Policy WSA4 – Yieldsfield Farm (sometimes recorded as Yieldfields farm), Stafford Road, Bloxwich
Object
Draft Black Country Plan
Representation ID: 19871
Received: 04/10/2021
Respondent: Mr Gordon Robertson
We are strongly against using greenbelt land for new homes. There are numerous brownfield sites and derelict buildings which can be used for refurbishment within Bloxwich / Walsall that can be used for housing without damaging the biodiversity of the local area. We regularly see bats, Woodpeckers and recently Red Kites, we would in danger of losing these. We also think that the greenbelt land particularly mentioned on Stafford Road Bloxwich would begin the process of amalgamation of Bloxwich / Newtown and Great Wyrley becoming one big urban sprawl. This would put huge strain on the existing infrastructure which doesn't cope with the current traffic level.
The addition of homes would cause environmental and social problems and Walsall already has very poor air quality, more homes will mean more people more pollution.
We realise there is a need for more homes in the area but this would cause a massive strain on education GP surgeries, hospitals etc. The existing resources are already bursting at the seams and they must first be improved to cope with current demand.
Object
Draft Black Country Plan
Representation ID: 22392
Received: 08/10/2021
Respondent: Inland Waterways Association Lichfield
Policy WSA4 - Yieldsfield Farm, Stafford Road, Bloxwich
This site includes the former Lords Hayes Branch of the Wyrley & Essington Canal, which runs along its northern boundary. Although long disused and largely filled-in, its course is clearly visible in the field boundaries and its original extent is shown on historic maps. There is still evidence of water in places and its course is shown as a Site of Local Importance for Nature Conservation (SLINC) on the Strategic Allocation plan.
Policy ENV7 – Canals (5) requires that the potential to record, preserve and restore disused canal features should be fully explored, and that the line of the canal should be protected by the detailed site layout. Para. 10.102 further advises that the potential to preserve the line of the canal as part of the wider green infrastructure network be explored, and also that where feasible and sustainable, proposals should consider the potential for the restoration of disused sections of canal.
There is considerable potential here for the Lords Hayes Branch Canal within the site to be at least partly restored to water to protect its historic interest and to provide an attractive aquatic feature and an improved environmental corridor within the site. Although there are no proposals to make this section navigable again, the Lichfield & Hatherton Canals Restoration Trust plan to restore a section of the canal just outside this site, from Fishley Junction to west of Fishley Lane, as part of the new route for a restored Hatherton Canal. Consideration should also be given to re-watering the short intervening section to join these up to secure a reliable water supply for the SLINC section.
Comment
Draft Black Country Plan
Representation ID: 23196
Received: 11/10/2021
Respondent: Bloor Homes Midlands
Agent: Cerda Planning Ltd
6.4. When considering the somewhat questionable location and boundaries to sites on the edge of the plan area such as the proposed allocations under policies WAS4, WSA1, CSA1 and CSA2, the plan and its policies do little to consider the wider spatial or landscape impacts of developing these sites and appear to reduce the weight given to high (and moderate-high) levels of Green Belt and landscape harm in these areas favoring its central area.
6.5. The plan identifies the development of a network of Neighbourhood Growth Areas are proposed to be released from the Green Belt in sustainable locations. However, given the identified infrastructure requirements on each of these sites (noting that no fewer than 7 new Health Centres
are required by the allocating policies) it is our submission that these areas should be planned more holistically to ensure that wider benefits ensue from these allocations and that the delivery of the necessary infrastructure is actually viable and will be delivered where there is a proven need. To this end the term NGA, which is, by any other name, a housing allocation should be widened to provide for coordinated growth in areas where there is an identified need (or deficiency) of services and sites allocated in order to provide for both the much needed new homes but also new services and facilities.
Support
Draft Black Country Plan
Representation ID: 23362
Received: 15/02/2022
Respondent: L&Q Estates
Agent: Barton Willmore
[Attachment: Rep Form]
Dear Sir or Madam,
Please find enclosed our Representations to the Draft Black Country Plan 2039 (Regulation 18) Consultation, on behalf of L&Q Estates, in relation to land at Yieldfields, Bloxwich. The Representations include the below reports as appendices:
- Yieldfields, North Walsall Vision Document (October 2021)
- Review of Sustainability Appraisal (October 2021)
- Yieldfields Delivery Trajectory
- Transport Technical Note (October 2021)
- Preliminary Ecological Review: Constraints and Opportunities (July 2019)
- Heritage Appraisal (September 2019)
I have also attached these documents separately, in case they are easier to read.
These Representations relate specifically to the Sustainability Appraisal, and Sections 2, 3, 4, 5, 6, 9, 10 and 13 of the Draft Black Country Plan (Regulation 18) Consultation document.
Please let me know if you have any queries or require any further information.
[---------------------- REP FORM ENDS -------------------------]
[Attachment: APPENDIX 2 YIELDFIELDS, NORTH WALSALL VISION DOCUMENT (OCTOBER 2021)]
APPENDIX 2
YIELDFIELDS, NORTH WALSALL VISION DOCUMENT (OCTOBER 2021)
L&Q ESTATES
ABOUT L&Q ESTATES
L&Q Estates is one of the largest strategic land companies in the UK, promoting and developing residential and mixed use schemes in all geographical areas. We are not a house builder or contractor but play a unique role as master developer, taking forward and coordinating all aspects of the development process from initial site assembly through to masterplanning, planning promotion and Section 106 negotiations before delivering serviced land to the market place.
The Vision 03
Introduction 04
Planning Policy Context 06
Local Context 08
Opportunities and Constraints 10
Key Design Proposals 16
Summary of Key Benefits 22
Case Studies 23
THE VISION
"YieldFields is an exciting new urban extension on the northern edge of Bloxwich, with the potential to bring forward the delivery of approximately 978 new homes, a new primary school and varied new community and recreational facilities. It will be set within generous formal and informal open space, providing accessibility for residents to local recreation and outdoor space to promote health, wellbeing and sustainable life choices."
The development will provide approximately 978 new homes for the local area, as per the Draft Policy WSA4 (Walsall Strategic Allocation) of the Black Country Plan, of a range of types, tenures and sizes to suit local need.
The development will be responsive to its location creating a new transitional edge to Bloxwich and the Green Belt, enhanced with new and existing planting where appropriate as part of landscape buffers along the boundaries of the development. The development will also respond sensitively to the existing grade II listed Yieldfields Hall located on the site, reconfiguring it for potential future community or residential use.
The development will create large new areas of public open space including recreational and informal sports provision, allowing the proposed community to have better access to nature and open space, benefitting health and well being whilst giving character to the development.
The development is sustainably located with a range of services and facilities within walking and cycling distance, including the supported by provision of new facilities and new pedestrian/cycle infrastructure as part of the development.
INTRODUCTION
This Vision Document has been prepared by Barton Willmore on behalf of L&Q Estates, who are promoting an urban extension to the north of Bloxwich.
The land under promotion is located on the northern edge of Bloxwich, between Bloxwich Golf Course and Great Wyrley. The site lies within the administrative boundary of Walsall.
L&Q Estates intends to engage with the Council, and other stakeholders, about this important strategic proposal.
The site lies on the northern edge of Bloxwich, east of the A34 Stafford Road. The site extends to approximately 38.9 hectares and comprises of a series of fields in agricultural use. The majority of the site is classed as Grade 3B agricultural land, with some pockets of Grade 4. These are interspersed with trees and hedgerows. The only buildings within the Site are located within Yieldfields Farm, which includes the histonc Grade ll Listed Yieldfields Hall, visible from Stafford Road when facing north
PLANNING POLICY CONTEXT
Walsall Metropolitan Borough Council
The Development Plan for Walsall Borough currently comprises the Black Country Core Strategy (BCCS) (2011), the saved policies of the Walsall Unitary Development Plan (2005) and the Site Allocations DPD (2019).
Emerging Black Country Plan
Walsall Metropolitan Borough Council and the other Black Country authorities are preparing a new Black Country Plan. The Issues and Options consultation has held between July - September 2017. The Black Country Authorities are consulting on the Draft Black Country Plan (Regulation 18) from August - October 2021. This identifies that the Black Country Authorities will seek to deliver at least 47,837 net new homes over the plan period (2018-2039). In addition, the Black Country Authorities feel that they have demonstrated that exceptional circumstances exist to justify the redrawing of green belt boundaries around the urban edge to release land for development.
The Draft Black Country Plan allocates the part of the site located in Walsall for 978 homes. This allocation would result in this part of the site being removed from the Green Belt. Draft Policy WSA4 (Yieldfields Farm) sets out a series of design principles for the development of the site, which include:
High quality, sensitive design and layout that conserves and enhances the setting and significance of Yieldfields Hall
Delivery of appropriate local facilities to support residents and to enhance the sustainability of the existing area, including a new primary school and local health centre.
Contribution to improvements for secondary school provision in North Bloxwich.
Investigation and detailed proposals for remediation of contaminated land.
A transport strategy that includes new crossing points on the A34 and a new vehicular junction to serve the development.
A site-wide Sustainable Drainage Strategy, to ensure that drainage requirements can be met on site and
are designed to deliver landscape, biodiversity and amenity benefits.
A strategy for landscape and habitat creation.
Black Country Urban Capacity Report (May 2021)
The Urban Capacity Report sets out the position regarding the need for and supply of land for housing and employment in the Black Country from April 2020 to March 2039. The Urban Capacity Report identifies that the gap between supply and need over the new Black Country Plan period up to 2039 has grown to 38,595 homes, an increase of around 10,000 homes since 2019. The report considers the potential additional sources of housing supply in the urban area to help close this gap, including density increases and sites in Strategic Centres. However, current evidence suggests that these sources are likely to generate no more than a few thousand homes. Therefore, the identified shortfall - that is the amount of housing need which cannot be accommodated in the Black Country urban areas - remains significant, at around 36,819 homes.
Given the evidence, the Urban Capacity Report concludes that the exceptional circumstances necessary to trigger a Green Belt review in the Black Country, in order to meet housing and employment land needs, have been met.
LOCAL CONTEXT
The site lies on the northern edge of Bloxwich, approximately 1 mile north of the town centre.
The site is bounded as follows:
Immediately to the north of the site are agricultural fields with the village of Newtown located beyond.
To the south east the site is bounded by Bloxwich Golf Club with agricultural fields bounding the site to the north east.
Bloxwch Golf Club lies to the south of the site.
To the west the site is bounded by the A34, Stafford Road with Bloxwich itself beyond to the south west.
Facilities and Services
There are a number of facilities and services within walking distance of the site located in Bloxwich to the south. These facilities include local centres, Bloxwich Town Centre, convenience stores, supermarkets, pubs, a number of primary and secondary schools, and medical facilities. Additionally there are a number of pubs located closer to the site on Stafford Road.
The site is also within walking distance of a number of sports, recreational and community facilities including Bloxwich Golf Club and the King George Playing Fields.
There are a number of schools in the local area with the closest Primary School being Lower Farm Primary School (approximately 0.6 miles, 12 minutes walk from the site) and the closest Secondary School being Walsall Academy (approximately 0.7 miles, a 15 minute walk from the site).
Additionally there is the potential to locate a new primary school and a small community hub on the site itself as
part of the development.
Transport
Bus
The closest bus stops to the site are located on Turnberry
Road approximately 0.4 miles from the centre of the site, serving the X51 route and on the A34, Stafford Road approximately 0.5 miles from the centre of the site, serving the 1, 74 and X51 routes. The frequency and destinations of each route are as follows:
The 1 Bus Route runs between Walsall and Cannock Town Centre with a daytime frequency of one bus every half an hour.
The 74 Bus Route runs between Walsall and Stafford Town Centre with a daytime frequency of approximately one bus every half an hour.
The X51 Bus Route runs between Birmingham and Cannock Town Centre with a daytime frequency of approximately one bus every twenty minutes.
Train
The closest train station to the site is Bloxwich North, located approximately 1.1 miles Ca 22 minute walk or
6 minute cycle) from the centre of the site. Bloxwich North offers regular services to Birmingham International via Birmingham New Street and Rugeley via Cannock.
Walking/Cycling
The site is located within close proximity of a number of Public Rights of Way with the opportunity to create new cycle and pedestrian routes within the site linking to the surrounding countryside.
Car
The site is located on the A34, a main road running between Birmingham and Manchester via Walsall, Cannock, Stafford and Newcastle-under-Lyme. It is also well located for key nearby road connections to the AS, M6 Toll and M6.
OPPORTUNITIES AND CONSTRAINTS
Wider Constraints and Opportunities
The Wider Constraints and Opportunities Plans opposite demonstrates a number of key opportunities and constraints located in the surrounding area around the site (site constraints are considered overleaf).
Wider Opportunities
• The site is located on the northern edge of Bloxwich, and is well located for local facilties, services and public transport.
• The site is located on a main road, the A34, and is well located for local road connections including to the AS, M6 Toll and M6.
• There are several public rights of way in the vicinity of the site with potential development of the site having the potential to improve connectivity for the local communities between Bloxwich and the surrounding countryside.
Wider Constraints
• There are a number of listed buildings in the vicinity of the site which will need to be considered and responded to appropriately.
• The site is located within the Green Belt.
Site Constraints and Opportunities
The Constraints and Opportunities Plans opposite demonstrates a number of key opportunities and constraints located on the site.
Site Opportunities
• The site topography can be used to inform the location of attenuation and drainage.
• The site is located entirely within Flood Zone 1 and is therefore suitable for development.
• Existing landscaping on the site can be retained and enhanced where possible to inform new public open space, planted boundaries and to give character to the development.
• There are significant opportunities for biodiversity improvements as part of any development.
Site Constraints
• A proportion of the site has been previously worked for coal, with mine shafts and areas of past shallow coal workings. The masterplan will be developed in response to these constraints and subject to site investigation works and remediation, the site can come forward for development, as shown by the adjacent Turnberry Estate which similarly had previously been worked.
• There is some surface water level flooding which will need to be considered but isn't seen as a constraint to development.
• The Grade II listed Yieldfields Hall, located within the site will need to be considered and responded to appropriately.
Landscape and Gfeen Belt
On the basls of a comprehenslve Landscape, Vlsual and Green Belt Appralsal process, lt ls consldered that the Slte has potentlal for resldentlal development. There
ls a degree of contalnment currently provlded to the Slte by the mature vegetatlon structure wlthln the Slte and formlng the Slte boundarles; and by exlstlng bullt development assoclated wlth the A34 to the west. Sensltlve sltlng ln thls way would help llmlt effects
on prevalllng landscape character and vlsual amenlty and further mltlgatlon would be achleved by careful locatlon of bullt form and relnforcement of the exlstlng vegetatlon structure wlthln the Slte. In order to lntegrate development lnto the landscape successfully, a number of key landscape and vlsual opportunltles and constralnts need to be addressed (as shown on the plan below).
It ls acknowledged that there would be harm to the Green Belt as a result of development of the Slte. However, there ls potentlal for sensltlve development set wlthln
the exlstlng landscape framework. Thls framework would
also provlde a robust Green Belt boundary. Thls boundary would be based on physlcal features that are currently readlly recognlsable and consldered permanent, lncludlng the double hedgerow marklng the former canal route along the northern Slte boundary.
KEY DESIGN PROPOSALS
The initial concept masterplan for the site is presented opposite. The masterplan has been prepared in response to the Constraints and Opportunities detailed in the previous section. A summary of the design principles and development benefits of the site are listed below:
The proposals will be able to deliver the 978 allocated dwellings in the Black Country Plan over a residential development area of approximately 24.5 hectares at an average site density of approximately 40 dwellings per hectare.
The proposed development retains existing hedgerows and planting wherever possible, incorporating these into new green corridors and public open space.
An integrated sustainable drainage strategy utilises the existing topography to create a well considered drainage solution.
The development includes large, well overlooked areas of new public open space including potential informal sports provision in the southern corner of the site. This area of non-developed green space allows for views of Yieldfields Hall and preserves its setting.
As part of the proposals we have sought to retain
the existing Yieldfields Hall and a number of ancillary buildings, incorporating these into the proposed
new 'Community Hub' on the site. New boundary
planting will help to preserve the setting of the listed buildings whilst demolition of modern ancillary farm buildings close to Yieldfields Hall will enhance its setting further.
The development will incorporate a clear street hierarchy, creating a highly legibile development with a clearly defined loop road through the site.
The development will incorporate new pedestrian and cycle routes across the site to enhance local connectivity and accessibility, particularly between Bloxwich and the surrounding open countryside.
There is potential for a 2FE Primary School located
in the centre of the site to maximise accessibility and encourage walking and cycling to school.
The Concept
The development framework sets out to:
Create a new sustainable Urban Extension to the existing residential community in Bloxwich.
Create a landscape buffer and soft edge/transition to the new development edge and the countryside.
Establish a new community hub located along the
A34 Stafford Road.
Movement and Connectivity
The development framework sets out to:
Create a coherent hierarchy of streets within the site with a primary access point and route with a secondary loop road branching off from it, leading to
tertiary roads and private drives.
Retain part of the existing track on the site as a
green_way route to the primary school for walking and cycling.
Facilities
The development framework sets out to:
Create good accessibility to the existing local centre
(at 800m walking distance from the site) and to
Bloxwch town centre;
Create a new local primary school, located close to the centre of site to serve the new and existing communities.
Create a new Community Hub close to the A34, Stafford Road.
The development also has the potential to sensitively
reconfigure the existing grade II listed Yieldfields
Hall on the site for potential future community or residential use.
Landscape
The proposed landscape strategy would create a Gl framework consisting of notable key areas of open space connected via green corridors that run within and around the Proposed Development of the Site. This framework will allow for the retention of the existing established hedges and trees, to be reinforced with additional native planting as part of a Site_wide landscape strategy. Sustainable drainage would also form a feature within
the Gl framework, which together with the proposed
landscaping would be designed to deliver a range of benefits to recreation, visual interest, landscape character and biodiversity. Once mature, the proposals would establish a comprehensive vegetation structure, that
would provide robust green buffers to the site boundaries.
Overall, the GI framework would help assimilate the proposed development into the receiving landscape, mitigating any adverse impacts on the surrounding landscape character and visual amenity.
SUMMARY OF KEY BENEFITS
New Homes for All
The development will provide approximately 978 new homes for the local area of a range of types, tenures and sizes to suit local need.
Sensitive to the Local Context and Setting
The development will be responsive to its location creating a new transitional edge to Bloxwich and the Green Belt, enhanced with new and existing planting where appropriate as part of landscape buffers along the boundaries of the development. The development will also respond sensitively to the existing grade I I listed Yieldfields Hall located on
the site, reconfiguring it for potential future community or residential use.
Open Space for Recreation and Wellbeing
The development will create large new areas of public open space including recreational and informal sports provision, allowing the proposed community to have better access to nature and open space, benefitting health and well being whilst giving character to the development.
Connectivity and Sustainability
The development is sustainably located with a range of services and facilities within walking and cycling distance, supported by provision of new facilities and new pedestrian/ cycle infrastructure as part of the development.
L&Q ESTATES DEL VERY CASE STUDIES
Emersons Green, Bristol
L&Q Estates have a track record of delivering strategic development on sites that have previously been worked for coal, as exemplified at Lyde Green, Bristol. Then Gallagher Estates, L&Q Estates formed part of a
consortium that promoted and obtained planning consent for over 2,000 new homes, as well as employment land, schools, a local centre and community facilities, located
on the eastern edge of Bristol.
Coal was extensively mined around Bristol, and indeed the site was underlain by a number of coal seams within the Coalpit Heath Basin. Based on The Coal Authority's records areas of the site had previously been worked at shallow depths, with a number of mine shafts leading to deeper workings also recorded. As part of promoting
the site a comprehensive ground investigation was commissioned by L&Q Estates, which involved a range of techniques including trial pits, soil strips, boreholes, gas monitoring, groundwater monitoring and chemical testing.
Based on these investigative works a programme of remediation was identified, which included drilling, grouting and capping with reinforced concrete plugs
to remediate the identified shallow workings and mine entries, as well as capping of remaining coal seams with material to prevent combustion.
L&Q Estates were therefore able to demonstrate that despite areas of the site having previously been worked for coal, through a comprehensive investigation to identify these features and the development of a tailored mitigation strategy to remediate these features, the site was suitable for development. The site was subsequently acquired by Taylor Wimpey and today is well_progressed,
with a large number of new homes and employment units built and occupied.
Wixams, Bedford
L&Q Estates have a track record of delivering strategic development on challenging sites, not least at Wixams, Bedford where on the site of a former WWII Royal Ordnance Factory now stands a new garden village
set in an extensive, 300 acre high quality landscape
environment. Pursuant to being the site of the largest munitions factory in the world, the site functioned as
a trading estate including uses such as car breakers, scrap metal dealers and panel beaters, before Gallagher Estates, now L&Q Estates, partnered with lnnogy to promote the site for a new garden village and the re_use of 450 acres of largely derelict land.
Given the site's history, following the grant of planning permission in 2007 significant enabling works have been undertaken to facilitate the derelict site being redeveloped into a new garden village; this included the
removal of over 100 derelict buildings, remediation of the former bomb_making factory, earthworks, realignment
of the A6 and delivery of strategic infrastructure such as drainage, services and roads.
Wixams itself is composed of four distinct villages, each with their own identity, and will see the delivery of 4,500 new homes, along with four primary schools, a secondary school, a 'High Street' as well as employment units and landscaped parks, play areas and recreational facilities.
