset (5892). The present owner maintains that this house was built in the 17th century as a gamekeeper's lodge, however the current fac;ade is 19th-century. A lodge building is identified at the junction of Lichfield road and the entrance drive to Sandhill house. This lodge (5891) was constructed in the late 19th-century, but first appears on the 1902 Ordnance Survey map.

6.1.28 Home Farm (5992) is also a non-designated heritage asset in its own right. It was constructed in the 19th-century with a walled garden and a mature belt of sycamore.

6.1.29 Located to the southeast of Sandhills, adjacent to Lichfield road is the site of Shire Oak House (5993). This is a mid-19th-century villa, set within its own grounds. It has undergone a series of name changes, first known as Bleak House, the Hill House and finally Shire Oak House by 1919. It is now a residential home. Adjacent to this is the site of a gravel pit (10217). It was still being worked in 1938 and was one of a number of small-scale gravel extraction pits located on the periphery of the site.

6.1.30 At the southwestern corner of the site is the Shire Oak Inn (10218). This is shown on the 1st edition Ordnance Survey map but labelled as Anchor Inn. It is also believed to have been the site of a brewery.

6.1.31 The series of historic Ordnance Survey maps shows the change in the landscape which has occurred over the late 19thand early 20th century. Within the site, the major changes have been the introduction of the Sandhills Arm of the Wyrley and Essington Canal which cut across the site and the later use of a large portion of the area as an orchard. The 1st edition Ordnance Survey map shows the site, with Sandhills House, Home Farm. The entrance to Sandhills House is shown leading northwest from Lichfield Road, with what appears to be a formal avenue of trees lining the driveway.

6.1.32 In the surrounding landscape, directly adjacent to the site boundary is the site of Bleak House. This building is shown within its own grounds. On the 1902 Ordnance Survey map, the name of the building has been changed to Hill House, and the 1919 Ordnance Survey map has this as Shire Oaks, with a large gravel pit located immediately west.

6.1.33 The 1st edition Ordnance Survey map shows the settlement of Cutshill to the northwest, separated from the site by the canal. The settlement is very linear, with little other development in the vicinity of the site. There are a number of collieries within the area, but it is likely that during the 19th -century, the site was used for agricultural purposes.







T e c h n ic a I C o m p e n d i u m IHome Farm, Sandhills

6.1.34 The 1902 Ordnance Survey map shows the orchard covering the majority of the site. It also shows the area of Sandhills Farm as enlarged, with a number of gravel pits and possible glasshouses. A lodge building has appeared at the entrance to the drive leading to Sandhills House,a non-designated asset in its own right. It also shows the development of Shire Oak to the southwest of the site with housing appearing along Chester Road.

6.1.35 There is litt le change within the site until the removal of the orchard in the mid-20th- century. The settlements within the surroundings of the site expand during the 20th- century. By the 1950s, the settlement of Shire Oak has expanded with housing added on the northeastern side of Chester Road and linking the settlement of Ogley Hay, forming one continuous strip of development. This expansion continues until the extents seen in the present day. The proposed development site remains unchanged.

Conclusions


6.1.36 This appraisal has shown that there are no major heritage constraints which could preclude the development of this site. There are a small number of designated assets within the vicinity of the site, but it has been demonstrated that the site does not contribute to their significance. Therefore, change within the site would cause no harm.

6.1.37 The appraisal has identified the potential for below ground archaeology to be located within the footprint. This consists primarily of early modern, industrial archaeology. In particular, it is likely that any intrusive works would identify the line of the Sandhills arm of the Wyrley and Essington Canal. In addition, any works in the vicinity of Sandhills House and Home Farm may uncover evidence of wharf and industrial canalstructures.

6.1.38 The northern portion of the site was beneath a large-scale orchard for at least 50 years, with two fields to the south of Home Farm also included. It is possible that given the density of the planting and the age of the orchard, this would have removed archaeological deposits, or at the very least caused fairly substantial truncation. The site is likely to have been used for agricultural purposes throughout is recent history. There is little potential for earlier phases of archaeology within the site.

6.1.39 Therefore,archaeological investigation would be required for areas which have the potential to disturb the Sandhills arm of the canal, in addition to a Heritage Assessment to accompany any planning application for this site.