Some 1,600 new homes are now built and occupied at the site, which continues to be transformed, with L&Q Estates having taken the role of master developer to
steer this site from a technically challenging site to a new
garden village.
[----------------------- APPENDIX 2 ENDS -----------------------]
[Attachment: APPENDIX 3
REVIEW OF THE SUSTAINABILITY APPRAISAL (OCTOBER 2019)]
Land at Yieldfields, Bloxwich
Review of the Sustainability Appraisal supporting the Draft Black Country Plan 2039 (Regulation 18) Consultation
October 2021
1.0 Introduction
1.1 This report sets out the conclusions of a review of the Sustainability Appraisal (SA) process supporting the Draft Black Country Plan (BCP), which is at Regulation 18 stage . The BCP is being produced by Dudley Metropolitan Council, Sandwell Metropolitan Council, Walsall Council and City of Wolverhampton Council, which together form the Black Country Authorities (BCA) and will guide development up to 2039. The review has focused on the SA (which incorporates Strategic Environmental Assessment (SEA)) of the BCP: Regulation 18 SA Report (herein referred to as the Reg 18 SA Report), prepared by Lepus Consulting on behalf of the BCA in July 2021 . The Reg 18 SA Report is undergoing consultation to offer an opportunity to submit representations to the Draft Plan.
1.2 Whilst the review has focused on the latest SA material, reference has been made to earlier reports where necessary to give a view on the adequacy of the whole iterative SA process. The BCA published the ‘SA Scoping Report’ in February 2017 and then the SA Issues and Options Report in June 2017 alongside the Issues and Options Report (consultation period: 3rd July to 8th September 2017), which formed the first phase of the formal review of the BCP. The latest stage of this process is the Regulation 18 version of the BCP which the BCA issued for consultation between 16th August 2021 to 11th October 2021. The accompanying Reg 18 SA Report identifies the likely significant effects of all reasonable options within the Regulation 18 Plan.
1.3 The Plan will undergo amendments before further consultation with an updated SA Report at Regulation 19 stage, which is planned for August - September 2022. The final SA report will be submitted with the submission version of the Plan to the Secretary of State for Examination In Public (programmed for March 2023).
1.4 The full SA review is included at Appendix 1. It uses a ‘traffic light’ scoring system to identify areas that would benefit from improvement (amber) and those elements of the SA process that are considered to comply fully with the requirements (green). Two areas of deficiency (red) were identified (which is expected given that the SA process is incomplete at this stage of plan-making) as well as a number of areas that would benefit from further focus before the Regulation 19 consultation stage, so that the process is as robust as possible.
1.5 In addition, this report includes an appraisal of the development site ‘Land at Yieldfields, Bloxwich’, which is included as a draft strategic allocation for residential development within the BCP (Policy WSA4).
1.6 The site-specific appraisal is included at Appendix 2 and has been undertaken by Barton Willmore utilising the same matrix methodology and 14 SA Objectives used to consider the alternative site options within the Reg 18 SA Report for inclusion within the BCP. The matrix assessment with a colour coded key is a method often used for the assessment of site options in SAs, to make the comparison of the positive and negative sustainability aspects of a site clear and consistent. The appraisal provides commentary on the score that we consider should be awarded for each objective indicator question. The appraisal draws on the evidence base available for the site, including the concept masterplan, vision statement and preliminary technical reports.
2.0 Review of SA
Purpose of Review
2.1 A review of the SA documents has been undertaken against the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the “SEA Regulations”) and Section 19 of the Planning and Compulsory Purchase Act 2004 (the “Act”), which sets out requirements for SA. SA is a complex and legalistic process and should be undertaken iteratively, alongside the preparation of the Plan. SEA is also a statutory assessment process, originally required under the European SEA Directive, transposed in the UK by the SEA Regulations and amended by the Environmental Assessments and Miscellaneous Planning (Amendment) (EU Exit) Regulations 2018 (SI 2018/1232). As set out in the explanatory Memorandum accompanying the Brexit amendments, they are necessary to ensure that the law functions correctly following the UK's exit from the EU. No substantive changes were made by this instrument to the way the SEA regime currently operates. Therefore, the SEA Regulations remain in force.
2.2 A Local Plan must be prepared in accordance with Section 39 of the Act “with the objective of contributing to the achievement of sustainable development”. It should therefore be informed by the SA process, which itself must comply with the SEA Regulations.
2.3 The full review of the SA process which includes the 2021 SA is presented at Appendix 1. This review has sought to identify any areas of the SA that would benefit from further focus or clarity in order to ensure that the Plan is determined as sound at Examination. As above, whilst the review has focused on the Reg 18 SA Report, reference has been made to earlier reports where necessary to give a view on the adequacy of the whole iterative SA process.
Review Summary
2.4 Two areas of deficiency were identified in the SA report, as follows. Given that the SA and plan-making process is iterative, there is the opportunity for these comments to be addressed at Regulation 19 stage and in the case of monitoring, when the Plan is adopted:
• Likely significant effects on the environment (cumulative effects) – The SA Scoping Report states that the assessment of cumulative effects will be presented in tabular format and show where the different effects arise when two or more draft policies operate together. However, the Reg 18 SA Report does not mention or address cumulative effects and does not consider how each of the SA Objectives might interact with one another. Section 5.5.27 of the SA Issues and Options Report concludes that the Centres Threshold Approach positively manages the economic growth of the Black Country, to ensure that proposals support balanced growth and do not individually or cumulatively lead to harmful impacts. The approach to the assessment of cumulative effects is not well outlined and seems inconsistent with the above being the only section that specifically mentions cumulative effects. Therefore, it is unclear as to whether other effects were considered within the SA assessment and all were found to be negligible/neutral and/or if any potentially negative effects were identified. It would be helpful to clarify this. The Reg 18 SA Report should include a separate section setting out the methodology used to determine cumulative effects, which would create a more robust and transparent assessment. For example, within the likely impact scoring key tables, it is not clear whether a major negative score would contribute to a cumulative significant effect or whether a major positive score would contribute to a cumulative significant effect (in a positive way). The SA Objectives methodology assumptions should also outline how these effects contribute to determining the category (e.g. minor/significant positive/negative, etc.) given in the SA assessment matrices. The potential cumulative effects of the Plan, including the site alternatives, should be considered prior to the Regulation 19 Stage. The Reg 18 SA Report does also not refer to cross border effects, for example in relation to housing provision or downstream flooding, which can occur where a plan will have effects outside of the plan area and should be documented in the SA. The approach to the assessment of cumulative effects should be well outlined in the methodology section and should be consistent between the different environmental topics.
• Monitoring – There is no section on monitoring significant effects included. The SA should identify the trends and monitoring indicators for each of the SA Objectives used in the SA process that will be used to monitor change over time from the baseline conditions, that may occur as a result of the Plan. The Reg 18 SA Report should explain that post adoption of the plan, its actual impacts will be monitored to make sure that unexpected effects are identified and dealt with and should set out suggested monitoring indicators for each of the SA Objectives used in this SA process and suggest the frequencies/ timeframes for monitoring. The measures should also monitor the implementation of SA mitigation measures, for instance new landscaping or green infrastructure, thereby identifying positive as well as negative effects. This should be developed throughout the SA process and therefore should be rectified before the updated SA report is published for consultation with the Draft Plan at Regulation 19 stage.
2.5 The following areas of the SA would potentially benefit from additional consideration:
• Relationship with other plans and programmes – The Reg 18 SA Report should summarise the significant policy changes that have taken place since the previous version of the SA was published (such as the 2021 NPPF). Consideration should also be given to whether any aspect of the SA Framework requires updating as a result. This is important as a number of relevant policy and legislation changes have occurred since 2017. These include the July 2021 version of the NPPF, the 2019 amendment to the Climate Change Act (net zero), publication of the 25-year Environment Plan and the Environment Bill, which will mandate biodiversity net gain and is in its final stages going through Parliament. The Department for Environment, Food and Rural Affairs (Defra) has recently released Biodiversity metric 3.0 for calculations. The UK has also exited the EU, with the majority of European-derived legislation retained as set out in the EU Withdrawal Act.
• Current state of the environment – It would be helpful if the Reg 18 SA Report clarified that the baseline data published in the SA Scoping Report in 2017 has been updated using the most recently published information, which is reflected in the Reg 18 SA Report, and whether there were any changes in the overall trends identified previously and whether the SA Objectives were affected by this. Several important developments have occurred since 2017 that would have a bearing on the baseline and future baseline conditions, with and without the plan, which have not been addressed within the Reg 18 SA Report. These include the COVID-19 pandemic and resulting recession and lifestyle changes including an increased prevalence of home working and less travel. The Government has also published a 10 point plan for a Green Recovery which should also be considered in the SA. The urgency of the climate and biodiversity emergencies should be acknowledged given recent policy, legislation and progress reports (such as the recent Sixth Assessment Report published by the Intergovernmental Panel on Climate Change (IPCC) ).
• Existing environmental problems – Further work should be undertaken prior to the next version of the SA, to fully reflect the findings of the Habitat Regulations Assessment (HRA) within the SA. Briefly outlining the conclusions of the HRA would give more meaning and solid conclusions (rather than mixed scores) to the assessment of ecological effects, and would make the argument that the findings have been incorporated into the SA more robust. There is no evidence that cumulative effects have been assessed in relation to European sites in the Reg 18 SA Report, which would have been the case for in-combination effects in the HRA, for legal compliance. Given the need for assessments to be coordinated, it would be helpful to have more information within the SA on the HRA undertaken for the BCP. It is considered that the findings of the HRA should inform and be incorporated into the SA before the Regulation 19 consultation, particularly given the requirements of the Regulations for the HRA to be undertaken in parallel to the SA, as above.
• Mitigation - The Reg 18 SA Report should include the use of mitigation measures to avoid, reduce and offset significant adverse effects on the environment and maximise beneficial environmental effects from implementation of the Draft Plan. It would also be helpful if there was a section outlining the changes to the plan which have occurred because of suggestions raised during the appraisal process for reducing the negative impacts of the Draft Plan and enhancing its benefits. Section 6 of the Reg 18 SA Report outlines the reasons given by the BCA as to why alternative sites were either selected or rejected and suggests where mitigation is likely to be required at a site. Given that the assessments have only been undertaken pre-mitigation and not post-mitigation, it is not clear how this mitigation has been determined, and it would be helpful if this was clarified in the SA Report. As the evidence base expands, more detailed environmental assessment work will be undertaken on each of the proposed site options which will result in the identification of the specific mitigation and enhancement measures which will be fully considered in future SA reports that accompany the next stage of the BCP and individual planning applications for the site allocations. Upon undertaking assessments of sites, this should also include pre- and post-mitigation assessments, and should consider design measures such as the creation of pedestrian and cycling infrastructure, green space, future proofing to increase mitigation of and adaptation to climate change (for example the Future Homes Standard) and the standard mitigation measures such as the implementation of a Construction Environmental Management Plan (CEMP), in accordance with appropriate legislation and best practice for development sites, which would mitigate construction effects from noise, air quality and traffic and minimise the likelihood of significant adverse effects arising.
• Reasonable alternatives – The Reg 18 SA Report should better outline how the alternative sites were identified and the site selection process, for example which of these were from Calls for Sites, and were any submitted to the LPA in response to consultation events or on an ad-hoc basis, to demonstrate that a full range of options have been included. It is not clear whether these sites are identified in the Dudley, Sandwell, Walsall, and Wolverhampton Strategic Housing Land Availability Assessments (SHLAAs) , which provide a list of alternative sites to be considered for allocation. References are not clearly given to the evidence base supporting alternatives. The SA should also outline any initial high level appraisal that may have been undertaken of the sites, for example at the SA Scoping stage based on designations and/or subjective assessment and explain whether the considered list of alternatives was initially reviewed by the SA team to ensure that the relevant factors from the SA were being considered. If any site visits and desk-based research was undertaken using existing information this should also be outlined. The SA process should be iterative so that as further information becomes available, more detailed appraisal of sites is undertaken. A map demonstrating the location of the sites and a description, location, summary of evidence and constraint plans for each would be useful visual aids. It would be helpful to outline whether any sites submitted to the Council were excluded and not taken forward and the reasoning behind this, particularly if this was due to sustainability reasons or not, as the Tables in Section 6 outlining the reasons for site selection/rejection do not include sites which did not pass the ‘Gateway Test’ (Section 6.1.2).
• Reasonable alternatives – The Reg 18 SA Report should better explain whether the findings were integral to decision making and the process informed site selection and whether the constraints have informed the development of site concept plans. The assessment of alternative options should be clearer regarding the criteria used to determine significance, and in linking effect significance to the need for subsequent mitigation. For example, the ‘negative effect’ within the SA objective category in the key should note that this would require consideration of mitigation, and what this means for the policies/sites. A more thorough summary section would also provide more easily identifiable conclusions, identifying the preferred alternatives/sites and the reasons they are preferred over other alternatives, including how environmental/sustainability considerations informed this selection.
• Reasonable alternatives – A more thorough summary section would provide more easily identifiable conclusions, identifying the preferred alternatives/sites and the reasons they are preferred over other alternatives, including how environmental/sustainability considerations informed this selection.
• Consultation - Appendix B of the Reg 18 SA Report outlines the comments received on the SA Scoping Report and the Issues and Options SA Report from the relevant bodies (Natural England, Historic England and the Environment Agency) and the public, however this does not explain how and where in the Reg 18 SA Report the consultation responses have been addressed.
• Non-Technical Summary - There is no Non-Technical Summary (NTS) within the supporting documents. Whilst the BCP is at the Regulation 18 Consultation stage, it is good practice to have an NTS for each revision of the SA, so that it is clear how the SA has evolved through the iterations. This should be rectified at the Regulation 19 Consultation.
• Limitations and Assumptions - The Reg 18 SA Report should reiterate and expand on the limitations and assumptions set out in the SA Issues and Options Report, including the assumptions about secondary data, the accuracy of publicly available information, ensuring alternatives were appraised consistently, the number of policy guidance, the extent of the baseline data being so vast and subjective judgement.
2.6 Additional information to address the deficiencies identified and the points summarised above would increase the robustness of the SA in the reasons for selecting the chosen draft policy alternatives based on their sustainability merits and assist in achieving the right outcome at Examination.
3.0 Site Appraisal
Methodology
3.1 The site Land at Yieldfields, Bloxwich is one of 723 reasonable alternatives sites across the plan area for potential residential, employment, and Gypsies, Traveller and Travelling Showpeople use, assessed within the SA. The site has a draft strategic allocation for residential development in the Black Country Local Plan, under Policy WSA4. It has an indicative capacity of up to 978 homes and, as shown in the concept masterplan, these homes are proposed in addition to a 2-form entry primary school, Community Hub, open space and informal sports provision.
3.2 The SA assessed the reasonable alternatives sites against the 14 SA Objectives, as outlined in the SA. Table 1.1 shows the scoring criteria used to appraise the reasonable alternatives. Decision-making criteria are used to assist the scoring process for each objective. They are shown in Appendix 2 below.
Table 1.1: Criteria for assessment of effects
Score/Description
--/Likely to result in a major negative effect.
-/Likely to result in a minor negative effect.
0/Either no impacts are anticipated, or any impacts are anticipated to be negligible.
+/-/It is entirely uncertain whether impacts would be positive or negative.
+/Likely to result in a minor positive effect.
++/Likely to result in a major positive effect.
[See attachment for table]
Performance of Land at Yieldfields, Bloxwich
3.3 The scores for Land at Yieldfields, Bloxwich in the Reg 18 SA Report are as follows in Figure 1.1.
Figure 1.1: Land at Yieldfields, Bloxwich SA Scoring [Table]
/1/2/3/4/5/6/7/8/9/10/11/12/13/14
Policy Ref/Cultural Heritage/Landscape/Biodiversity/CC Mitigation/CC Adaption/Natural Resource/Pollution/Waste/Transport/Housing/Equality/Health/Economy/Education
WSA4/-/--/+/-/+/-/0/--/0/-/+/-/++/0/++/+/++
3.4 A site-specific appraisal has been undertaken by Barton Willmore, to review the site’s scores against the SA objectives in light of the environmental reporting that has been undertaken to inform the masterplanning process. The site appraisal follows the methodology and matrix as used in the Sustainability Appraisal for Policy WSA4 and reviews the site against the SA scoring criteria shown above. The sources used to inform the appraisal are as follows, comprised of baseline assessments undertaken at the site:
• Site Boundary Plan;
• Vision Document;
• Heritage Technical Briefing Note;
• Heritage Appraisal;
• Landscape, Visual and Green Belt Appraisal;
• Green Belt Advice Note;
• Existing Surface Water Overland Flows Plan;
• Preliminary Drainage Strategy;
• Technical Note on Mining Development Constraints Plan; and
• Preliminary Ecological Review: Constraints and Opportunities.
Summary of Site Appraisal
3.5 Following review of the SA, it is concluded that the site represents a justifiable location for future residential-led development, as presented in the concept masterplan, which proposes 978 homes, a new primary school and varied community, open space and recreational facilities. The site appraisal has reviewed the scores assigned to the site, against the 14 SA objectives, with due consideration to the environmental reporting undertaken for the site, and the vision document that informs the concept masterplan. Based on the reports available for the site, we consider that the site should be scored more highly against some SA objectives.
3.6 We agree with the SA’s scores for cultural heritage, pollution, waste, housing, health, economy, and education, skills & training. Of these, housing and health score the greatest and are expected to provide a significant, beneficial effect whereby the future development will add to the current services available in the area through the provision of land safeguarded for high-quality homes, a primary school and open space for recreational and community use. Of those that scored negatively, such as cultural heritage and waste, the site appraisal finds that the future development will likely have a minor adverse effect on the setting of the identified heritage features onsite, and on the waste produced during operation in addition to Walsall’s domestic waste.
3.7 The site has the potential to retain and enhance elements of the landscape and green infrastructure network. Using careful design and placement within the site, the future development will minimise its impacts on the heritage setting of locally identified sensitive features, and landscape views from residential and Public Rights of Way (PRoW) receptors, by using the existing landforms and enhancement of green infrastructure to screen the site from the view of sensitive receptors. Enhancement of the green infrastructure network will also provide benefit to the local Green Belt, by further supporting barriers to urban sprawl, and biodiversity features onsite through the provision of enhanced habitat and foraging provision. Further afield, statutory and non-statutory ecological designations outside of the site footprint are not expected to be adversely affected by the future development due to their distance from site, and intervening development.
3.8 The enhanced green infrastructure will also provide opportunities to enhance human health, through the provision of recreational and play space, and green routes for enjoyment. The site is within walking and cycling distance of numerous pedestrian and cycle networks, to which the future development will connect, therefore providing beneficial effects to local health through the encouragement of active travel, and a reduction in reliance on private cars; in turn this will benefit operational traffic produced by the future development. During construction, human and environmental health will be protected through the implementation of the CEMP.
4.0 Conclusion
4.1 The conclusion reached within this report, based on a review of the Reg 18 SA Report in Appendix 1, is that the SA process so far has two deficiencies and a number of areas that would benefit from further focus before/during the Regulation 19 consultation stage so that the process is as robust as possible. It is anticipated that the SA would then provide a comprehensive discussion around the likely effects of alternatives as evidence supporting the BCP as a reasonable strategy for sustainable development.
4.2 In addition, based on the site appraisal in Appendix 2, the potential development site ‘Land at Yieldfields, Bloxwich’ is a sustainable reasonable alternative to be selected for inclusion within any proposed site allocations within the BCP based on its location, opportunities and performance against the 14 SA Objectives, to aid sustainable development in this area. Based on the reports available for the site, we consider that the site should be scored more highly against some SA objectives.
[SEE ATTACHMENT FOR APPENDIX 1 AND APPENDIX 2]
APPENDIX 1:
SUSTAINABILITY APPRAISAL COMPLIANCE REVIEW
APPENDIX 2:
SITE APPRAISAL - LAND AT YIELDFIELDS, BLOXWICH
[----------------------- APPENDIX 3 ENDS -----------------------]
[Attachment: APPENDIX 4
YIELDFIELDS DELIVERY TRAJECTORY]
[See attachments for this appendix 4]
[----------------------- APPENDIX 4 ENDS -----------------------]
[Attachment: APPENDIX 5
TRANSPORT TECHNICAL NOTE (OCTOBER 2021)]
Technical Note
Transport Technical Note (October 2021)
1.1.1 Pell Frischmann has been commissioned by L&Q Estates to provide transport planning and highways consultancy services to support the draft strategic allocation of a site located off of Stafford Road, Bloxwich in the Emerging Black Country Plan (BCP). The location of the site, identified in Draft Policy WSA4, is shown in Figure 1.
Figure 1. Site Location
1.1.2 It is proposed that pedestrian and vehicle access to the site would be achieved via Stafford Road. An initial site access strategy is provided in Appendix A which shows that a new roundabout and priority access could be introduced to serve the site; this demonstrates that safe and suitable access to the site can be achieved, in line with the National Planning Policy Framework. However, it should be noted that the form and location of these is not
fixed at this stage.
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1.1.3 The site is included within Draft Strategic Allocation Policy WSA4 Yieldfields Farm and has an estimated capacity of 978 homes based on a net developable area of approximately 24.5 hectares.
1.1.4 This Technical Note has been produced to set out the sustainability credentials of the site, the access arrangements as well as the proposed trip generation and distribution and potential impact on the highway network.
2
2.1.1 The site is bounded to the north by fields with Newtown, Landywood and Cannock beyond in South Staffordshire District. To the east the site is also bounded by fields, to the south by Bloxwich Golf Course, to the west is Turnberry housing estate as well as being the site frontage bounded by Stafford Road.
2.1.2 Stafford Road is approximately 7.3 metres wide. The road is street lit and subject to a 30mph speed limit and forms part of a red route. To the north, Stafford Road provides access to Cannock and the M6 Toll and links to the A5. To the south, Stafford Road provides access to Walsall and the A4148 Walsall Ring Road that links to the M6 motorway at junction 10.
Figure 2. Local Highway
3
3.1
3.1.1 The Guidelines for Providing for Journeys on Foot1 document describes the ‘maximum’, ‘acceptable’ and ‘desirable’ walking distances. It suggests that in terms of commuting, walking to school and recreational journeys; walk
1 Guidelines for Providing for Journeys on Foot, Chartered Institution of Highways and Transportation
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Distances up to 1,000 metres respectively.
3.1.2 For non-commuter journeys, the guidance suggests that a walk distance of up to 1,200 metres can be considered, with the ‘desirable’ and ‘acceptable’ distances being 400 metres and 800 metres respectively.
3.1.3 Table 1 summarises the broad walking journey times that can fall under each category.
Table 1. Walk Journey Distance and Time Threshold
IHT Threshold/Distance (Metres)/Walking Time (Minutes)
/Commuting, Walking to school and recreation/Other non-commuter
Journeys/Commuting, Walking to school and recreation/Other non-commuter
Journeys
Desirable/500/400/6/5
Acceptable/1,000/800/12.5/10
Maximum/2,000/1,200/25/15
3.1.4 Figure 3
Figure 3. Walking Catchment
3.1.5 Figure 3 and Table 1 confirms that Bloxwich’s town centre, including the High Street shops are within convenient walking distance of the site, these shops include a Pharmacy, convenience stores, banks and a post office. Other available amenities within the catchment areas include primary and secondary schools, food stores, allotments, employment facilities, Bloxwich North Railway Station, and public houses. It is anticipated that the development at
Yieldfields will be supported by on-site and off-site infrastructure, including a new on-site primary school and local
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Transport Technical Not
health centre, in addition to a contribution towards improvements for off-site secondary school provision in North
Bloxwich.
3.1.6 Along the site frontage a footway is provided on the eastern side of Stafford Road. This footway provides access to the bus stops on Stafford Road as well as the residential area to the west of the site. To the south of the site the footways provide access into Bloxwich, whilst to the north this footway continues towards Newtown; the Stafford Road/Turnberry Road junction is signalised and includes refuges that allow pedestrians to cross with traffic safely.
3.1.7 A footpath is also present approximately 125m south of the Stafford Road/Turnberry Road junction providing a further, more direct route to Bloxwich North Railway Station through the Turnberry Estate. Alternatively, pedestrians can use the footways provided along Turnberry Road to access this station.
3.1.8 A signal-controlled pedestrian crossing is also provided on Stafford Road approximately 240m to the south of the
Stafford Road/Turnberry Road junction.
3.2
3.2.1 Local Transport Note (LTN) 1/04 states that there are limits to the distances generally considered acceptable for cycling. The mean average length for cycling is 4km (2.4 miles), although journeys of up to three times this distance are not uncommon for regular commuters. It is widely considered that cycling has the potential to substitute for short car trips, particularly those under 5km, and form part of a longer multi modal journey by public transport.
3.2.2 LTN 1/20 states ‘recent growth recorded in central London and other towns and cities following programmes of investment have illustrated that there is significant potential for change in travel behaviour and that more people cycle for everyday journeys where acceptable conditions are provided. Two out of every three personal trips are less than five miles in length an achievable distance to cycle for most people, with many shorter journeys also suitable for walking. For schoolchildren the opportunities are even greater: three quarters of children live within a 15-minute cycle ride of a secondary school, while more than 90% live within a 15-minute walk of a primary school”. Cycling is therefore an important journey to work mode that has the potential to substitute for short car journeys.
3.2.3 Figure 4 presented the 5km cycle catchment from the site. It shows that all of Bloxwich and surrounding residential and employment areas are within convenient cycling distance of the site. The catchment also extends towards Cannock with both the Orbital and Cannock Gateway retail parks within cycling distance of the site.
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Figure 4. Cycle Catchment
3.2.4 Figure 5 includes an extract of the Walsall cycle map. There are no dedicated cycle facilities on Stafford Road.
However, to the east of the site the Wyrley and Essington canal towpaths are available for cycle trips to and from the wider West Midlands area providing routes to Walsall to the south and Wolverhampton to the west of the site.
3.2.5 As outlined above a cycle connection is also available through the Turnberry Estate providing a more direct route to Bloxwich North Railway Station.
3.2.6 In addition, National Cycle Network (NCN) route 5 is also located to the east of the site and forms a long-distance route providing a mixture of on-road and traffic free sections towards Lichfield via Burntwood and Brownhills to the
northeast of the site and Smethwick via Walsall to the south of the site.
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Figure 5. Walsall Cycle Map Extract
3.2.7 The above demonstrates that the residents of the proposed development could safely and conveniently access key destinations such as Bloxwich Town Centre and Bloxwich North Railway Station as well as further away locations by cycling.
3.3
3.3.1 The nearest bus stop from the site is located on Turnberry Road approximately 650m (7.5 minute walk) from the centre of the site and this is served by the X51 bus service. Further bus stops are located to the south of the site approximately 750m (9-minute walk) and north approximately 950m (11.5 minute walk) from the centre of the site, which are also served by the X51 service as well as the 1 and 74 service.
3.3.2 Figure 6 displays the local bus routes passing the site.
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Figure 6. Local Bus Routes
3.3.3 Table 2 provides a summary of the available bus services.
Table 2. Bus Service Summary
Service Number/Route/ Destinations/Weekday Frequency/Saturday Frequency/Sunday Frequency
X51/Birmingham
Cannock via Walsall/
20 minutes/
30 minutes/
30 minutes
1/Walsall - Cannock via
Bloxwich/
30 minutes/
No Service/
No Service
74/Stafford Cannock via Bloxwich/
30 minutes/
30 minutes/
No Service
Note: Timetable information obtained August 2021, First/ Last service based on time service arrives/ departs the
nearest bus stop to the development
3.3.4 In summary, a good range of bus services are available within convenient walking distance of the site, which provide a direct link between the site and Bloxwich, Walsall, Stafford, Cannock and Birmingham and the surrounding areas. These buses operate throughout the day which also facilitates commuting into Walsall or Cannock.
3.3.5 There may also be potential to divert/ extend bus services though the site to help facilitate the use of sustainable transport and this opportunity would be considered as part of any future planning application for the site. However, existing service frequencies are sufficient to ensure that bus travel would be an attractive option, with internal routes to provide a direct linkage towards the nearest bus stops, and opportunities to upgrade existing stops, for example
with shelters and real time passenger information.
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ansport Technical Note
3.4
3.4.1 Bloxwich North railway station is located approximately 1.8km to the west of the site. Services are operated by West Midlands Railway between Rugeley Trent Valley and Birmingham International via Birmingham New Street, that provides further connects throughout the UK. Example frequencies and journey times of the rail services to key destinations are set out in Table 3.
Table 3. Rail Services Summary
Destination/Journey Time/Peak Time Frequency
Cannock/7 minutes/30 minutes
Walsall/8 minutes/40 minutes
Rugeley Trent Valley/20 minutes/30 minutes
Birmingham New Street/30 minutes/40 minutes
Birmingham International/55 minutes/40 minutes
3.4.2 The train station is likely to be a destination for residents and is easily accessible by walking (21-22 minute journey), cycling (5-6 minute journey) and public transport via the X51 bus service (3 minute journey) which passes the site, providing a range of opportunities for multi-modal sustainable travel journeys, including the first and last leg of journeys. These rail services operate at times throughout the day which also facilitate commuting.
3.5
3.5.1 The above demonstrates that the site is in a sustainable location within walking and cycling distance of the local services and amenities. The site also benefits from nearby bus stops with frequent services to Cannock and Walsall and a nearby railway station with frequent services to Birmingham New Street.
4
4.1.1 The total developable area for the site is approximately 24.5ha and it is anticipated that the site could be developed for approximately 978 dwellings as outlined in draft policy WSA4 of the draft strategic allocation identified in the emerging Black Country Plan.
4.1.2 It is proposed that pedestrian and vehicle access to the site would be achieved via Stafford Road as shown in the plan in Appendix A.
4.1.3 Vehicle access to the site is proposed onto Stafford Road via two new accesses; at this stage the first is proposed as a three-arm roundabout that will also assist in traffic calming on Stafford Road in response to the existing signage and speed cameras on approach to Bloxwich. The second is proposed as a priority ‘give way’ T-junction. Capacity of the access strategy is dependent on future junction modelling which would be undertaken as part of any future planning application. This may result in the need for the priority access to be amended to include a ghost island right turn lane, which is also considered feasible within highway boundary/the proposed allocation site. At this stage, the access strategy is not fixed and so the form and location may change, but importantly, demonstrates that safe and suitable access to the site can be achieved in line with the NPPF.
4.1.4 Opportunities for improvements will be explored at the Stafford Road/ Turnberry Road junction, to reconfigure the existing three-arm signalised junction to provide dedicated crossings to facilitate active travel connections towards Bloxwich town centre, the railway station and the local bus stops.
4.1.5 As shown on the indicative site access plan, pedestrian access to the site would be achieved via 3m wide shared use path provided adjacent to Stafford Road, connecting with the existing 2m wide footways to the north and south on Stafford Road as well as the Turnberry Estate with improvements to the Stafford Road / Turnberry Road junction to promote connectivity across Stafford Road.
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Transport Technical Note
4.1.6 Subsequently, adequate access for all modes of travel, including walking, cycling and public transport will be provided, in line with draft policy TRAN1 of the BCP.
5 Assignment
5.1
5.1.1 To quantify the impact of the proposed development on the local transport system, the number of person trips for all modes of transport that are likely to be generated by the development should be calculated.
5.2
5.2.1
Establish Houses Privately Owned category of the TRICS database were examined. This is considered a robust assessment as any development would also include a proportion of affordable housing.
5.2.2
All sites located in Greater London and outside of England were deselected. Only those sites classed as ‘edge of town’ and ‘suburban area’ were selected to the proposed allocation site.
5.2.3 Table 4 shows the residential trip rates and trip generation for the proposed development. A copy of the TRICS
output is attached at Appendix B.
Table 4. Residential Trip Rates and Generation
Time Period/Vehicle Trip Rates (Per Dwelling)/Traffic generation (978 Dwellings)
/Arrival/Departure/Two-way/Arrival/Departure/Two-way
AM Peak
(08:00 09:00)/
0.141/
0.378/
0.519/
138/
370/
508
PM Peak
(17:00 18:00)/
0.349/
0.161/
0.510/
341/
157/
498
5.2.4 As shown in Table 4, the proposed development could be expected to generate at total of 508 vehicle trips during the AM peak and 498 in the PM peak hour.
5.2.5 It should be noted that this is an initial assessment. As such, there are opportunities to significantly reduce the number of vehicle trips associated with the development when accounting for the development being underpinned by Decide & Provide (D&P) principles, with opportunities for internalisation of trips with the primary school / local centre, as well as the proximity of public transport and increased opportunities for home working. A robust Travel Plan will also be implemented at the site to increase the modal share of more sustainable modes.
5.3
5.3.1 To provide a more accurate representation of the existing and forecast modal split anticipated at the development site, the Census Journey to Work data for people travel to work within the ‘Walsall 006’ Middle Super Output Area has been analysed.
5.3.2 The method of travel data to work for the 2011 Census has been examined and modal splits calculated, the results are summarised below in Table 5.
Table 5. Method of Travel to Work
Method of Travel to Work/Modal Split
Car Driver/65.9%
Bus/14.2%
On Foot/8.2%
Car Passenger/7.4%
Bicycle/1.9%
Train/1.2%
Motorcycle/0.8%
Other/0.4%
Total/100%
5.3.3 Table 5 indicated that currently 15.4% of trips are made using public transport and 10.1% are walking/ cycling trips.
5.4
5.4.1 The modal splits outlined in Table 5 have been combined with the vehicle trip generation in Table 4 to calculate the two-way person trip associated with the proposed development, shown in Table 6.
Table 6. Multi-modal Trip Generation
Time Period/AM Peak/PM Peak
/Arrival/Departure/Two-way/Arrival/Departure/Two-way
Car Driver/138/370/508/341/157/498
Bus/29/79/108/74/33/107
On Foot/17/46/63/42/19/61
Car Passenger/15/42/57/38/18/56
Bicycle/4/11/15/10/5/15
Train/3/7/10/6/3/9
Motorcycle/2/4/6/4/2/6
Other/1/2/3/2/1/3
Total/209/561/770/517/238/755
5.4.2 Overall, it is anticipated that there could be approximately 118 additional two-way trips for public transport in the AM peak hour and 116 in the PM peak hour. There will be an additional 78 two-way trips in the AM peak for people travelling by foot and cycle, with 76 two-way trips in the PM peak.
5.4.3 The existing infrastructure and facilities are considered sufficient to accommodate the increased level of users.
Increased bus patronage may also provide the financial viability to increase the frequency of bus services close to the site. This would be examined in further detail as part of any future planning application. It should be noted that the above is based on existing travel patterns, however, the development would be underpinned by D&P principles and would look to instil sustainable travel behaviours immediately upon occupation.
5.5
5.5.1
Walsall 006. The origins of all trips to the area were separated from the data and a percentage demand was derived for all the destinations for vehicle driver trips using the most appropriate route to/from each area.
5.5.2 The indicative distribution of the development traffic is shown in Figure 7.
Figure 7. Development Traffic Distribution
5.6
5.6.1 The resulting assignment of development traffic is shown in Figure 8, and shows that the majority of traffic routes south towards Walsall though the Stafford Road/ Lichfield Road signalised junction.
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Figure 8. Development Traffic Assignment (Two-Way Vehicles)
5.6.2 Overall, the impact of the development traffic is likely to be constrained primarily to the A34 and A4124 corridors, with the majority of traffic travelling towards Walsall and M6 junction 10. Whilst there is anticipated to be an increase in traffic at a number of location in the vicinity of the site, the increase are not considered to be significant. At the planning application stage detailed assessments of the off-site junctions would be undertaken and appropriate mitigation measures identified as required, in line with draft policy TRAN3 of the BCP.
5.6.3 The development will be underpinned by D&P principles, with internal uses incorporated so as to minimise the number of external movements. Furthermore, sustainable modes will be maximised for external movements through improved connectivity towards the railway station and town centre.
5.6.4 Should traffic modelling reveal the need for mitigation measures at the above existing signalised junctions, then this will likely primarily form changes to signal timings to improve operational efficiency and alterations to the kerb line / lane positioning to increase stacking distances. There may also be opportunities to incorporate further entry lanes where highway boundary permits. For the Stafford Road roundabout junction, there is opportunity to upgrade this junction to signal control to provide additional capacity.
5.6.5 In conclusion, the potential traffic impact of the proposals should not be a barrier to the proposed allocation of the site.
6
6.1.1 The proposed layout of the development will be designed with the overriding philosophy of creating a sustainable development underpinned by D&P principles. By designing streets from the outset to be more pleasant places to be and secure by design with priority for active travel modes, people are more likely to use them for walking and cycling. These measures will assist in reducing the number of vehicle trips generated by the development.
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6.1.2 To further encourage sustainable travel and to reduce the need for residents to travel the following measures will be considered in the development of the site:
EV parking & charging infrastructure to reflect future demand and tie into low carbon energy strategy (in line with draft policy TRAN8 of the BCP).
Bike hire/share scheme at the site and other key locations
Mobility hub, including for example dedicated car club spaces and bicycle maintenance equipment;
Enhanced walking and cycle networks along active travel corridors towards Bloxwich North Railway Station and Walsall.
Greenways, open space & public space/realm incorporation
High quality public transport through/past the site using electric / hybrid vehicles and internal bus facilities including bus shelters with live timetable information
Enhancement of bus travel connections to the site through frequency improvements and extension, diversion and/or incorporation of new services.
6.1.3 The current parking standards in Walsall are set out within the Walsall Council Parking Strategy (adopted in 2008), and thus it is considered that this SPD should be updated to accord with the requirements of NPPF Paragraph 107 in terms of setting local parking standards. We consider that new parking standards should set out specific requirements for the provision for charging infrastructure for electric vehicles as part of developments.
6.1.4 A Travel Plan will also be included as part of any future planning application, which will detail a package of measures to promote sustainable travel to/from the site, in line with draft policy TRAN6 of the BCP, along with associated targets and monitoring programme.
7
7.1.1 Pell Frischmann has been commissioned by L&Q Estates to provide transport planning and highways consultancy services to support the proposed allocation of a site located off of Stafford Road, Bloxwich in the Emerging Black Country Plan.
7.1.2 The site is in a sustainable location within walking and cycling distance of the local services and amenities. The site also benefits from close bus stops with frequent services to Cannock and Walsall and a nearby railway station with frequent services to Birmingham New Street.
7.1.3 Vehicle access would be provided at two points off Stafford Road; whilst not fixed, at this stage this is proposed via a roundabout and a priority-controlled junction, the design of which would be in accordance with Walsall Councils Design Guidance. Pedestrian and cycle access is proposed via shared use paths adjacent to the site.
7.1.4 A trip generation and distribution assessment has been undertaken, which demonstrates the proposed developments traffic impact on the surrounding highway and nearby junctions. It has also been demonstrated that there are various opportunities for non-car-based travel to and from the site, which would further reduce the number of vehicle trips generated by the site.
7.1.5 The site will be developed as a sustainable community with the aim of encouraging active travel modes and reducing the number of vehicle trips generated by the development. Further consideration will be given to other measures to encourage sustainable travel including EV parking & charging infrastructure.
7.1.6 Overall, it is concluded that the proposed allocation site represents sustainable development, and no transport related issues should preclude delivery of the scheme.
[See attachment for illustrations and data contained in Appendix A and Appendix B]
[----------------------- APPENDIX 5 ENDS -----------------------]
[Attachment: APPENDIX 6
PRELIMINARY ECOLOGICAL REVIEW: CONSTRAINTS AND OPPORTUNITIES (JULY
2019)]
APPENDIX 6
PRELIMINARY ECOLOGICAL REVIEW: CONSTRAINTS AND OPPORTUNITIES (JULY
2019)
26036/A5/P4/WW/JE/bc October 2021
aspect ecology
Ecology Technical Note Project: Land at Yieldfields Farm, Bloxwich (EC04758) Preliminary Ecological Review: Constraints and Opportunities
July 2019
1. INTRODUCTION AND METHODOLOGY
1.1. Aspect Ecology has been appointed by Gallagher Estates to undertake an ecological survey of land at Yieldfields Farm, Bloxwich. The site is located to the north of Bloxwich and south of Landywood, being intersected by the A34 Stafford Road.
1.2. To inform the ecological constraints and opportunities of potential development at the site, a desktop study and Phase 1 habitat survey has been undertaken by Aspect Ecology.
1.3. To gather information on records of protected or notable species within the site and its surrounds, in addition to details of any ecological designations, Staffordshire Ecological Record (SER) and EcoRecord (the ecological database for Birmingham and the Black Country) were contacted in 2016.
1.4. Information on statutory designations was obtained from the online Multi-Agency Geographic Information for the Countryside (MAGIC) database, which utilises data provided by Natural England.
1.5. The site was originally surveyed in June 2016 in order to ascertain the general ecological value of the land contained within the boundaries of the site and to identify the main habitats and ecological features present. In order to ensure the baseline ecological position is fully up to date, update survey work was undertaken in May 2019 based on a reduced survey area (see Plan 4758/ECOl).
1.6. For each survey, the site was surveyed based on standard Phase 1 Habitat Survey methodology', whereby the habitat types present are identified and mapped, together with an assessment of the species composition of each habitat. This technique provides an inventory of the basic habitat types present and allows identification of areas of greater potential which require further survey.
2. ECOLOGICAL DESIGNATIONS
Statutory designations
2.1. No identified statutory ecological designations are present within the site. However, Wyrley
& Essington Canal Local Nature Reserve (LNR) is located adjacent to the west of the site. This
1 Joint Nature Conservation Committee (2010) 'Handbook for Phase 1 habitat survey: A technique for environmental audit.'
Aspect Ecology • Hardwick Business Park + Noral Way • Banbury + 0X16 2AF Tel: 01295 279721 + www.aspect-ecology.com
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aspect ecology
is a restored canal which features a variety of habitats, supporting some nationally scarce species. Public access is encouraged and managed via car parks at each end, a restored towpath and footbridges, and a number of information panels.
2.2. The next nearest statutory designation is Pelsall North Common LNR, located some 0.5km east of the site. This comprises an area of heathland, acid grassland and canals, with public access managed via a network of trails.
2.3. The nearest Site of Special Scientific Interest (SSSI) to the site is located approximately 1.5km to the east, comprising Cannock Extension Canal. This is also designated as a Special Area of Conservation (SAC), due to its population of the Annex 2 species Floating Water-plantain Luronium natans. The SSSI/SAC is the richest known waterway of its type in the county, in terms of its aquatic flora, and also supports an important invertebrate assemblage.
2.4. The only other identified European designation within 10km of the site is Cannock Chase SAC, located some 9.1km north of the site, and designated for its Annex 1 heathland habitats.
Non-statutory designations2
2.5. A number of non-statutory designations lie adjacent, or in close proximity, to the site. The Wyrley and Essington Canal, which lies adjacent to the west of the site as described above, is also designated as a Site of Biological Importance (SBI).
2.6. Newtown Pool Site of Importance for Nature Conservation (SINC) lies in close proximity to the south-west of the site, separated by Stafford Road. The designation comprises a large pool surrounded by wet woodland and grassland. Hobble End Biodiversity Alert Site (BAS) lies adjacent to the north of the site, comprising a pond, woodland and scrub.
2.7. A number of sites of potential wildlife value are also present in the local area. This includes Yieldfields Hall and Lord Hay's Branch Canal Potential Sites of Importance (PSls), both of which lie within the southern part of the site itself. Yieldfields Hall PSI is described as a series of pasture, mature hedges and a pond, where Great Crested Newts have been recorded. Lord Hay's Branch Canal comprises a former canal branch, abandoned in 1930 and filled in in 1954, now forming a linear band of scrub and grassland. A number of other PSls are located in close proximity to the south-east of the site, including Bloxwich Golf Club and Fishley Lane Hedges.
2.8. No areas of designated ancient woodland are present within 500m of the site.
2.9. Constraints and Opportunities. A number of statutory designations are present in the locality which should be further assessed for potential effects at the planning application stage. However, the two LNRs in close proximity to the site are relatively well screened from the site, whilst they are subject to considerable public use at present. Furthermore, it is considered that a sensitively designed layout can avoid any significant adverse effects on these and other designations.
2 The site straddles the boundary between Staffordshire and Birmingham. Non-statutory designations in Staffordshire comprise (i) Sites of Biological Importance (SBIs), which are of county importance and equivalent to County Wildlife Sites, and (ii) Biodiversity Alert Sites (BAS), which are of local importance or have potential to reach SBI standard through management.
Non-statutory designations in Birmingham comprise (i) Sites of Importance for Nature Conservation (SINCs),
which are of county importance, (ii) Sites of Local Importance for Nature Conservation (SLINCs), which are of borough importance, and (iii) Potential Sites of Importance (PSIs), which potentially contain important habitats but were yet to be evaluated against local site criteria or were yet to be formally adopted in 2016.
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aspect ecology
2.10. The site lies within the Impact Risk Zone (IRZ) for Cannock Extension Canal SSSI/SAC. This indicates that residential development at this location could potentially result in adverse impacts, and Natural England would expect to be consulted on a planning application. As such, further assessment of potential effects should be undertaken to inform any application. However, Cannock Extension Canal SAC is not a popular tourist destination3 and as such it is likely recreational effects can be mitigated through the provision of greenspace if necessary, whilst hydrological effects can be mitigated through sustainable drainage. Therefore, it is anticipated that mitigation, including a sensitively designed masterplan, could avoid adverse residual effects.
2.11. The site lies outside of the identified 8km Zone of Influence for Cannock Chase SAC for which contributions towards strategic mitigation are required, however, it lies within the wider
15km zone. Therefore, further assessment is recommended at the application stage to assess
the potential for cumulative effects. It is anticipated that this could be readily mitigated through the provision of greenspace.
2.12. It is also considered that effects on non-statutory designations can be avoided through a sensitively designed layout, including the use of buffering with semi-natural habitats adjacent to designations, which could provide an overall enhancement. The Potential Sites of Importance in the south of the site should be subject to further assessment, however it would appear unlikely that these would qualify as a local designation, whilst there is an opportunity to enhance retained habitats through appropriate management.
3. HABITATS AND ECOLOGICAL FEATURES
3.1. The site is dominated by agricultural land, formed by a mixture of arable, cattle-grazed pasture and silage fields. The fields are largely bound by a network of hedgerows and/or trees, many of which are mature in nature. A description of habitats recorded within the site is set out below, and shown on Plan 4758/ECO3.
Background records
3.2. A number of notable plant species have been recorded in the local area, including species of arable habitats such as Corn Spurrey Spergula arvensis, Field Woundwort Stachys arvensis and Cornflower Centaurea cyanus.
Arable
3.3. 2016 survey results. Several large arable fields are present within the site, which are cultivated for Wheat, Oat or Oilseed Rape production. The arable fields are generally intensively cultivated, with very little uncultivated field margin and few weed species present. Some of the arable fields contain relatively small uncultivated areas, which comprise grassland with locally abundant herbaceous species, albeit these areas are species-poor.
3.4. 2019 survey results. During the update Phase 1 survey conducted in May 2019, the site was recorded to continue to support a number of arable fields of a similar character to previously described in paragraph 3.3 above. An additional area of land contained within the 2019 survey area that was not subject to survey in 2016 was also recorded to support arable land, which is similar in nature to the other arable fields within the site.
3 As described in South Staffordshire Council's Allocation Sites for Housing, Employment and Gypsy, Traveler and Travelling Showpeople Habitat Regulations Assessment (November 2016)
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Yieldfields Farm , Bloxwich
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Semi-improved grassland
3.5. 2016 survey results. Much of the site is dominated by semi-improved grassland, which is used for cattle grazing or silage production. The cattle pastures tend to be stocked at a relatively low density, such that a variable sward length is present, including tall sward areas. The silage fields comprised a tall, very dense sward at the time of survey. The species composition of the pasture and silage fields are similar, being dominated by grasses typical of semi-improved neutral conditions such as Yorkshire-fog Holcus /anatus, Meadow Foxtail Alopecurus pratensis, Crested Dog's-tail Cynosurus cristatus, Perennial Rye-grass Lo/ium perenne and Cock's-foot Dactylis g/omerata. Herbaceous species tend to be sparse, and include species typical of nutrient enriched soils.
3.6. 2019 survey results. During the update Phase 1 survey undertaken in May 2019, the site was recorded to still be dominated by semi-improved grassland fields, of a similar nature to that described in paragraph 3.5 above.
Hedgerows, trees and scrub
3.7. 2016 survey results. The site supports an established network of hedgerows, which vary widely in their structure and management. Some are thick, bushy and tall, whilst others are defunct and limited to scattered shrubs and/or trees along a fence line. Many of the hedgerows feature standard trees, mostly in the form of Oak Quercus robur, Ash Fraxinus excelsior, Alder A/nus glutinosa and Sycamore Acer pseudoplatanus. Along some boundaries, trees form a continuous linear feature. A small number of more isolated trees are present along some boundaries and within fields.
3.8. Hawthorn Crataegus monogyna tends to be dominant within the hedgerows, which are also generally rather species-poor, although species-richness is variable between hedgerows. The ground flora of the hedgerows is generally species-poor, with ruderal and grassland species dominating. A number of hedgerows are associated with dry / wet ditches, as described below at paragraphs 3.10 and 3.11.
3.9. 2019 survey results. During the update Phase 1 survey conducted in May 2019, the site was recorded to continue to support a network of hedgerows of a similar character to described in paragraphs 3.7 and 3.8 above.
Watercourses and ditches
3.10. 2016 survey results. Several of the hedgerows support dry ditches, whilst wet ditches are present in places, mostly at the site boundaries. A network of wet ditches were present along the north-eastern site boundaries, although it is understood these are now outside of the site boundary.
3.11. The offsite Wyrley & Essington Canal lies adjacent to the west of the site, and separated from it by a steep bund which is overgrown with Bramble Rubus fruticosus agg.. The canal itself features a good coverage and diversity of aquatic plants.
3.12. 2019 survey results. During the update Phase 1 survey undertaken in May 2019, the watercourses and ditches were recorded to be as described in paragraph 3.11 above.
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Buildings and hardstanding
3.13. 2016 survey results. A number of buildings are present in the southern part of the site, associated with the active Yieldfields Farm. These comprise agricultural and residential buildings, of various construction types but tend to be relatively old and in a moderate state of repair.
3.14. 2019 survey results. During the update Phase 1 survey conducted in May 2019, the buildings were recorded to be as described in paragraph 3.13 above.
Woodland
3.15. 2016 survey results. A small area of woodland was present in the south-east of the site, although this is now located outside of the site boundary.
3.16. A number of areas of woodland and scrub lie adjacent to the site. These tend to be rather young and dense in nature, such that the ground flora is impoverished. The canopies are variously dominated by Sycamore, Oak and Ash.
3.17. An area of woodland to the north of the site, associated with Hobble End Biodiversity Alert Site, is more established. This area is dominated by Oak, over a sparse understorey and generally sparse ground flora, although ruderal species and Dog's-mercury Mercurialis perennis are locally dominant.
3.18. 2019 survey results. During the update Phase 1 survey conducted in May 2019, the offsite woodlands were recorded to be largely as described in paragraphs in 3.15-3.17 above, with the additional presence of Bluebell Hyacinthoides non-scripta noted.
Tall ruderal vegetation
3.19. 2016 survey results. Small areas of tall ruderal vegetation were recorded near the farm buildings towards the south of the site. These areas are species poor and dominated by Stinging Nettle Urtica dioica.
3.20. 2019 survey results. During the update Phase 1 survey carried out in May 2019, the areas of tall ruderal vegetation around the farm buildings were as described in paragraph 3.19 above. Additional areas of tall ruderal vegetation were recorded at the margins offields towards the west of the site.
Ponds
3.21. 2016 survey results. A small pond was recorded along the southern boundary of the site, which supported a very shallow water depth at the time of survey. The pond is heavily shaded by surrounding vegetation and is heavily silted. Two other offsite ponds are located in close proximity to the southern boundary, which are slightly larger but very shallow in nature.
3.22. 2019 survey results. During the update Phase 1 survey undertaken in May 2019, the pond along the southern site boundary, in addition to one of the offsite ponds, was recorded to be dry. The second offsite pond was recorded to support a shallow water level, as previously noted.
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Invasive species
3.23. 2016 survey results. A stand of Japanese Knotweed Fal/opia japonica was recorded in close proximity to the south of the site, forming a stand some 15 x Sm in size.
3.24. 2019 survey results. The stand of Japanese Knotweed was still recorded to be present. No other invasive species were recorded.
4. FAUNA
4.1. As part of the Phase 1 habitat surveys in 2016 and 2019, general observations were made of any faunal use of the site, with particular attention paid to the potential presence of protected or notable species. A preliminary assessment of the site's likely value to faunal groups is set out in the following sections, along with associated constraints and opportunities with regard to development.
Bats
4.2. Background records. Records were returned for 5 bat species within a 4km search radius around the site centroid, comprising Common Pipistrelle Pipistrellus pipistrellus, Soprano Pipistrelle P. pygmaeus, Brown Long-eared Bat Plecotus auritus, Noctule Nyctalus noctula and Daubenton's Bat Myotis daubentonii. None of these records relate to the site itself.
4.3. Preliminary assessment 2016. Few buildings are present within the site, although a cluster of agricultural buildings is present in the south. Some of these have potential to support roosting bats, in the form of raised tiles and loft voids. Elsewhere within the site, roosting opportunities are likely to be available within trees which bound many of the fields. It is therefore recommended that specific survey work is undertaken at the application stage to assess the status of roosting bats within the site.
4.4. In terms of foraging and commuting habitat, the majority of the site is of poor suitability for bats generally due to its open and semi-improved nature. However, the network of hedgerows and trees are likely to offer good foraging and commuting opportunities, particularly where these form dense, continuous features. As such, bat activity survey work should be undertaken at the application stage, to identify both species present and bat activity levels across the site.
4.5. Update survey results and assessment 2019. During the updated Phase 1 survey conducted in May 2019, the site was recorded to provide potential opportunities for roosting, foraging and commuting bats as described in paragraphs 4.3 and 4.4 above.
4.6. Constraints and opportunities. The proposals should seek to retain any confirmed bat roosts, or otherwise provide adequate mitigation and compensation. In addition, the proposals should seek to retain the network of hedgerows where possible, particularly where these are continuous.
4.7. The proposals present an opportunity to provide an enhancement for bats, through the creation of new roosting opportunities in the form of bat boxes. Enhancements to foraging and commuting bats could be provided by stocking up defunct hedgerows, and reinstating hedgerows which are no longer present.
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Other mammals
4.12. Background records. The protected species Water Vole Arvicola amphibius has been recorded within the local area, including along the Wyrley and Essington Canal adjacent to the west of the site. The Priority Species Brown Hare Lepus europaeus has also been recorded in the locality.
4.13. Preliminary assessment 2016. During the Phase 1 habitat survey undertaken in 2016, evidence of a number of mammal species of no particular conservation importance was recorded within the site, including Red Deer Cervus elaphus.
4.14. Few opportunities for Water Vole are present within the site, due to the scarcity of wet ditches with emergent vegetation. Nevertheless, it is recommended that the wet ditch in the west of the site is subject to a Water Vole survey to inform an application, albeit this is of poor suitability. The site is unlikely to support other protected mammal species such as Dormouse, due to the lack of extensive woody habitats and the site's location at the periphery of the species' range.
4.15. The site may also support other UK Priority Species of mammal, such as Brown Hare and Hedgehog. However, based on the nature of the habitats present and the lack of observations during the Phase 1 survey, the site is unlikely to be of particular importance to any such species.
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Yieldfields Farm, Bloxwich
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aspect ecology
4.16. Update survey results and assessment 2019. During the update Phase 1 survey conducted in May 2019, the site was recorded to support opportunities for other mammals as described in paragraphs 4.13, 4.14 and 4.15 above.
4.17. Constraints and opportunities. The site is relatively unconstrained in terms of other mammals. The provision of new landscape planting could provide benefits to a range of mammals such as Hedgehog, whilst new wetland features in the vicinity of the canal could potentially benefit Water Vole. The proposals also offer an opportunity to reopen wet ditches within the site, encouraging emergent vegetation which in turn could attract Water Vole.
Birds
4.18. Background records. Numerous records of birds were returned from the data search for the local area, many of which are wetland species which are unlikely to make use of the site. However, a number of notable farmland bird species have been recorded in the locality, including Skylark Alauda arvensis, Yellowhammer Emberiza citrinel/a and Barn Owl Tyto alba.
4.19. Preliminary assessment 2016. During the Phase 1 habitat survey undertaken at the site in
2016, moderate numbers of Skylark (Red Listed Bird of Conservation Concern) were recorded, with singing males recorded mostly from the arable fields. However, the winter• sown nature of many of the fields is likely to preclude successful breeding later in the season, reducing the site's value for this species.
4.20. Other Birds of Conservation Concern incidentally recorded within the site include Yellowhammer Emberiza citrinella (Red-listed) within hedgerows in the south-west of the site, Willow Warbler (Red-listed), Mistie Thrush (Red-listed), and Tawny Owl (Amber-listed). In addition, House Sparrow (Red-listed) and Swift (Amber-listed) were recorded around the farm buildings in the south of the site. Despite their conservation statuses, all of these species remain relatively common.
4.21. Update survey results and assessment 2019. During the update Phase 1 survey conducted in May 2019, no further Birds of Conservation Concern were recorded within the site.
4.22. Constraints and opportunities. Development of the site is likely to result in a change in the breeding bird assemblage within the site, with the possible reduction of numbers of farmland bird species such as Skylark, but with significant new opportunities created for declining urban species such as the UK Priority Species House Sparrow, Starling Sturnus vulgaris and Swift. These species could be particularly targeted for enhancement through benefits arising from the installation of bird nest boxes within new buildings. In addition, new landscape planting would provide enhanced nesting opportunities for a variety of other species in the long term, such as the Priority Species Song Thrush Turdus philomelos.
Reptiles
4.23. Background records. Few reptile records were returned for the local area, limited to Common Lizard Zootoca vivipara and Grass Snake Natrix natrix. Neither has been recorded within the site itself.
4.24. Preliminary assessment 2016. The site offers opportunities for reptiles in the form of tall• sward grassland and hedgerows. However, much of the tall-sward grassland comprises a very uniform, tall dense sward, which provides limited basking opportunities for reptiles. Furthermore, the silage fields appear to be cut annually, such that opportunities for reptiles are likely to be highly seasonal. Nevertheless, it is recommended that a reptile survey is
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undertaken at the application stage, to assess their presence/absence, distribution within the site and population size class.
4.25. Update survey results and assessment 2019. The update Phase 1 survey conducted in May
2019 recorded the site to support similar opportunities for reptile species as described above.
4.26. Constraints and opportunities. The site is considered unlikely to support a high density of reptiles. Should reptiles be present, appropriate mitigation should be provided to maintain opportunities for this species group within the site. The proposals provide a potential opportunity to enhance the site for reptiles, through the creation of new habitats centred on wildflower grassland and scrub, particularly where this provides connectivity across the site and to off-site habitats.
Amphibians
4.27. Background records. A large number of records of the protected species Great Crested Newt Triturus cristatus were retuned for the local area, particularly to the south-east and west, albeit not within the site itself. The Priority Species Common Toad Bufo bufo has also been recorded in the locality.
4.28. Preliminary assessment 2016. A single small pond was recorded within the site, along the southern boundary, whilst a high number of ponds are present in the near vicinity of the site. The single onsite pond appears to be of poor suitability for Great Crested Newt. However, this species is highly likely to breed in the wider locality, given the high number of nearby ponds and records of the species. Similarly, Common Toad is likely to breed in the local area. Therefore, specific survey work should be undertaken at these ponds at the application stage, where access can be arranged.
4.29. Update survey results and assessment 2019. During the update Phase 1 survey work carried out in May 2019, the single pond recorded along the southern boundary was noted to be dry and is therefore still considered to offer poor suitability for Great Crested Newt. However, offsite ponds are present within the immediate surrounds of the site which were noted to be suitable to support Great Crested Newt.
4.30. Constraints and opportunities. Great Crested Newts are likely to breed in nearby offsite ponds and enter the site in their terrestrial phase. However, the site's importance to this species is limited by the lack of onsite breeding opportunities, and any use of the site is likely to be in the near vicinity of offsite breeding ponds. Therefore, it is anticipated that amphibians can be adequately safeguarded under a sensitively designed scheme, particularly if this includes semi-natural greens pace in the vicinity of offsite ponds. Enhancements could be provided for amphibians through the creation of new waterbodies within the site, for example, as part of sustainable drainage systems.
Invertebrates
4.31. Background records. No records of protected invertebrate species were returned from the desktop study. However, numerous records of UK Priority Species were returned, the majority relating to butterflies and moths which appear to be well recorded in the area.
4.32. Preliminary assessment 2016. The majority of the site is dominated by arable and semi• improved grassland habitats which are species-poor in nature. These habitats are common in the locality and are unlikely to support an important invertebrate assemblage. However,
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the network of hedgerows and trees are likely to be of somewhat elevated value in the context of the site, whilst offsite habitats such as ponds, woodland and the canal to the west may be of local or higher value.
4.33. Update survey results and assessment 2019. During the update Phase 1 survey work undertaken in May 2019, the site was recorded to support potential habitats for invertebrate species as described above in paragraph 4.32.
4.34. Constraints and opportunities. Habitat features of somewhat elevated importance should be retained under the proposals where possible, whilst buffering should be considered adjacent to offsite habitats of potential value to invertebrates. The proposals could provide a significant enhancement to invertebrates, particularly through the reinforcement of existing hedgerows with native species, reinstating missing hedgerows, and creating new habitats such as wildflower grassland and native landscape planting.
5. CONCLUSION
5.1. A number of statutory and non-statutory designations are present in the vicinity of the site, whilst part of the site itself has been identified as a potential non-statutory designation. It is anticipated that the ecological interest of these designations can be adequately safeguarded under a sensitively designed scheme, albeit further assessment is recommended at the application stage.
5.2. The site is dominated by agricultural land, comprising arable and semi-improved grassland, which is of negligible to low ecological value. The fields are largely bound by a network of hedgerows and/or trees, some of which are well-established. These features are of elevated value in the context of the site. Other habitats are limited in extent, comprising scrub, tall ruderal vegetation, a ditch, a pond, buildings and hardstanding.
5.3. A number of protected faunal species are likely to make use of relatively small parts of the site. These are likely to include roosting and foraging bats, nesting birds, reptiles and Great Crested Newts. It is therefore recommended that further survey work is undertaken at the application stage, whilst it is anticipated that any species could likely be safeguarded and associated habitats potentially enhanced under a sensitively designed masterplan.
5.4. Significant opportunities for biodiversity are present under any proposals. These arise following the removal of land from intensive agricultural production, whilst in addition the creation and reinforcement of green infrastructure across the site, incorporating existing features of ecological value such as hedgerows and mature trees, would give rise to significant potential gains. As such, it is concluded that the proposals are highly deliverable in ecological terms.
[----------------------- APPENDIX 6 ENDS -----------------------]
[Attachment: APPENDIX 7 Heritage Appraisal]
APPENDIX 7
HERITAGE APPRAISAL (SEPTEMBER 2019)
Heritage Appraisal
Yieldfields Hall Farm, Bloxwich
Heritage Appraisal
Yieldfields Hall Farm, Bloxwich
Project Ref:
Status: 26036/AS/Pl/JS/SO
Draft 26036/AS/Pl/JS/SO
Final 26036/AS/Pl/JS/SO
Final
Issue/Rev: 01 01 02
Date: Prepared by: Checked by: Authorised by: August 2019
James Sugrue
Joanna Burton
Gareth Wilson August 2019
James Sugrue
Joanna Burton
Gareth Wilson September James Sugrue Joanna Burton
Gareth Wilson
Barton Willmore
St Andrews House St Andrews Road Cambridge
CB4 lWB
Tel: 01223 345 555 Ref: 26036/A5/P 1/JS/SO
File Ref:
Date: 26036.Pl.HS.JS
COPYRIGHT
The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore Planning LLP.
All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks.
CONTENTS
1.0 Introduction
2.0
3.0 Identified Heritage Constraints
4.0 Analysis: Principle of Development
5.0 Conclusions
APPENDICES
Appendix 1: Site Boundary Plan
Appendix 2: List Descriptions
Introduction
1.0 INTRODUCTION
1.1 This Heritage Appraisal has been prepared by Barton Willmore on behalf of L&Q Estates to support the promotion of an urban extension to the north of Bloxwich. The land under promotion (the site) is located north of Bloxwich Golf Course and south of Great Wyley. The site extends to approximately 120 hectares located on land either side of the A34
Stafford Road. The southern part of the site lies within the administrative boundary of
Walsall whilst the northern part is within South Staffordshire.
1.2 This appraisal has been prepared to advise the client team on the deliverability of development on the site with reference to the historic environment constraints. It deals specifically with the setting of Yieldfields Farm, which is included in the site, and Bloxwich Golf Club clubhouse, located outside of the site (Fig. 2); principles relating to the reuse of the listed building/sat Yieldfields Farm are considered separately.
1.3 It has been informed by a desk-top review including a review of the historic map evidence together with a site visit made on 26 July 2019. Specific reference has been made to the Site Selection Methodology set out in Historic England's guidance document 'The Historic
Environment and Site Allocations in Local Plans: Historic England Advice Note 3' (2015).
\ GREAT
\ WYRLEY
Figure 1: Strategic Overview Plan showing location of the site defined by the darker orange, and the Bloxwich Golf Course and North Walsall Cemetery defined by lighter pink (Barton Willmore).
Page 1
2.0 HERITAGE DECISION MAKING FRAMEWORK
Plan Making
2.1 Paragraph 185 of the National Planning Policy Framework (NPPF) (2019) requires that Local Plans should 'set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. This strategy should take into account:
a) the desirability of sustaining and enhancing the significance of heritage assets, and putting them to viable uses consistent with their conservation;
b) the wider social, cultural, economic and environmental benefits that conservation
of the historic environment can bring;
c) the desirability of new development making a positive contribution to local character and distinctiveness; and
d) opportunities to draw on the contribution made by the historic environment to the character of a place.
2.2 In line with paragraph 185 of the NPPF, the Planning Practice Guidance (PPG) (updated
2019) for Historic Environment advises plan-making bodies to identify specific opportunities for conservation and enhancement of heritage assets, including their setting. This could include development that will make a positive contribution to, or better reveal the significance of the heritage asset, or reflect and enhance local character and distinctiveness with particular regard given to the prevailing styles of design and use of materials in a local area.
2.3 Historic England have produced 'The Historic Environment and Site Allocations in Local Plans: Historic England Advice Note 3' (2015) to set out advice on evidence gathering, site selection and allocation policies to make sure heritage considerations are integrated into the site selection methodology.
Development Management
2.4 The current development management decision-making framework is set out below for reference.
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Legislation
Planning {Listed Building and Conservation Areas} Act 1990
2.5 Listed buildings and conservation areas are protected by the provisions of the Planning
(Listed Buildings and Conservation Areas) Act 1990.
2.6 Section 16 applies to applications for listed building consent. It states that the planning authority or Secretary of State shall have 'special regard to the desirability of preserving the building or its setting or any features of special architectural or historical interest which it possesses.' It goes on to state that consent shall enure the benefit of the building and all persons interested in it.
2.7 Section 66 of the Act outlines a similar duty when exercising planning functions in relation to development affecting listed buildings and their setting.
Local Plan Policy
Black Country Core Strategy (adopted 2011)
2.8 'Policy ENV2 Historic Character and Local Distinctiveness' reinforces legislation by aiming to protect and promote special qualities, historic character and local distinctiveness in order to maintain a sense of place. It states that 'development proposals will be required to preserve and, where appropriate, enhance local character and those aspects of the historic environment together with their settings and that where a proposal has the potential to impact on the distinctive elements of historic character the proposal should be supported by evidence to demonstrate that all aspects of the local character have been
'fully assessed and used to inform proposals'
Walsall Unitary Development Plan (UPD) (adopted 2005)
2.9 The Walsall UDP was adopted in 2005 to cover the period up to 2011. Most of the policies have been 'saved' until such a time that they are replaces by policies from the Local Plans. Some of the previously saved policies have been replaced by adopted Site Allocation Document policies and/or Area Action Plan policies.
2.10 'Policy ENV27: Buildings of Historic or Architectural Interest' is a 'saved policy'. It addresses development with a potential to impact buildings of historic or architectural interest. The policy reads as follows:
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(a) "Alteration, extension or any other form of development involving a listed building or its setting will only be permitted where it can be clearly demonstrated by the applicant that the internal and/or external appearance, character and value of the building, its curtilage and the contribution the building makes to the surrounding area in which it is situated are not adversely affected by the proposals. This would include the permanent removal of any part or feature that contributes to its special architectural or historic interest, whether or not specifically mentioned in its listing description. The submission of full details of any changes that materially affect the special architectural or historic interest of a listed building and/or its curtilage will be required as part of any Listed Building Consent (LBC) application.
(b) The change of use of a listed building will only be permitted if there will be no detrimental impact on the character and appearance of the building and/or its setting.
(c) The Council regards the demolition of a listed building as a matter of last resort. LBC for the demolition of a listed building will only be granted where the applicant can demonstrate that:-
I. The building would be unviable in its existing (or last permitted) use, all reasonable efforts having been made to sustain it.
II. There is no alternative use to which the
building can be converted, all reasonable efforts having been made to identify such an alternative.
III. The building cannot be practically
incorporated within the proposed development scheme.
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(d) Where there is no other option available, the Council will require the applicants to undertake a detailed building recording scheme, to a specified standard, prior to any demolition taking place.
(e) Listed Building Consent and planning permission for "enabling development" - that is, development intended to provide funding for the reinstatement and re-use of a listed building - will only be granted where:- • The reinstatement of the Listed Building is guaranteed. This may require some or all of the reinstatement works to take place as part of the first phase of the scheme. • Such development will not harm the building's architectural or historic value, or the building's immediate setting. • A full justification is provided to show that the proposal is both necessary and capable of producing the desired result. The development does not compromise other policies of this Plan, including protection of the Green Belt."
2.11 Policy ENV28: The 'Local List' of Buildings of Historic or Architectural Interest states that the Council will not grant planning permission for the demolition or adverse alteration of a 'local list' building. It makes no direct reference to their setting.
South Staffordshire Local Plan Core Strategy Development Plan Document
{DPD} Adopted December 2012
2.12 The Core Strategy sets out the long-term vision, objectives and planning policies to deliver a sustainable future for the District. 'Policy EQ3: Conservation, Preservation and Protection of Heritage Assets' sets out the historic environment strategy. The relevant sections are:
b) "The Council will support and encourage measures which secure the improved maintenance, management and sustainable reuse of heritage assets, particularly those which are identified nationally or locally as being at risk. Where necessary
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an assessment will be made of whether the benefits of a proposal for enabling development, which would otherwise conflict with planning policies but which would secure the future conservation of a heritage asset, outweigh the disbenefits of departing from those policies.
c) The Council will ensure that development which affects a heritage asset or its setting will be informed by a proportionate assessment of the significance of the asset, including its setting, which is likely to be affected by the proposals. These will be judged by considering the extent to which an asset's archaeological, architectural, historic or artistic interest will be harmed, including its conservation, in the interest of present and future generations.
e) The Council will consider the significance and setting of all proposed works to heritage assets, informed by relevant guidance that is supported by English Heritage. In addition the following principles will be adhered to:
• minimising the loss and disturbance of historic materials
• using appropriate materials, and
• ensuring alterations are reversible
f} The Council will require all works proposed to heritage assets, or sites with the potential to include assets, to be informed by a level of historical, architectural and archaeological evidence proportionate to their significance. Where appropriate, the Council may also require historical research and archaeological recording to be undertaken before works to a heritage asset commence.
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Heritage assets including Listed Buildings (and those on a local list} Registered Parks and Gardens (and other historic landscapes} Conservation Areas and Scheduled Ancient Monuments are identified on the Policies Map and Inset Plans. Development proposals should be consistent with the NPPF, the adopted Village Design Guide Supplementary Planning Document (or subsequent revisions} and other local planning policies."
Material Considerations
National Planning Polley Framework {NPPF} 2019
2.13 The NPPF sets out government planning policy. Chapter 16 sets out policies for conserving and enhancing the historic environment.
2.14 Paragraph 192 states that local planning authorities, in determining planning applications, should take account of: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and the desirability of new development making a positive contribution to local character and distinctiveness.
2.15 Paragraph 193 advises that great weight should be given to an asset's conservation; the more important the asset, the greater this weight should be. It goes on to state that significance can be harmed or lost through alteration or destruction of the heritage asset, or development within its setting. Any such harm or loss should require clear and convincing justification.
2.16 Paragraphs 195 and 196 set out two decision-making tests where proposals would lead to substantial and less than substantial harm respectively. Paragraph 195 guides that substantial harm to or total loss of significance should not be permitted unless that harm is necessary to deliver substantial public benefits that would outweigh that harm or loss, or other criteria are met.
2.17 Paragraph 196 guides that where a development proposal would lead to less than substantial harm, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.
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2.18 Paragraph 197 of the NPPF guides that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. A balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset in determining applications affecting non-designated heritage assets.
2.19 Paragraph 200 guides local planning authorities to look for opportunities for new development within conservation areas and within the setting of heritage assets to enhance or better reveal their significance. Proposals that preserve those elements of the setting that make a positive contribution to or better reveal the significance of the asset should be treated favourably.
2.20 Implementation of the NPPF is supported by the Planning Practice Guidance (PPG), 2014 (updated 2019).
2.21 Paragraph ID: 18a-002-20190723 guides that conservation is an active process of maintenance and managing change.
2.22 Paragraph ID: 18a-003-20190723 guides that a positive strategy to the conservation and enjoyment of the historic environment could include development that will better reveal the significance of heritage assets and reflect and enhance local character and distinctiveness.
2.23 Paragraph ID: 18a-020-20190723 provides examples of heritage benefits, including:
• sustaining or enhancing the significance of a heritage asset and the contribution of its setting;
• reducing or removing risks to a heritage asset; and
• securing the optimum viable use of a heritage asset in support of its long-term conservation.
Best Practice Guidance
2.24 The 'Good Practice Advice in Planning (GPA) Note 3: The Setting of Heritage Assets' (second edition) (2017) has been produced by Historic England to set out guidance on managing change within the setting of heritage assets, including archaeological remains and historic buildings, sites, areas, and landscapes. It advocates a staged approach to
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assessing significance and the impact of development within the setting of heritage assets.
2.25 The Historic England 'Advice Note 10: Listed Buildings and Curtilage' (2018) has been produced to help identify buildings and other structures within the curtilage of a listed building and therefore treated as part of the listed building. It is based on the current legislative provision in the Planning (Listed Buildings and Conservation Areas) Act 1990 (S. 1[5]) and consideration of listed buildings and curtilage in legal cases.
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Identified Heritage Constraints
3.0 IDENTIFIED HERITAGE CONSTRAINTS
3.1 Step 1 of the Site Selection Methodology set out in Historic England's Advice Note 3 'The Historic Environment and Site Allocations in Local Plans' seeks to identify which heritage assets are affected by the potential site allocation. These have been identified below following a desk-top study and fieldwork.
3.2 A search of the National Heritage List for England has identified the following designated heritage assets located approximately within 1km of the site (see Appendix 3 for listed building and conservation area plans):
• Yieldfields Hall Farmhouse, Grade II listed building, located within the site;
• Bloxwich Golf Club Clubhouse, Grade II listed building, located c.185m S of the site;
• Bloxwich Park Conservation Area, located c. lkm S of the site;
• Royal Exchange Public House, Grade II listed building, located c.l.Olkm S from the site;
• Pelsall Works Bridge Wryley Essington Canal, Grade II listed building, located approximately 1.07km E of the site;
• Landywood Farmhouse, Grade II listed building, located c. l. lSkm NW of the site.
Figure 2: Indicative site boundary with locations of Yieldfields Hall Farmhouse (Grade JI) and
Bloxwich Golf Club Clubhouse (Grade JI).
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Identified Heritage Constraints
3.3 The proximity of the site to Yieldfields Hall (Grade II) and Bloxwich Golf Club Clubhouse
(Grade II) means there is a potential for development to impact these buildings.
3.4 Bloxwich Park Conservation Area and the Royal Exchange Public House (Grade II and located within the conservation area) are within the centre of Bloxwich. They are sufficiently removed and screened from the site by later suburban development that they will not be affected.
3.5 Pelsall Works Bridge (Grade II) is screened from the site by intervening vegetation and topography such that development on the site is unlikely to be visible from the bridge. If there are views, they are likely to be very limited, such that there will be no material effect on the listed building.
3.6 Landywood Farmhouse (Grade II) is located over 1km from the site and is screened from views by development along Broad Lane, Springhill. The distance and intervening development are such that development on the site will not have any impact on the listed building.
3. 7 A search of locally listed buildings within Walsall and South Staffordshire local lists has identified that there are no locally listed buildings located within the site. Within 1km there are two locally listed buildings in Walsall: the (former) engine house & boiler house, Fishley Colliery No. 4 and Barn, Poplars Farm, both located on Fishley Lane. They are both of a sufficient distance and well screened from the site by mature tree planting such that, subject to scale and detailed design, it is unlikely that development on the site will have any impact on the way in which these assets are experienced. No locally listed buildings were identified within a 1km search of the South Staffordshire Local List.
3.8 In addition, the route of The Lord Hayes Canal branch (now disused) is located within the site and has some heritage interest associated with the local economic history of the region. It does not appear to have been included as a locally listed building however a review of list has identified a large number of canal structures. The former canal and any associated structures therefore have potential to be non-designated heritage assets and if so, would constitute a material consideration.
3.9 For the reasons as set out above, this appraisal will only consider the potential constraints of Yieldfields Hall and Bloxwich Golf Club Clubhouse. They are discussed in more detail below.
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Identified Heritage Constraints
Brief History of the Site
3.10 Located between the settlements of Bloxwich to the south and Cannock to the north, the land where the site is located includes Yieldfields Hall and agricultural field systems surrounding the settlement of Newton. The A34 Stafford Road divides the site and forms a historic route between Cannock in the north and Bloxwich in the south.
3.11 The site is divided into two districts with South Staffordshire in the north and Walsall in the south. The boundary follows the historic route of Essington Wood Brook.
3.12 There are records of the land holding at Yieldfields dating back to the 16th century when in 1549 the Crown sold land called 'Yeld feldes' in Little Bloxwich. It had belonged to the chantry in Walsall church founded by John de Beverley and William Coleson, who had given houses and land in the parish as part of the endowment in 1365. From the medieval period onwards, the land is likely to have been managed farmland, which continues to characterise the land today. The land is now made up of amalgamated field systems, that have developed through the merger of enclosed field systems that are recorded on the
1883 first edition Ordnance Survey (OS) map (see Figure 3).
3.13 The site is also partially located on the Cannock Chase coalfields, where coal deposits close to the surface have resulted in a long history of coal extraction. As early as 1746
Jonas Slaney was working coal at Little Bloxwich. In 1774 a mine at Great Bloxwich, next to the Walsall-Stafford turnpike road, was advertised for sale; the coal was at a depth of
111 ft.1 The extent of coal extraction is visible on the 1883 first edition OS map, the Cannock Lodge Colliery was located within the site in the area west of the A34 Stafford Road, Norton Cannock Colliery located east of the A34 Stafford Road and Fishley Colliery ( opened c.1865) located to the east of the site. The industry declined in the early 20th century with many collieries in Walsall and South Staffordshire failed or abandoned.
3.14 From the time of the publication of the 1919 OS map, where all the collieries are shown in use, to the publication of the 1921 OS map, all of the collieries in the area became disused and remain represented as such on the maps until the late 20th century when the sites are either developed or returned to agricultural or woodland. Late-19th century workers houses in Newton and on Long Lane are most likely a development for the colliery workforce.
1 A P Baggs, G C Baugh and Johnston D A, 'Walsall: Economic history', in A History of the County of Stafford: Volume 17, Offlow Hundred (Part), ed. M W Greenslade (London, 1976), pp. 180-208. British History Online http://www.british-history.ac.uk/vch/staffs/vol17/pp180-208 [accessed 26 August 2019].
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Identified Heritage Constraints
3.15 The coalfields resulted in the development of some of the communication routes within the site. The Wyrley and Essington Canal, built under an Act of parliament in 1794, is located to the south east of the site. It was constructed to transport coal through to the Birmingham Canal Navigations. The Lord Hayes Branch (now disused) is located across the site and was built under the 1794 Act and connected Cannock Lodge Colliery and Fishley Colliery to the Wyrley and Essington Canal. The closure of the collieries is likely to have marked an end to the function of the canal and an Act of abandonment in 1954 officially ended operation of the Lord Hayes Branch. The railways also serviced the collieries, with the line between Rugeley Trent Valley and Walsall by the South Staffordshire Railway, and the Cannock Mineral Railway in 1858 (this was absorbed into the South Staffordshire Railway by 1869). The 1883 first edition OS map shows a branch with sidings running directly into Cannock Lodge Colliery. As with the canal, the closure of the colliery resulted in the removal of this branch and it is no longer represented on the 1921 OS map.
3.16 In the second half of the 20 century to the present the site can be characterised as agricultural, with a mix of pastural and arable farming. In the wider landscape, major changes include the opening of Bloxwich Golf Club, to the south of the site, opened in
1924. The row of semi-detached houses north of Newton, on the A34 Stafford Road, date to the 1930s. The Turnberry Estate, located west of the A34 opposite Yieldfields Farm, was developed in the 1980s with North Walsall cemetery is also situated in the northernmost part of the Turnberry Estate.
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Identified Heritage Constraints
Figure 3: Detail from 1st edition OS map, 1:2500 scale.
Statement of Significance
3.17 Step 2 of the Site Selection Methodology established in Historic England's guidance on site allocations is to establish what contribution the site makes in its current form to the significance of the heritage assets identified in Step 1. An appraisal of their heritage significance is set out below.
Yieldfields Hall Farmhouse
3.18 Yieldfields Hall is a Grade II listed farmhouse that was formerly a private house dating to the 18" century. As a Grade II listed building, it should generally be considered of high significance.
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Identified Heritage Constraints
3.19 The architectural style of the house suggests an early-18 century date. Key external features include the segmental arches above the windows on the first floor, the exposed box sash windows on the first and second floor, the bold string course in brick and the double pile plane with overhanging cornice of the pitched roof. The red brick was also fashionable in the first half of the 18\ century. The earliest phase is constructed with handmade bricks in a Flemish bond.
3.20 The core of the 18" century house has undergone later alterations and additions. In the earlier 19 century a two-storey block was added to the rear of the house and the front range was extended to the east c.1900. Another small lean-to extension is located to the rear of the property and on the ground floor two canted bay windows were added at some point in the 19 century (see Figures 5 and 6). Yieldfields Hall has special architectural interest as a high-quality example of an 18\ century domestic house and later farmstead.
3.21 The house has historical interest in its associations to locally notable families. In particular, the association with Catholic recusants in the 17\ century (presumably in an earlier house) and the 18 century. Following the Roman Catholic Relief Act 1791
Yieldfields Hall was recognised as a place of religious worship, the priest, a Mr John Perry, paid 5 shillings for the licence. This is likely to have ended following the construction of the Catholic Chapel of St. Thomas the Apostle in Bloxwich.
3.22 Ancillary farm buildings surrounding Yieldfields Farm are a mixture of dates, including examples dating to the 19t century. These are characterised by their red brick construction, windows with segmental arches and blue engineering brick sills and pitched slate roofs, these buildings can be seen on the first edition 1:2500 scale OS map, dated
1884 (see Figures 3, 8 and 9). Pre-1948 buildings on the site that are in the same ownership at the time of listing and ancillary in use may be considered to be curtilage listed.
Setting
3.23 Yieldfields Hall Farmhouse is located within a complex of ancillary agricultural buildings that form the immediate setting of the building. The agricultural land surrounding Yieldfields Hall has a historic functional and associative relationship with the farmhouse. The house was not always a farmhouse but was built on the outskirts of the town as a rural property within easy access of the surrounding settlements. As a large house built within a rural location, the surrounding agricultural landscape makes a positive contribution to the interest of the building in forming an open countryside setting intended
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Identified Heritage Constraints
for a large house of this status and latterly, its agricultural function. The gardens and formal outlook of the house are to the south and west of the house and would be the most sensitive area to change.
3.24 A short access track off the A34 Stafford Road, that runs from west to east to the south of the property, marks the original access. This track continues to run in a straight line to the east and historically turned south to join Fishley Lane. To the east of the farm the track is lined with mature trees that are also shown on the pt edition OS map dated 1883. The property also accesses the A34 Stafford Road from the rear of the property.
3.25 The immediate setting includes gardens to the front, east and west of the property that are enclosed by a brick wall. This creates a domestic curtilage that gives way to the surrounding agricultural land. A small bungalow to the south of Yieldfields Hall and later modern agricultural buildings have no architectural or historic interest and make no contribution to the setting of the Farmhouse.
3.26 Yieldfields Hall's location next to the A34 Stafford Road contributes to our understanding of the building as a private residence and the historical relationship with surrounding towns. The house was intended to be visible from the road and there is an important view of the house when approached from Bloxwich. The A34 Stafford Road forms a border to the west, beyond which is the 1980s Turnberry Estate which makes no contribution to the interest of the listed building.
Figure 4: View from A34 Stafford Road north towards Yieldfields Hall Farmhouse.
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Identified Heritage Constraints
Figure 5: Yieldfields Hall, view facing north to the front elevation.
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Identified Heritage Constraints
Figure 6: Yieldfields Hall Farmhouse. View facing south to rear of building showing the two extensions to the main house; extension to the rear 19 century and extension to the side c. 1900.
Figure 7: View west towards Yieldfields Hall Farm showing surrounding field systems and tree lined track.
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Identified Heritage Constraints
Figure 8: View facing west towards ancillary buildings within Yieldfields Hall Farm.
Figure 9: View facing south-east towards an ancillary building within Yieldfields Hall Farm.
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Identified Heritage Constraints
Bloxwich Golf Club Clubhouse
3.27 Bloxwich Clubhouse has been developed from a former early 19 century house, known as 'Field House'.
3.28 The special historic and architectural interest of the house relates to the surviving fabric of the former 'Field House' and what it tells us of historic past lives, architectural fashions and regional building variations. It is a good example of a large private residence built in the late Georgian style with a symmetrical composition (see Figure 10).
3.29 The subsequent development of the property as the clubhouse for Bloxwich Golf Club and the golf course itself, make no contribution to the heritage interest of the property.
Setting
3.30 The setting of the clubhouse has changed significantly. Having historically enjoyed an open setting to all aspects, including what would appear to have been an area of parkland to the east, its setting is now characterised by modern development to the west and south and the golf course itself to the north and east.
3.31 The golf course landscaping completely screens views from the clubhouse to the site, which is located to the north of the golf course, and vice versa. This includes a mature tree lined boundary along the northern border of the golf course that screens views to the north.
3.32 In conclusion, the site in its currently form is not considered to make any material positive contribution to the way in which the Clubhouse is experienced.
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Identified Heritage Constraints
Figure 10: View facing north towards 8/oxwich Golf Club clubhouse.
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Analysis: Principle of Development
4.0 ANALYSIS: PRINCIPLE OF DEVELOPMENT
4.1 Step 3 of the Site Selection Methodology is to identify what impact development on the proposed allocation might have on the significance of any heritage assets. This section sets out a review of the potential heritage impacts that may result from such development.
4.2 Development at 'Land at Yieldfields Farm', as set out in the 2018 Vision document, will provide 'A sustainable, residential-led urban extension to Bloxwich, providing up to 2,000 new homes, primary schools and local facilities set within a unique landscape setting with access to generous open space and sports facilities'. The quantum and scope of development set out in this vision provides the basis for this analysis.
Yieldfields Hall Farmhouse
4.3 The primary heritage interest of the Grade II listed Yieldfields Hall Farmhouse is derived from its architectural interest as a high-quality example of an 18 century house, and its local historic interest as a high status country residence and later farmstead. Yieldfields Hall was listed in 1984 as a farmhouse and the property shows multiple phases of evolution as it developed from a private dwelling to a farmstead. There are ancillary buildings and structures on the property, including those associated with the farm, that are likely to be considered curtilage listed.
4.4 The development potential of the listed farmhouse and the curtilage listed ancillary buildings is likely to be limited. The farmhouse has good survival of historic fabric that makes an important contribution to the special interest of the building. There will be a desirability that any development preserves or enhances this special interest, limiting the level of change possible without harming the building. The ancillary farm buildings can be split between those modern farm buildings that would not be considered curtilage listed and can be removed without requiring listed building consent, and those historic structures that are considered as curtilage listed. In some cases, historic farm buildings that are curtilage listed will be considered to make a positive contribution to the listed farmhouse. There will be a desirability that development preserves or enhances curtilage listed buildings that make a positive contribution to the farmhouse and their settings. Walls, gateposts and similar structures associated with the listed building may also be considered as curtilage listed, with the desirability that they too would be retained in any potential development. This is likely to limit the scope of development within the farmstead. Principles relating to the reuse of the farmhouse and ancillary buildings are
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Analysis: Principle of Development
considered in more detail in a separate Technical Note (Barton Willmore, September
2019).
4.5 The agricultural setting contributes to the special interest of Yieldfields Hall by providing a rural setting to the listed building. Land that forms part of the historic ownership of Yieldfields Hall shares a functional and associative relationship with the listed building. The development of this land would erode the contribution that it currently makes to its significance by virtue of the loss of these functional and associative relationships and the replacement of open farmland with residential development. Further research is required to understand the nature of the historic land ownerships.
4.6 Notwithstanding the above, it is likely that a quantum of development can be accommodated in the wider setting with a lower degree of impact on its significance, subject to detailed design. It is likely that any proposal for development will need to demonstrate that it sustains the open character of its setting to a degree that minimises any harm to an acceptable level. This is likely to include the retention of the historic access track that continues east of the farm and the land to the south of the front (south) elevation that the hall was designed to overlook. There is an important view of the house when approached from Bloxwich on the A34 Stafford Road. The principal elevation of the house when travelling north is visible and the house is orientated to the south, making it prominent in the view. Maintaining this view is likely to be a consideration when seeking to conserve the special interest of the building.
4.7 In summary, it is considered likely that a landscape buffer will need to be retained around the listed building to retain an open character to the setting and views to and from the principal elevation. Subject to detailed design, this would mitigate the impacts of development on the remainder of the site. The development of land beyond a retained landscape buffer currently/formerly part of the agricultural land holding of Yieldfields Hall is likely to have some degree of impact by virtue of the loss of the functional and associative relationship.
4.8 Subject to detailed design, development on land at further distance and outside of the historic landholding is likely to have a limited, if any, impact on the significance of Yieldfields Hall.
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Analysis: Principle of Development
Bloxwich Golf Club Clubhouse
4.9 The landscaped setting of the golf course visually screens the clubhouse from the site and the wider agricultural landscape of the site does not make a contribution to its special interest.
4.10 The site is visually, physically and functionally separate from the Grade II listed Bloxwich Golf Club Clubhouse, such that, in principle, the development of the site is unlikely to have any adverse impact on the significance of the building, including the contribution made by its setting. If there are views, they are likely to be very limited, such that there would be no material impact on the significance of the listed building.
Additional Considerations
4.11 The former Lord Hayes canal branch is located within the site. This has the potential to be a non-designated heritage asset and if so, would be a material consideration. Development of the site has the potential to result in the loss of or harm to the setting of the former canal. The canal is currently disused and in an overgrown condition, and there exists a good opportunity to deliver a direct public benefit through improving its condition and setting. The incorporation of the canal as a feature into future development offers an opportunity to make a positive contribution to the heritage asset and better reveal its significance. This would be in line with paragraph 185 of the NPPF.
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Conclusions
5.0 CONCLUSIONS
5.1 This Heritage Appraisal has identified locally and statutorily designated heritage assets within the immediate area surrounding the site. The Grade II listed Yieldfields Hall Farmhouse is located within the site and Grade II listed Bloxwich Golf Club Clubhouse is located c.185m south the site. These two designated asserts are both identified to have potential to be affected by development on the site.
5.2 Although Bloxwich Golf Club is located adjacent to the site, the Grade II listed clubhouse is visually screened from the site and the agricultural landscape is not considered to contribute to the heritage interest in the asset. It is therefore concluded that the principle of development on the site is unlikely to have any adverse impact on the significance of the building, including the contribution made by its setting. This is subject to detailed design considerations.
5.3 The site includes the Grade II listed Yieldfields Hall Farmhouse and its associated agricultural landscape surrounding the farmstead. In line with local and national planning policy and the legislative test there will be a desirability that any development sustains or enhances the heritage interest of the listed building. This also applies to those buildings or structures that are considered curtilage listed and contribute to the heritage interest of the listed building. The development potential of Yieldfields Hall Farmhouse is likely to be limited to proposals that retain the buildings and ancillary structures of heritage interest and puts them to a viable use. This is considered separately elsewhere.
5.4 The development potential in the area immediately surrounding the listed building is likely to be limited. The landscape surrounding Yieldfields Hall provides an open and agricultural setting that makes a positive contribution to its heritage interest. There will likely be a desirability that the open aspect of the listed building is retained.
5.5 There is an important view of the house when approached from Bloxwich on the A34
Stafford Road. It would be desirable that this is retained and that Yieldfields Hall remains prominent when viewed from the road.
5.6 Land at greater distance from the farmstead and outside of its historic ownership is likely to be able to accommodate development with little, if any, adverse impact on the significance of Yieldfields Hall Farmhouse, subject to detailed design.
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Conclusions
5.7 A review of the site concludes that designated heritage constraints are likely to be limited to the immediate area surrounding Yieldfields Hall Farmhouse. There are no significant constraints affecting the wider site.
5.8 Any potential impact on non-designated heritage assets should not present a constraint on the proposed allocation of this site at this stage, however consideration should be given to their preservation and enhancement to demonstrate positive plan-making. The Lord Hayes canal branch is one possible future non-designated heritage asset with potential to be affected and provision should be made in future master-planning stages to incorporate it into any proposed development scheme.
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[See Attachment for Appendix 1, 2 and 3 for additional evidence, data and supportive illustrations]
[----------------------- APPENDIX 7 ENDS -----------------------]
Object
Draft Black Country Plan
Representation ID: 23400
Received: 11/10/2021
Respondent: West Midlands CPRE
Agent: Gerald Kells
WAM232 (WSA4) Walsall Bloxwich
The site is not well located beyond the edge of Bloxwich, so with less frequent bus services, and is adjacent to Yieldsfield Farm (a Grade II listed building), which means it threatens to contravene Policy ENV5. Although it is on the very edge of the Black Country, there does not appear to be a strong Green Belt boundary along that line.
Green Belt assessment in Land Use Consultants’ 2019 Green Belt Study – High
Support
Draft Black Country Plan
Representation ID: 23436
Received: 15/02/2022
Respondent: L&Q Estates
Agent: Barton Willmore
Land At Yieldfields, Bloxwich
Response to Draft Black Country Plan 2039 (Regulation 18) Consultation
On Behalf of L&Q Estates
¬
October 2021
Land at Yieldfields, Bloxwich
Response to Draft Black Country Plan 2039 (Regulation 18) Consultation
Prepared on behalf of L&Q Estates
CONTENTS
Page
1.0 Introduction 1
2.0 Sustainabiliy Appraisal 2
3.0 Section 2 - The Vision, Strategic Objectives and Strategic Priorities 3
4.0 Section 3 - Spatial Strategy 4
5.0 Section 4 - Infrastructure and Delivery 12
6.0 Section 5 - Health and Wellbeing 14
7.0 Section 6 - Housing 16
8.0 Section 9 - Transport 21
9.0 Section 10 - Environmental Transformation and Climate Change 23
10.0 Section 13 - Sub-Areas and Site Allocations 28
APPENDICES
Appendix 1: Site Boundary Plan (Drawing BM-M-03)
Appendix 2: Yieldfields, North Walsall Vision Document (October 2021)
Appendix 3: Review of Sustainability Appraisal (October 2021)
Appendix 4: Yieldfields Delivery Trajectory
Appendix 5: Transport Technical Note (October 2021)
Appendix 6: Preliminary Ecological Review: Constraints and Opportunities (July 2019)
Appendix 7: Heritage Appraisal (September 2019)
1.0 INTRODUCTION
1.1 We write on behalf of our client, L&Q Estates, in relation to their interests at land at Yieldfields, Bloxwich (hereafter referred to as ‘the Site’). L&Q Estates welcome the opportunity to be involved in the preparation of the Black Country Plan, and it is within this context that they wish to make representations to the Regulation 18 Consultation.
1.2 On behalf of L&Q Estates, we have previously made representations to the Issues and Options Consultation in September 2017 and submitted the Site to the Call for Sites exercises in August 2017 (under their previous name, Gallagher Estates) and August 2020.
1.3 The Site is shown outlined in red on Drawing BM-M-03 (Appendix 1) and is located on the northern edge of Bloxwich. A Vision Document (included at Appendix 2) has been prepared and submitted as part of this response to the Regulation 18 Consultation on the Draft Black Country Plan, which provides analysis of the Site and a Vision for its development alongside a Concept Masterplan for consideration, in accordance with Draft Strategic Allocation Policy WSA4.
1.4 The Concept Masterplan covers approximately 38.9 hectares of land within the administrative boundary of Walsall. This demonstrates that the Site could deliver approximately 978 new homes, in addition to a new 2 form-entry primary school, Community Hub, open space and informal sports provision, as well as enhancing the existing Grade II Listed Yieldfields Hall.
1.5 The Site is deliverable, available and suitable for release from the Green Belt to deliver a high quality residential-led development that will significantly assist in meeting the Black Country’s identified housing need as well as the unmet need from the Greater Birmingham Housing Market Area (HMA).
2.0 SUSTAINABILIY APPRAISAL
2.1 NPPF Paragraph 32 states:
‘Local plans and spatial development strategies should be informed throughout their preparation by a sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan has addressed relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).’
2.2 The reference to relevant legal requirements refers to Strategic Environmental Assessment. Neighbourhood plans may require Strategic Environmental Assessment, but only where there are potentially significant environmental effects.
2.3 A review of the Sustainability Appraisal (SA) (July 2021) to support the Draft Black Country Plan has been undertaken (Appendix 3). The review concludes that the SA process so far has two major deficiencies and a number of areas that would benefit from further focus before/during the Regulation 19 consultation stage so that the process is as robust as possible. It is anticipated that the SA would then provide a comprehensive discussion around the likely effects of alternatives as evidence supporting the BCP as a reasonable strategy for sustainable development.
2.4 The review also assessed the Site against the SA’s objectives, and the scores given, as well as providing updated scores based on the latest evidence. This concludes that, based on its location, opportunities and performance against the 14 SA Objectives, the Site comprises a reasonable alternative to be selected for inclusion within any proposed site allocations within the BCP to aid sustainable development in this area. Based on the reports available for the Site, it is considered that the Site should be scored more highly against some SA objectives.
3.0 SECTION 2 - THE VISION, STRATEGIC OBJECTIVES AND STRATEGIC PRIORITIES
The Vision
3.1 The Black Country Authorities have set out a vision for the Black Country up to 2039. We support the vision in principle, which seeks to create a prosperous, stronger and sustainable Black Country. This vision provides a positive framework for the Strategic Objectives and is generally aligned with the three overarching sustainability objectives set out in NPPF Paragraph 8.
Strategic Objectives
3.2 We have reviewed the strategic objectives and strategic priorities set out in Table 1 (Black Country Plan – Objectives and Strategic Priorities) of the draft Plan. We are supportive of the Strategic Objectives, which will address the key strategic challenges and opportunities that have arisen since the Core Strategy was adopted in 2011. We consider that the Site, which has the potential to deliver 978 new homes in Walsall alongside the provision of local services and facilities as well as significant open space in a sustainable location, would assist the Black Country Authorities in achieving these objectives.
4.0 SECTION 3 - SPATIAL STRATEGY
4.1 The Spatial Strategy is set out in Draft Policies CSP1, CSP2, CSP3 and CSP4, and illustrated on the Key Spatial Diagram (Figure 2), which provides the overarching basis for the Plan’s proposals for growth and infrastructure improvements. We are supportive of the Key Spatial Diagram, as this accords with Paragraph 23 of the NPPF, which requires broad locations for development to be indicated on a key diagram, and land-use designations and allocations identified on a policies map.
4.2 L&Q Estates’ site is identified on the Key Spatial Diagram as a draft housing allocation (Draft Policy WSA4) capable of delivering over 300 homes and a neighbourhood growth area. It should be noted that the Site has an estimated capacity of 978 homes as set out under Draft Policy WSA4.
Development Strategy [CSP1]
4.3 Draft Policy CSP1 (Development Strategy) provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039. Part 1 of Draft Policy CSP1 seeks to deliver at least 47,837 net new homes and create sustainable mixed communities that are supported by adequate infrastructure. Part 2 of Draft Policy CSP1 identifies that the spatial strategy seeks to deliver this growth and sustainable patterns of development by delivering a limited number of Neighbourhood Growth Areas in highly sustainable locations on the edge of the Urban Area. We are generally supportive of this policy, which seeks to direct growth to the most sustainable locations and to sites which have been assessed as the most suitable by the Black Country Authorities’ housing site selection process and as part of the Sustainability Appraisal.
4.4 The Development Strategy, set out under Draft Policy CSP1, has been developed through a comprehensive assessment of a range of alternative options, as set out in the Spatial Options Paper. The Sustainability Appraisal (SA) also includes an assessment of eleven spatial options identified by the Councils. Each option has been assessed for its likely sustainable impacts.
4.5 The Preferred Spatial Option selected is Option J (Balanced Growth), which focuses growth within both existing residential and employment areas in the sub-region, taking advantage of their existing infrastructure capacity, in addition to a limited number of new growth areas near to the edge of settlements that take account of environmental, climate change, accessibility and socio-economic requirements. Spatial Option J ensures that development within the Green Belt is only located in the most sustainable locations areas with good access to help reduce reliance on private car usage. In addition, this Spatial Option seeks to ensure housing is of a high-quality design, which could potentially include ensuring energy efficient homes are provided. Therefore, this option could potentially have a minor positive impact in regard to climate change mitigation. L&Q Estates support this approach and Spatial Option J being pursued.
4.6 The Site benefits from a sustainable location with good access to surrounding sustainable modes of transport. Bloxwich North railway station, which provides services between Birmingham New Street and Rugeley Trent Valley, is located approximately 1.8km to the west and is accessible from the Site by walking, cycling and public transport. Bloxwich North railway station is located along the Chase Line which was recently subject to major improvement works including electrification to enable faster and more frequent services. In addition, the nearest bus stop to the Site is located approximately 650m to the west on Turnberry Road. Further bus stops are located approximately 750m to the south of the Site outside Bloxwich golf club and approximately 950m to the north of the Site opposite the New Masons. These bus stops are serviced by the X51, 1 and 74 bus services which provide direct links to Walsall, Stafford, Cannock and Birmingham. The development of the Site will provide the opportunity to enhance these bus services and provide bus stops closer to the Site. The Site’s good public transport links are also important in the context of Paragraph 142 of the NPPF, which identifies that where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land that is well served by public transport.
4.7 A Transport Technical Note (October 2021) has been prepared by Pell Frischmann (included at Appendix 3) which identifies that the Site presents the opportunity for a sustainable development, underpinned by ‘decide and provide’ principles to firstly reduce the need to travel and secondly to maximise the use of sustainable modes for any journeys. Whilst the Transport Technical Note concludes that the potential traffic impact of the proposals should not be a barrier to the proposed allocation of the Site, detailed assessments of the impact of the proposed development on the surrounding highway network, including off-site junctions, will be undertaken during the preparation of the outline planning application, following the adoption of the Black Country Plan. Suitable mitigation measures will be identified and developed should any junctions require improvement. Therefore, L&Q Estates consider that the Site is a suitable and deliverable site that could be released from the Green Belt to deliver a sustainable extension to the urban area of Bloxwich. This would be in accordance with the aims of the NPPF and would also significantly assist in meeting the housing need of the Council and the unmet needs of the Greater Birmingham HMA.
Neighbourhood Growth Areas
4.8 The strategic approach for the Towns and Neighbourhoods Areas and the Green Belt is set out within Draft Policy CSP3. We are supportive of this policy, in particular Part B (i) which states that the areas outside the Strategic Centres and Core Regeneration Areas will provide 27,068 new homes through a network of new Neighbourhood Growth Areas providing 6,792 homes, in highly sustainable locations on the edge of the Urban Area. As noted above, the part of the Site within Walsall extends to 38.9 hectares and has the potential to deliver 978 new homes in Walsall alongside the provision of a primary school, local services and facilities and open space in a sustainable location.
4.9 Part G of Draft Policy CSP3 advises that a defensible Green Belt will be provided to help promote urban renaissance within the urban area and that provides easy access to the countryside for local residents; with the landscape safeguarded and enhanced where possible for its heritage, recreation, agricultural and nature conservation value. We are supportive of this policy, which aligns with NPPF Paragraph 137 on preventing urban sprawl. NPPF Paragraph 137 states:
‘The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.’
4.10 The Site is located within the Green Belt at the northern edge of Bloxwich, flanking the A34 corridor. Barton Willmore’s Landscape Team have assessed the Site and have previously undertaken a Landscape and Visual and Green Belt Appraisal (LVGBA), which was submitted in support of L&Q Estates’ Call for Sites submission for the Site in August 2020. This Assessment considers that the Site makes only a limited contribution to the purposes of the Green Belt. The existing extents of built form along the A34 corridor towards settlements to the north have created a situation in which the urban area of Bloxwich has sprawled and there is potential for merging of towns. However, a shallow ridgeline on the northern edge of the Site provides the basis for reinforcement through green infrastructure provision to create physical features that are readily recognisable and likely to be permanent.
4.11 There is potential for sensitive development of the Site within the topographical containment provided by the shallow ridgeline extending through the northern part of the site; within the existing extent of development along the A34 north of Bloxwich; and avoiding development of the land in the eastern edge of the Site which is less subject to urbanising influences than those areas nearer the A34. The Masterplan 1 contained in the Vision Document (Appendix 2) sets out to create a landscape buffer and soft edge/transition along the perimeter/edge of the new development to soften the visual impact on the surrounding countryside, thus providing a clearly defined and defensible Green Belt boundary in accordance with Draft Policy CPS3. In addition, the Site would also provide a network of green links, streets and spaces which will provide pedestrian and cycle routes to public rights of way, improving access to the remaining Green Belt.
4.12 As part of the justification to Draft Policy CSP3 provided within the Draft Black Country Plan, Paragraph 3.48 emphasises that it is important that the individual sites (as defined in Draft Policy CSP3) in each of the Neighbourhood Growth Areas are masterplanned together, regardless of ownership, owing to the fact that new development will generate the need for new infrastructure. Where appropriate, masterplans may be prepared through a collaborative process involving the landowner/developer(s) and the relevant Black Country Authority. We are supportive of the Neighbourhood Growth Areas being masterplanned together (per allocation) and want to note that the Site only has one majority landowner who have promotion agreement with L&Q Estates, who are a master developer. More information of L&Q Estates’ experience of delivering large sites, like this Site, is set out in the Vision Document (Appendix 2).
Design
4.13 With regard to achieving well-designed places, Draft Policy CSP4 states that the Black Country’s ongoing transformation will be supported by the development of places and buildings providing a range of functions, tenures, facilities, and services, intended to support the needs of diverse local communities.
4.14 L&Q Estates intend to engage with the local community and other stakeholders through public consultation events to help influence the design of the Yieldfields development during the preparation of the outline planning application, following the adoption of the Black Country Plan. A site-specific design code will be developed for the Site in accordance with NPPF Paragraph 129.
4.15 Therefore, L&Q Estates are supportive of Draft Policy CPS4, and consider that the Site can meet the aims of the policy, particularly as the planned public engagement will ensure the design of spaces and buildings will be appropriate and will respond to local context and identified needs in terms of size, type and tenure. The Vision Document demonstrates that much work has already been undertaken into achieving a well-designed neighbourhood.
Green Belt
4.16 Paragraph 140 of the NPPF confirms that, once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.
4.17 The Black Country Authorities consider that, through the preparation of the Black Country Plan, exceptional circumstances have been demonstrated to remove certain areas of land from the Black Country Green Belt to meet housing and employment land needs. The Black Country Urban Capacity Review Update (May 2021) summarises the various sources of housing supply and compares current supply with identified need. The report calculates that the amount of housing need that cannot be accommodated in the Black Country urban areas remains significant, at around 36,819 homes. This is despite reviewing all potential sources of housing capacity, making a series of structured assumptions around density and windfalls, and comprehensively exploring the capacity on occupied employment land in the context of up-to-date employment land evidence. In addition, the Urban Capacity Review also notes the strategic Duty to Cooperate issues, particularly the current and emerging housing shortfall position across the Greater Birmingham and Black Country Housing Market Area. It is also important to note that Paragraph 4.7 of the Urban Capacity Review concludes that “the exceptional circumstances necessary to trigger a Green Belt review in the Black Country, in order to meet housing and employment land needs, have been met”.
4.18 Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development, as noted in NPPF Paragraph 141. This will be assessed in terms of whether the strategy:
a. Makes as much use as possible of suitable brownfield sites and underutilised land;
b. Optimises the density of development, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c. Has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
4.19 With regard to making as much use as possible of suitable brownfield sites and underutilised land, the Urban Capacity Review identifies (at paragraphs 2.1.7-2.1.9) that the inclusion and assessment of sites within the current SHLAAs has followed Government guidance, best practice, sustainability principles and the spatial strategy of the current Black Country Core Strategy (BCCS). A ‘brownfield first’ principle is applied. The sites identified as deliverable or developable are mainly those with planning permission, allocations on surplus employment land and other sites in the BCCS growth network (including greenfield sites, where appropriate i.e. those with planning permission or considered to be policy compliant). The SHLAAs have been informed via a Black Country ‘call for sites’ carried out in 2017-20 to inform the BCP.
4.20 Therefore, in terms of the sites included within the Black Country SHLAAs, it is considered that the assessments have been comprehensive in their scope and identifying potential sources of supply, including making as much use as possible of suitable brownfield sites and underutilised land. In particular, the Urban Capacity Report (at paragraph 3.1.2) identifies that it has undertaken a review of existing housing allocations, which has resulted in a reduction of housing supply from allocations on currently occupied employment land, as reflected in each of the individual SHLAAs.
4.21 In terms of optimising density, the Urban Capacity Report (at paragraph 3.1.9) refers to the Strategic Growth Study (2018) findings and conclusions, which suggests that the Birmingham and Black Country urban area should seek to apply a minimum 40dph density threshold (net area). This could yield an additional 4,000 dwellings (1,000 dwellings from sites of 200+ dwellings and 3,000 dwellings from small sites below 200 dwellings) in the Black Country (subject to further local testing). The Strategic Growth Study based the findings on a sample of 750 sites across the 14 HMA Local Planning Authorities.
4.22 In 2019, a review was undertaken by the Black Country Authorities to test this conclusion more locally. It identified that from 2009-2019 approximately 86% of sites of 15 dwellings or more have been developed at a density of 35dph and higher. Around 54% have been developed at a density of 35-60dph. The Urban Capacity Report notes that it is not possible to increase densities on sites with planning permission and any increases arising from changes in policy would not take effect until 2024 (anticipated BCP adoption date). An analysis is, however, undertaken of the potential uplift arising from the draft BCP Policy on housing density and accessibility.
4.23 The analysis considers the potential uplift resulting from applying the draft Policy standards to sites of 10 dwellings or more that are unlikely to be the subject of planning permission before 2024. This results in a maximum additional supply of 476 dwellings which is significantly less than the Strategic Growth Study assumption of around 4,000 dwellings. The Urban Capacity Report explains this is due to a more detailed analysis of more up to date site information. The analysis assumes all sites within the 35-45dph density range have a density of 35dph and can uplift to 40dph. The Urban Capacity Report considers that it could be the case that many of these sites are already due to deliver at near 40dph (or above). For example, the Walsall SHLAA 2020-2021 states that it has already applied the emerging minimum 40dph assumption to all sites (bar those considered ‘deliverable’ within the five-year supply). Indeed, some sites within the supply are already significantly exceeding some minimum densities from the BCCS and Strategic Growth Study.
4.24 In terms of the potential to exceed the suggested minimum 40dph, the BCP however needs to take into account the housing mix needs of the area. The Strategic Growth Study (paragraph 6.14) identified that generally it is possible to create developments within densities of 40dph or 50dph which continue to provide for a mix of housing types and sizes, including family housing. The BCCS Policy HOU2 (Table 8) identifies that generally schemes of 35-45dph will constitute 0-25% flatted developments. The Black Country and South Staffordshire Strategic Housing Market Assessment (SHMA, 2017) concluded that given the nature of existing housing stock, the optimum housing mix overall would be 12% 1 bed; 22% 2 bed; 40% 3 bed; and 26% 4 bed properties (to vary by area and tenure). Therefore, given that 66% of the preferred tenure is for 3 bed+ homes, there is limited scope to drive minimum densities further without compromising the housing needs of the community.
4.25 With regard to discussions with neighbouring authorities, the Black Country Plan confirms that it intends to draft and agree Statements of Common Ground with relevant authorities (including South Staffordshire, Lichfield, Cannock and Shropshire) and bodies on key duty to co-operate issues at the BCP’s publication stage. However, the issue of the significant shortfall in planned provision to meet housing requirements within the Black Country and wider HMA has been well-considered, as evidenced by the Greater Birmingham HMA Strategic Growth Study (2018) which was commissioned by the 14 local authorities that comprise the Greater Birmingham and Black Country Housing Market Area.
4.26 Based on the above, it is considered that the Council have fully examined all other reasonable options for meeting the identified need for development outside of the Green Belt in line with Paragraph 141 of the NPPF.
Compensatory Improvements
4.27 Paragraph 142 of the NPPF advises that, where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and/or is well served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. Similarly, Draft Policy GB1 (The Black Country Green Belt) states that for sites that are removed from the Black Country Green Belt and allocated to meet housing, or other needs through the Plan (as listed in Chapter 13):
a. ‘The design of development will include physical features that define the new green belt boundary in a readily recognisable and permanent way; and
b. Compensatory improvements to the environmental quality, biodiversity and accessibility of remaining green belt land will be secured to offset the impact of removing the land from the green belt, in accordance with national policy.’
4.28 As such, the Draft Black Country Plan provides for compensatory improvements for the loss of Green Belt through those strategic allocations that are being released from the Green Belt. For example, Yieldfields will deliver significant improvements to the quality and accessibility of the existing Green Belt. These improvements will include the creation of a landscape buffer and soft edge/transition along the development edge and the countryside, in addition to retaining and enhancing existing mature tree belts and hedges, responding to the local countryside character to the north. In terms of connectivity, Yieldfields will include a series new pedestrian and cycle routes from the development to existing Public Rights of Way located in the Green Belt, as shown in the Vision Document and Masterplan. Therefore, L&Q Estates are supportive of Draft Policy GB1, and consider that the site is capable of meeting the requirements set out within Part 2 a) and b) of the policy.
5.0 SECTION 4 - INFRASTRUCTURE AND DELIVERY
5.1 Strategic Policies should make sufficient provision for infrastructure, as confirmed in parts b) and c) of NPPF Paragraph 20, which states:
‘Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for infrastructure for:
b) transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)
c) community facilities (such as health, education and cultural infrastructure)’
5.2 Draft Policy DEL1 (Infrastructure Provision) of the Draft Black Country Plan emphasises that all new developments should be supported by the necessary on and off-site infrastructure to serve its needs, mitigate its impacts on the environment and the local community and ensure that it is sustainable and contributes to the proper planning of the wider area. Therefore, we are supportive of this policy in principle, owing to its conformity with national planning policy.
5.3 We support the draft Plan’s assertion that allocated sites on the fringe of the urban area, which have been removed from the Green Belt, will be easier and quicker to deliver than sites within the urban area. A Delivery Trajectory has been prepared for the Site (Appendix 4) which assumes that a planning application is submitted on adoption of the Black Country Plan in 2024, and anticipates that construction will commence in 2026. The Delivery Trajectory demonstrates that 978 homes could be delivered in the Plan Period, even if the adoption of the Plan or a start on site were to slip by a further one or two years.
5.4 In addition, we agree that some allocated sites will need to be supported by a range of new infrastructure, such as schools, shops and improved local transport infrastructure, due to their significant size.
5.5 Part 3 of Draft Policy DEL1 advises that the Black Country Authorities will set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, and where appropriate, masterplans:
a. The infrastructure that is to be provided or supported;
b. The prioritisation of and resources for infrastructure provision;
c. The scale and form of obligation or levy to be applied to each type of infrastructure;
d. Guidance for integration with adjoining local authority areas;
e. The procedure for maintenance payments and charges for preparing agreements;
f. The defined circumstances and procedure for negotiation regarding infrastructure provision.
5.6 We strongly support this approach to address infrastructure requirements for proposed urban extensions, such as Yieldfields, and to review the needs of each area based on its size and location.
5.7 It is anticipated that the development at Yieldfields will be supported by on-site and off-site infrastructure, including a new on-site 2 form entry primary school and local health centre, in addition to a contribution towards improvements for off-site secondary school provision in North Bloxwich. We would, therefore, welcome future consultation on the Infrastructure Delivery Plan, once prepared, as this will identify the infrastructure investment required to support the proposed development at Yieldfields, in addition to identifying potential constraints to delivery and the key delivery mechanisms and partners.
Promotion of Fibre and 5G Networks
5.8 Draft Policy DEL3 (Promotion of Fibre to the Premises and 5G Network) requires all major developments to deliver Fibre to the Premises (FTTP) capacity/infrastructure to all individual properties or alternatively, non-Next Generation Access technologies that can provide speeds in excess of 30MB per second, where FTTP cannot be delivered. Further, any proposals for infrastructure to support the delivery of 5G networks will be supported in principle, subject to meeting the requirements of other local policies and national guidance.
5.9 We are supportive of Draft Policy DEL3, particularly as this aligns with Paragraph 114 of the NPPF, which requires planning policies and decisions to support the expansion of electronic communications networks, including next generation mobile technology (such as 5G) and full fibre broadband connections. However, it is important to note that the promotion of Fibre may not always be practicable or viable in new developments. Criterion (1) is therefore supported insofar it allows for this requirement to be reduced where it can be clearly demonstrated that it is not practical or viable.
6.0 SECTION 5 - HEALTH AND WELLBEING
6.1 Draft Policy HW1 (Health and Wellbeing) provides a strategic context for how health and wellbeing is influenced by planning. We are supportive of this draft policy, particularly as it aligns with the requirements of NPPF Paragraph 92 as it aims to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible and enable and support healthy lifestyles to address identified local health and wellbeing needs.
6.2 Part C of Draft Policy HW1 advises that new developments that provide a range of housing types and tenures that meet the needs of all sectors of the population, including for older people and those with disabilities requiring varying degrees of care; extended families; low-income households; and those seeking to self-build, will create an environment that protects and improves the physical, social and mental health and wellbeing of its residents, and reduces health inequalities.
6.3 In accordance with Draft Policy HW1, the Site will provide a range of housing types and tenures that meet the needs of all sectors of the population. The Black Country Housing Market Assessment (BCHMA) 2021 provides an update on the current position, using best available evidence and information, regarding the need for different types and tenures of housing across the Black Country over the Black Country Plan period. It then disaggregates the future housing need into different types of housing the future population will need, including the size, type and tenure of housing needed for different groups in the community (including, but not limited to, those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes). For example, the BCHMA indicates that the size of dwelling stock in Walsall in 2020 was as follows:
• One bedroom – 8.7%
• Two bedroom – 25.4%
• Three bedroom – 50.5%
• Four or more bedrooms – 15.4%
6.4 In addition, the Projected Tenure Profile in Walsall in 2039 is anticipated to be as follows:
• Owner Occupied – 59.8%
• Private Rented – 15.7%
• Shared Ownership – 1.4%
• Social Rent/Affordable Rent – 23.1%
6.5 The development at Yieldfields will provide a high quality, affordable and sustainable type of housing to meet identified needs in Walsall, using best available evidence, including the BCHMA. This will ensure that the development accords with the aims of Draft Policy HW1 in achieving a healthy, inclusive and safe development to address identified local health and wellbeing needs.
6.6 In addition, the Site will also include a range of social infrastructure, including a primary school, community facilities, new public open space, children’s play areas and informal sports provision, in accordance with Part G of Draft Policy HW1. The development will also retain and enhance green infrastructure, including existing mature tree belts and hedges, in accordance with Part H of Draft Policy HW1.
Healthcare Infrastructure
6.7 Draft Policy HW2 sets out the requirements for the provision of health infrastructure to serve the residents of new developments. Part 3 of Draft Policy HW2 emphasises that proposals for major residential developments must be assessed against the capacity of existing healthcare facilities and/or services as set out in local development documents.
6.8 We are supportive of this draft policy as it seeks to deliver appropriate local facilities to support residents and to enhance the sustainability of existing areas. It is considered that the healthcare requirements for Yieldfields should be set out in the Infrastructure Delivery Plan, once prepared. We note that work is ongoing in relation to the Infrastructure Delivery Plan. We therefore reserve the right to comment further at a later stage, once the specific requirements for this Site have been clearly defined.
7.0 SECTION 6 - HOUSING
7.1 Paragraph 66 of the NPPF requires strategic policy-making authorities to establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need can be met over the plan period. Draft Policy HOU1 (Delivering Sustainable Housing Growth) of the draft Black Country Plan states that sufficient land will be provided to deliver at least 47,837 net new homes over the period 2020-2039. The majority of the requirement will be met through sites with existing planning permission and sites allocated for housing by this Plan and other local plan documents. We are supportive of this draft policy which aligns with the aims of NPPF Paragraph 66.
7.2 It should be noted that Barton Willmore LLP has prepared a critical review of the Black Country Urban Capacity Review Update (May 2021) on behalf of a Consortium of housebuilders, land promoters and developers (including L&Q Estates). This review, which is being submitted separately in response to the draft Black Country Plan Regulation 18 Consultation, includes a detailed response on the Housing Requirement for the Black Country.
7.3 The Urban Capacity Review Update (May 2021) identifies a combined housing need for the Black Country Authorities of 4,004 homes per annum which equates to 76,076 homes over the period 2020-39. This is based upon the current standard methodology for calculating housing need (using the 2020-2030 household projections, new 2020 affordability ratios published in 2021, and reflects the 35% uplift to Wolverhampton’s local housing need figure introduced by changes to the standard method in December 2020). The Urban Capacity Review Update notes that this figure is subject to change, for instance when the Draft Black Country Plan reaches its Regulation 19 Publication (Pre-submission) stage in mid-2022 the figure will reflect any changes to the inputs (such as household projections and affordability ratios) and it will cover the period 2021-2039, as the standard methodology only applies to future years.
7.4 It is important to emphasise that the Planning Practice Guidance is clear in its approach that the “standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area” (Paragraph 010; Reference ID: 2a-010-20190220). The Draft Black Country Plan should therefore reflect that the proposed ‘Housing Need’ figure is only a starting point and additional housing may be required to facilitate economic growth or the delivery of affordable housing.
7.5 For example, an appeal decision for up to 800 dwellings at the Former North Worcestershire Golf Club highlighted the chronic shortfall in affordable housing which has come forward within Birmingham City since 2011 (Appeal Ref: APP/P4605/W/18/3192918) – a decision which was ‘called-in’ by the Secretary of State. Paragraph 14.108 of the Inspector’s Report states that only 2,757 new affordable homes were provided in the City over the first 6 years of the Plan period. This represents less than half of the target provision and a net increase of only 151 affordable homes if Right to Buy sales are taken into account. The Inspector goes on to state that given the heavy reliance in the five-year housing land supply on City Centre apartment schemes, it is difficult to see how that trend can be reversed in the short to medium term (paragraph 14.109).
7.6 Whilst it is noted that Birmingham City Council does not form one of the Black Country Authorities, it highlights the recent difficulties with delivering homes on brownfield sites. The high proportion of flatted developments, coupled with the increased likelihood of viability issues, has led to a chronic shortfall in the provision of affordable homes. Should the Black County Authorities follow a similar approach, it may therefore be necessary to increase the Housing Requirement, in accordance with national guidance, to improve affordability.
7.7 The latest Black Country Housing Market Assessment (dated March 2021) advises that the total annual affordable housing need in the Black Country represents 21.6% (867 per year) of the annual dwelling growth in the housing market area. The Housing Market Assessment considers it would be reasonable to expect this proportion of new housing as affordable to be delivered on a large housing site in the Black Country, where a figure of 25% would be plausible (subject to viability). The Assessment concludes by suggesting that Councils can be confident that the affordable housing need identified in the model will be addressed by the dwelling growth identified by the Standard Method and no adjustment is required to this figure. However, as noted above, flatted developments and an increased likelihood of viability issues on brownfield sites could mean that meeting the total annual affordable housing need in the Black Country would be much more challenging than predicted within the Black Country Housing Market Assessment.
7.8 In light of the above, it is considered that any shortfall in housing supply should be regarded as a minimum given that it is currently calculated against an untested housing target that may require an upward adjustment to take account of affordability. Therefore, we support Draft Policy HOU1 in principle, particularly the reference to delivering ‘at least’ 47,837 net new homes, given this could facilitate that increased housing number is feasible through good design.
Housing Density, Type and Accessibility
7.9 Draft Policy HOU2 (Housing Density, Type and Accessibility) seeks to assess the accessibility of all housing developments to a range of residential services by walking, cycling or public transport to determine housing densities. Whilst we are supportive of this approach, the policy states that all major developments should achieve a minimum net density of 40 dwellings per hectare (dph) where accessibility standards for moderate density housing are met. However, Part 5 of Draft Policy HOU2 states:
‘Chapter 13 provides details of the appropriate density and, where appropriate, house type mix, to be sought on each housing allocation site, in accordance with the requirements set out in this policy. Further details of design requirements for housing developments may be set out in Supplementary Planning Documents.’
7.10 Draft Policy WSA4 (Yieldfields Farm) within Chapter 13 identifies that the Site should deliver a density of at least 35 dph, which is lower that the density requirements set out within Draft Policy HOU2, which requires higher densities of at least 40 dph. We consider that only Part 5 of the Draft Policy HOU2, and thus the requirements set out within Chapter 13 of the Plan, applies to Yieldfields. However, we do consider that an average density of 40 dph is achievable on the Site and Masterplan 1 contained in the Vision Document is based on this density. This ensures that Masterplan 1 can deliver 978 homes, in accordance with Draft Policy WSA4. Due to site constraints, it is considered that the net developable area of Masterplan 1 is 24.7 hectares and if this was delivered at a net density of 35 dph, it would result in 864 homes being delivered.
7.11 With regard to affordable housing, Draft Policy HOU3 (Delivering Affordable, Wheelchair Accessible and Self Build/Custom Build Housing) states that all developments of ten homes or more should provide a proportion of affordable housing, where this is financially viable. The minimum proportion of affordable housing that should be provided is 20% affordable housing on greenfield sites in medium value zones (where the Site is located). Further, Part 3 of Draft Policy HOU3 advises that the tenure and type of affordable homes sought will be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations. L&Q Estates support this policy and the collaborative approach to identifying site-specific affordable housing requirements, including tenure and type of affordable homes to be provided on-site.
7.12 With regard to National Wheelchair Accessibility Standards, Part 4 of Draft Policy HOU3 requires 15% of homes on greenbelt sites in medium or higher value zones to meet the optional Building Regulations Requirement M4(3): Wheelchair User Dwellings and all remaining homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings. L&Q Estates are supportive of this approach and consider that such requirements can be met on the Yieldfields site.
7.13 With regard to Self-Build and Custom Build plots, Part 6 of Draft Policy HOU3 states that on developments of 100 homes or more, where there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located, at least 5% of plots should be made available for self-build or custom build, or sufficient to match the current number on the register if lower. We support this policy, which aligns with the aims of Paragraph 62 of the NPPF in terms of providing opportunities for people wishing to commission or build their own homes. Further, Part 6 goes on to state that any plots that have not been sold after 12 months of appropriate marketing will revert to the developer to build. L&Q Estates consider that Yieldfields can deliver 5% self-build and custom build plots. However, we strongly support the fall-back option of reverting any unsold self-build plots to the developer to build should any of these plots not be sold.
Education Facilities
7.14 Draft Policy HOU5 states that where a housing development of ten or more homes would increase the need for education facilities to the extent that new or improved facilities would be required to meet this need, planning obligations or Community Infrastructure Levy will be secured sufficient to meet the need, where this is financially viable. For strategic allocations, the likely requirement for on-site provision of new schools is set out in Chapter 13. Accordingly, Draft Policy WSA4 (Yieldfields Farm) (contained in Chapter 13) sets out that Yieldfields could deliver a new on-site primary school, in addition to a contribution to improvements for secondary school provision in North Bloxwich.
7.15 We support Draft Policy HOU5 and consider that Yieldfields could deliver a primary school to be positioned centrally within the site. The Vision Document demonstrates that the Site could also provide a significant amount of open space to include informal sports provision and children’s play areas.
7.16 In addition, the development would also make a financial contribution towards other local infrastructure, such as transport and secondary school provision. Therefore, we also support of Part 2 of Draft Policy HOU5, which states that where land is provided for a new school as part of a housing development, the financial contribution made by that development towards education facilities will be reduced accordingly.
7.17 Draft Part 4 of Policy HOU5 advises that new and redeveloped education facilities should include provision for wider community use of sports and other facilities where appropriate. Whilst we support the general requirements and intentions of Draft Part 4 of Policy HOU5, clarification is required in relation to whether this policy would apply if strategic allocations include provision for community use of sports and other facilities elsewhere within the site, but not necessarily as part of education facilities.
8.0 SECTION 9 - TRANSPORT
8.1 Paragraph 113 of the NPPF advises that all developments that will generate significant amounts of movement should be required to provide a travel plan, and the application should be supported by a transport statement or transport assessment so that the likely impacts of the proposal can be assessed.
8.2 We are supportive of Draft Policy TRAN3 (Managing Transport Impacts of New Development), which is consistent with NPPF Paragraph 113, emphasising that Transport Assessments and Travel Plans produced by developers are essential to demonstrate that an acceptable level of accessibility and safety can be achieved using all modes of transport to, from and through the development. An initial Transport Technical Note has been prepared by Pell Frischmann (Appendix 5) which concludes that the site would represent sustainable development and would be underpinned by a vision-led approach that would minimise the number of vehicular movements generated and maximise the use of sustainable modes of transport. The Transport Technical Note concludes that the Site is not anticipated to result in any significant transport impacts. In accordance with Draft Policy TRAN3, further detailed assessments of the impact of the proposed development on the surrounding highway network, including off-site junctions, will be undertaken during the preparation of the outline planning application, following the adoption of the Black Country Plan.
8.3 Draft Policy TRAN5 (Creating Coherent Networks for Cycling and Walking) also encourages new developments to create an environment that encourages sustainable travel via safe and direct links that connect to existing walking and cycling networks, in addition to public transport nodes and interchanges. We are supportive of this policy, as it accords with the requirements of Paragraph 110 of the NPPF, which advises that in assessing sites that may be allocated for development in plans, it should be ensured that appropriate opportunities to promote sustainable transport modes can be taken up, and that safe and suitable access to the site can be achieved from all users. In accordance with Draft Policy TRAN5, L&Q Estates’ site at Yieldfields will include a series of new pedestrian and cycle routes within the development, in addition to providing opportunities for improvements at the Stafford Road/Turnberry Road junction to provide dedicated crossings to facilitate active travel connections towards Bloxwich town centre, Bloxwich North railway station and local bus stops.
Parking
8.4 Draft Policy TRAN7 (Parking Management) identifies that the Black Country Authorities will ensure a consistent approach to maximum parking standards is enforced in new developments, as set out in supplementary planning documents. We are supportive of this policy in principle, however, the current parking standards in Walsall are set out within the Walsall Council Parking Strategy (which was adopted in 2008), and thus it is considered that this SPD should be updated to accord with the requirements of NPPF Paragraph 107 in terms of setting local parking standards. In addition, we consider that new parking standards should set out specific requirements for the provision for charging infrastructure for electric vehicles as part of developments. Draft Policy TRAN8 (Planning for Low Emission Vehicles) lacks clarity in this regard. Consequently, L&Q Estates seek clarification that new parking standards are being developed which will replace the Walsall Council Parking Strategy (2008) and would welcome the opportunity to consult on this, where appropriate.
9.0 SECTION 10 - ENVIRONMENTAL TRANSFORMATION AND CLIMATE CHANGE
Nature Conservation
9.1 Policy ENV1 (Nature Conservation) emphasises that development within the Black Country will safeguard nature conservation by ensuring that locally designated nature conservation sites (Sites of Local Importance for Nature Conservation), important habitats and geological features are protected from development proposals that could negatively affect them. The Black Country Authorities have undertaken ecological surveys and Local Sites Assessment Reports for the strategic allocations, including Yieldfields. In addition, Aspect Ecology undertook an ecological survey of Yieldfields in 2019 (included at Appendix 6) and have undertaken a high-level review of the Local Sites Assessment survey. It should be noted that the Local Sites Assessment survey was undertaken just four months following the Aspect Ecology survey in 2019 and covers the southern-most part of the red line boundary surveyed by Aspect Ecology.
9.2 The Local Sites Assessment concludes that the only part of the survey area which is considered to qualify as a local designation (Site of Local Importance for Nature Conservation, SLINC) is the route of the old canal and hedgerows bounding the southeast. As such, development of the Site would need to demonstrate no adverse effects on this SLINC or, where damage is unavoidable, measures are put in place to mitigate the impacts. Aspect Ecology consider that as the SLINC designation relates to hedgerows and wildlife corridors, the Site can be developed without causing any adverse effect.
9.3 However, all of the land within the centre of the Site, including some areas previously highlighted as a Potential Site of Importance (PSI), are not considered to qualify as a SLINC. The Local Sites Assessment notes that the arable and improved grassland field and associated species poor hedgerows on-site hold some ecological value for protected species and as an ecological corridor when assessed against the Birmingham and Black Country Local Sites Selection criteria, however, it fails to meet the criteria of a Local Wildlife Site. Accordingly, subject to appropriate mitigation in respect of protected species that may be present, and maintenance of some element of a wildlife corridor, it is inferred that the internal parts of the survey area are unconstrained in terms of potential development. Therefore, L&Q Estates are supportive of Policy ENV1 and consider that locally designated nature conservation sites and important habitats can be protected from the development proposals for Yieldfields, in accordance with the policy.
Biodiversity Net Gain
9.4 NPPF Paragraph 32 advises that local plans should address relevant environmental objectives, including opportunities for net gains. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered). Further, Paragraph 174 advises that planning policies and decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.
9.5 L&Q Estates are supportive of Draft Policy ENV3 (Nature Recovery Network and Biodiversity Net Gain), which requires all development to deliver a minimum 10% net gain in biodiversity value when measured against baseline site information. The Site will seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement, in line with Part 5 of Draft Policy ENV3.
Trees
9.6 L&Q Estates are supportive of Draft Policy ENV4 for the provision, retention and protection of trees, woodlands and hedgerows. Part 3 of Draft Policy ENV4 advises that where removal of trees is unavoidable, replacement trees should be provided to compensate for their loss, on a minimum basis of three for one.
9.7 Part 6 of Draft Policy ENV4 states that all available data on extant tree cover and associated habitat will be considered when making decisions on the proposed loss of trees and woodland to accommodate infrastructure and other development proposals. In areas where evidence demonstrates that current levels of tree cover are low, proposals that incorporate additional tree planting, to increase existing levels of habitat and canopy cover, will be considered positively, as part of the wider contribution to biodiversity net gain. We are supportive of this pragmatic approach to loss of trees in the context of biodiversity net gain. However, it is considered that Part 6 of Draft Policy ENV4 conflicts with the aims of Part 3 within the same policy, which specifically requires replacement tree planting to compensate for any trees removed, as opposed to assessing the wider opportunities for biodiversity net gain. Therefore, further clarification is required in relation to which part of Draft Policy ENV4 would be applicable to strategic allocations, including the Site (Draft Policy WSA4).
9.8 Part 12 of Draft Policy ENV4 requires new tree planting to be included in all new residential developments, as street trees or as part of landscaping schemes. We support this requirement and can confirm that the development of Site would provide significant tree planting.
9.9 Part 13 of Draft Policy ENV4 requires new developments to make a minimum contribution of 20% canopy cover across the development site and a recommended contribution of 30% canopy cover across the development site. Whilst it is important to ensure that development proposals include new tree planting, this cannot result in schemes becoming unviable. We would therefore recommend that Part 13 of Draft Policy ENV4 is amended to confirm that this contribution can be reduced subject to viability considerations or confirm that the Black Country Authorities would accept tree planting in an appropriate off-site location.
9.10 Part 24 of Draft Policy ENV4 identifies that there will be a presumption against the wholesale removal of hedgerows for development purposes, especially where ecological surveys have identified them to be species-rich and where they exist on previously undeveloped land. Whilst L&Q Estates appreciate the aims of this policy, it should be noted that some developments will require the loss of some hedgerows to gain access. As set out in the Vision Document (Appendix 2), access to the Site will be taken from the A34 Stafford Road. Map 3 of the Birmingham & Black Country Local Sites Assessment Report for the Site identifies that the Site’s western boundary along the A34 comprises hedgerow with trees. Where access to the Site and the associated visibility splays are required, some of this hedgerow will need to be removed. Given the access would not result in the wholesale removal of the hedgerow, it is considered that this would be in accordance with Part 24 of Draft Policy ENV4.
Heritage Impact
9.11 Draft Policy ENV5 (Historic Character and Local Distinctiveness of the Black Country) states that development proposals that would potentially have an impact on the significance of any designated heritage assets, including any contribution made by their setting, should be supported by evidence that the historic character and distinctiveness of the locality has been fully assessed and used to inform proposals. Clear and convincing justification should be provided, either in Design and Access Statements, Statements of Heritage Significance, or other appropriate reports. In some instances, local planning authorities will require developers to provide detailed Heritage Statements and/or Archaeological Desk-based Assessments to support their proposals.
9.12 We are supportive of Draft Policy ENV5, which accords with Paragraph 194 of the NPPF. This policy is of relevance to the Site, owing to the fact that the site contains a Grade II Listed building, comprising Yieldfields Hall. Furthermore, Bloxwich Golf Club, which is located approximately 750 metres to the south of the Site, is also Grade II Listed. Both of these heritage assets are located within Walsall Borough.
9.13 A Heritage Appraisal (September 2019) (Appendix 7) has been prepared to assess the deliverability of development on Site with reference to the historic environment constraints. It has been informed by a desk-top review including a review of the historic map evidence together with a site visit made on 26th July 2019.
9.14 The Heritage Appraisal concludes that in line with local and national planning policy and the legislative test, there will be a desirability that any development sustains or enhances the heritage interest of the listed building. The development potential of Yieldfields Hall is likely to be limited to proposals that retain the buildings and ancillary structures of heritage interest and puts them to a viable use. L&Q Estates will seek to retain Yieldfields Hall as part of the Site’s development to provide either a community or residential use.
9.15 With regard to the review of the Site, the Heritage Appraisal concludes that designated heritage constraints are likely to be limited to the immediate area surrounding Yieldfields Hall. There are no significant constraints affecting the wider site.
9.16 With regard to Bloxwich Golf Club, the Heritage Appraisal concludes that the Grade II listed clubhouse is visually screened from the site and the agricultural landscape is not considered to contribute to the heritage interest in the asset. It is therefore concluded that the principle of development on the site is unlikely to have any adverse impact on the significance of the building, including the contribution made by its setting.
Open Space, Sport and Recreation
9.17 Draft Policy ENV8 (Open Space, Sport and Recreation) advises that each local authority will set out, in their Local Plans and on Policies Maps, proposals for specific open space, sport and recreation facilities and planning requirements for open space, sport and recreation. We support this policy and consider that Yieldfields could provide a policy compliant provision of public open space, including parks and gardens and amenity space, in addition to adequate provision for children and young people.
9.18 Draft Policy ENV9 (Design Quality) provides guidance on design standards and principles to be assessed and included within design and access statements. We support Policy ENV9 in principle, as this policy seeks to ensure that developments are designed to the highest possible standards. However, we are concerned with reference to Secure by Design included at Part 1) d) of Policy ENV9, as Secure by Design guidance encourages cul-de-sacs and discourages permeability which is at odds with all other design guidance. Yieldfields will seek to accord with Secure by Design whilst ensuring best practice placemaking. The Vision Document demonstrates that our design approach incorporates an awareness of safety, security and anti-social behaviour issues and ensures that these issues are appropriately addressed through the design process.
Climate Change
9.19 Policy CC2 (Energy Infrastructure) identifies that we would need to include opportunities for decentralised energy provision within the site, unless it can be demonstrated that the development is not suitable, feasible or viable for district heat or decentralised power networks. In addition, Draft Policy CC7 (Renewable and Low Carbon Energy and BREEAM Standards) identifies that major development must:
a. achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document, Part L 2013, or achieve any higher standard than this that is required under new national planning policy or building regulations; and, in addition
b. incorporate generation of energy from renewable or low carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development on completion.
9.20 We are generally supportive of Draft Policies CC2 and CC7 which relate to the mitigation of, and adaptation to, climate change. L&Q Estates are committed to responding to the climate crisis and are actively looking to deliver housing to standards above those set out in current building regulations in response to this challenge. Indeed, their most recent Corporate Strategy includes a commitment to setting an L&Q design standard in response to the emerging Future Homes Standard, as well as more broad investment in modern methods of construction. However, it is important to note that decentralised energy provision and renewable and low carbon energy dwellings may not always be practicable or viable in new developments. Therefore, we are supportive of Draft Policies CC2 and CC7 insofar as they allow for such requirements to be reduced where it can be clearly demonstrated that it is not practical or viable.
10.0 SECTION 13 - SUB-AREAS AND SITE ALLOCATIONS
10.1 The strategy for Walsall is set out at paragraph C.8 in Chapter 13 of the draft Black Country Plan, which is as follows:
‘In the future, Walsall will be a more confident place, with renewed investment in key infrastructure and key centres, greater opportunities for work and leisure and an affordable, accessible housing stock.’
10.2 We are supportive of this strategy and consider the delivery of the Site will help this to be achieved, particularly as the development will include a housing mix to meet the needs of Walsall including policy-compliant affordable housing provision, in addition to open space, sport and recreation facilities. The development will be sustainable in accordance with the strategy proposed for Walsall.
Neighbourhood Growth Areas
10.3 At Paragraph C.28 of Chapter 13, the Draft Plan identifies that the existing growth network does not have the capacity to accommodate all need for new homes and jobs. Consequently, a number of Neighbourhood Growth Areas are proposed in sustainable locations close to the existing urban area that have good access to services. L&Q Estates site at Yieldfields comprises a proposed Neighbourhood Growth Area within the draft Plan, as shown on the Walsall Spatial Plan.
10.4 Paragraph C.28 goes on to state:
‘These areas will provide for additional homes and jobs to meet the needs of our residents. They will also provide for new or enhanced services where necessary, and in most cases, developers will be required to enhance biodiversity through the provision of new areas for wildlife and the restoration of existing ones.’
10.5 We strongly support the proposed Neighbourhood Growth Areas and consider that land at Yieldfields can contribute to the aims for these areas. In Walsall, the Site extends to 38.9 hectares and has the potential to deliver up to 978 new homes alongside the provision of a 2 form entry primary school, a Community Hub, local health centre, significant open space and informal sports provision in a sustainable location. The Site will also seek to deliver a minimum 10% in biodiversity net gain, alongside other on-site habitat provision and enhancement.
Strategic Allocations
10.6 Table 31 includes all Walsall sites allocated for housing by the Draft Black Country Plan. The Site is included in the Table (Site Ref. WAH232) and has an indicative housing capacity of 978 homes. Further information in relation to Yieldfields is included within Draft Strategic Allocation Policy WSA4 - Yieldfields Farm (sometimes recorded as Yieldfields farm), Stafford Road, Bloxwich. Again, Draft Policy WSA4 states that the estimated capacity of the site is 978 houses. Paragraph C.32 states that for each site where the allocation includes housing, an indicative site capacity is provided, however, the precise number of homes to be developed will be determined through the planning application process. L&Q Estates are supportive of the indicative housing capacity included in Strategic Allocation Policy WSA4, in addition to Paragraph C.32, and will seek to engage with the Local Planning Authority, members of the public and other key stakeholders to ensure the Site can meet the aims of the policy.
10.7 We note that Table 31 includes an error in relation to the indicative net developable area for Yieldfields. This is stated in Table 31 as being 37.26 hectares, whereas in Policy WSA4, the indicative net developable area is stated as being 26 hectares. L&Q Estates confirm that based on the site constraints, it is considered the net developable area of the Site located in Walsall equates to 24.7 hectares, and therefore, it is assumed that the figure in Table 31 is an error. We would request that both figures are amended to 24.7 hectares to reflect the Site’s constraints.
10.8 In addition, we note that the anticipated delivery timescale for Yieldfields included in Table 31 suggests that 600 homes will be delivered within the Plan Period (i.e. by 2039). However, L&Q Estates consider that the entire capacity of 978 homes could be delivered at the Site over the Plan Period. Indeed, the Black Country Plan Viability and Delivery Study (May 2021) assumes that for larger sites, where there may be two or more outlets, a delivery rate of 200 dpa could be achieved. It is considered that a delivery rate of 200 dpa is very optimistic and based upon L&Q Estates’ extensive experience, it is considered that a delivery rate of 100 dpa (with two outlets) is achievable. As such, a Delivery Trajectory has been prepared for the Site (Appendix 4) which assumes that a planning application is submitted on adoption of the Black Country Plan in 2024, and anticipates that construction will commence in 2026. The Delivery Trajectory demonstrates that 978 homes could be delivered in the Plan Period, even if the adoption of the Plan or a start on site were to slip by a further one or two years.
10.9 Overall, L&Q Estates strongly support Draft Policy WSA4 and the design principles included for the Site. The Vision Document submitted in support of these representations (Appendix 2) demonstrates that the development at Yieldfields can achieve all of the design principles included in Draft Policy WSA4 relating to design quality, heritage, delivery of appropriate local facilities, education contributions, transport, remediation, drainage and biodiversity.
10.10 Notwithstanding the above, we have some proposed amendments to make to Policy WSA4, as follows:
• We note that the Site is referred to as ‘Yieldsfield Farm (sometimes recorded as Yieldfields farm), Stafford Road, Bloxwich’. L&Q Estates have confirmed that the Site should simply be referred to as ‘Yieldfields’, to avoid confusion.
• As noted above, Table 31 includes an error in relation to the indicative net developable area for Yieldfields, which is identified as being 37.26 hectares. Draft Policy WSA4 identifies this as 26 hectares. Based on the Site’s constraints, we consider that the net developable area is 24.7 hectares and suggest that both Table 31 and Draft Policy WSA4 can be amended to reflect this.
• Draft Policy WSA4 identifies that the Site should deliver a density of at least 35 dph, which is lower than the density requirements set out within Draft Policy HOU2, which requires higher densities of at least 40 dph. We consider that only Part 5 of Draft Policy HOU2, and thus the requirements set out within Chapter 13 of the Plan, applies to Yieldfields. However, we do consider that an average density of 40 dph is achievable on the Site and Masterplan 1 contained in the Vision Document is based on this density. This ensures that Masterplan 1 can deliver 978 homes, in accordance with Draft Policy WSA4. Due to site constraints, it is considered that the net developable area of Masterplan 1 is 24.7 hectares and if this was delivered at a net density of 35 dph, it would only result in 864 homes being delivered. Therefore, we suggest that the net density figure in Table 31 is amended to state 40 dph is achievable on this site.