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Object

Draft Black Country Plan

Policy GB1 – The Black Country Green Belt

Representation ID: 21793

Received: 11/10/2021

Respondent: Wood Abbey Ltd

Agent: Mr Richard Cowell

Representation Summary:

Introduction
1.1 This representation is made in response to the consultation on the Draft Black Country Plan 2039 (Regulation 18) (hereafter referred to as "the Plan").
1.2 This representation is objecting to the Plan and specifically in relation to the following policies and evidence base:
Policy
• Policy CSP1- Development Strategy
• Policy GB1- The Black Country Green Belt
• Policy HOU1 - Delivering Sustainable Housing Growth
Evidence base
• Black Country Green Belt Study
• Black Country landscape sensitivity assessment
• Sustainability Appraisal of the Black Country Plan
Basis of the objection
2.1 The Plan contains planning policies and land allocations to support the growth and regeneration of the Black Country over the years to 2039.
2.2 The Plan contains a Vision for the Black Country in 2039. This is underpinned by strategic objectives and priorities designed to deliver the Vision and associated outcomes. The proposed policy framework will guide and shape development across the Black Country and will set clear parameters for growth and transformation.
2.3 The Black Country Plan is being produced to, amongst other things, specifically facilitate the delivery of the right development types to meet identified and emerging needs in the most sustainable places; and to meet housing needs between now and 2039.
2.4 The importance of producing the Black Country Plan is to address local challenges and issues and specific reference is made to, "Providing good quality housing that meets the needs of a growing population - the Plan needs to identify sufficient land for housing to meet the needs of people who are likely to live in the area over the period of the plan."
2.5 The Black Country Housing Market Area Assessment sets out the housing need for the area with The Black Country Urban Capacity Update 2020 providing an updated statement on the current housing need. This is confirmed at paragraph 2.1.4 on page 7 as being 4,004 homes per annum, which equates to 76,076 homes over the Plan period 2020-39.
2.6 One of the core objectives of the Plan is, "Housing that meets all our needs".
2. 7 The Development Strategy for the Black Country is set out in Policy CSP1. The Policy provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039.
2.8 The housing target for the Black Country, as defined in Policy CSP1, is 47,837 new homes over the period 2020-39.
2.9 Compared to a local housing need of 76,076 homes the Plan has a shortfall of 28,239 homes.
2.10 The Black Country Urban Capacity Update 2020 concludes at paragraph 4.3 page 34 that "the identified shortfall -- that is the amount of housing need which cannot be accommodated in the Black Country urban areas - remains significant... 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."
2.11 This shortfall doesn't account for the current and emerging wider housing shortfall position across the Greater Birmingham and Black Country Housing Market Area (GBBCHMA), within which the Black Country is located.
2.12 The failure to deliver sufficient housing supply in the Black Country continues the failure from the Core Strategy period. As stated on page 16 of the Urban Capacity Update 2020 the Black Country as a whole has an under-supply of 10,347 homes at 2025/26 - 37% of the remaining target of 28,325 homes. The under-supply is continuous throughout the Plan period with the main reasons for the increased under-supply since 2019 being the further loss of supply on occupied employment land and the re-phasing of sites beyond 2026 to reflect realistic delivery timescales, in line with Government guidance on deliverability.
2.13 In order to meet this significant shortfall The Plan places an emphasis on the Duty to Cooperate, with The Plan stating that 28,239 homes will be exported through Duty to Co-operate.
2.14 The latest letters dated 2018 from neighbouring authorities identify their own challenges and inability to contribute to the level expected by the Black Country Authorities. The Reg 18 Duty to Cooperate Statement makes significant assumptions about contributions from other authorities to meeting housing needs in the Black Country. The Black Country cannot rely on solving their housing needs by exporting housing supply to neighbouring authorities, many of which are unable to meet their own needs.
2.15 The Black Country Plan currently fails to identify sufficient land to meet its needs. As a result over 30% of the housing needed in the Black Country is not provided for. This is a significant failure to comply with the National Planning Policy Framework. The Plan fails to provide a sufficient supply of land to meet the housing needs of local people and fails to meet the objectives that it has set for itself.
2.16 At para 3.15 of the Plan it is acknowledged that Black Country Authorities ("BCA") have demonstrated that exceptional circumstances exist to justify the redrawing of green belt boundaries around the urban edge to release land for development due to significant housing and employment needs and a deficit in the brownfield land supply within the Black Country.
2.17 Land should therefore be fully assessed not just against its suitability for green belt status but also with regard to the sustainability of the development it might accommodate.

2.18 At paragraph 3.16 the BCA have stated that they have undertaken an extensive Green Belt and landscape sensitivity assessment to identify land that, if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Green Belt boundaries.
2 .19 The review of the Green Belt has yielded land to supply 7,720 homes, however the assessment has failed to properly assess all land and identify sites which would meet the stated aims. It is also imperative that due to the extent of the housing shortfall the balance needs to be weighed in favour of delivering land for housing.
2.20 The site of Pedmore Hall Farm, as shown in Appendix A (the "site"), was promoted (site reference 203) through the call for sites and subsequently assessed as part of a wider area in the following:
• Dudley Landscape Sensitivity Assessment - reference BL 16
• Call for Sites Assessment - site reference SA-0031-DUD
• Green Belt Study - parcel ref B65
• Sustainability Appraisal - SA-0031-DUD-A.
2.21 In those assessments there was a failure to acknowledge the different characteristics, setting, and status of land, including existence of previously developed land and consider how parts of the site could be released from the Green Belt.
2.22 The release of a smaller parcel of land, as shown in Appendix A, would make an important contribution to meeting the significant housing shortfall in the area and deliver other important social and environmental benefits, further contributing to the exceptional circumstances for the site's release.
2.23 By drawing a tighter boundary to that originally promoted (reference 203) the conclusions of the various studies listed above would result in a positive consideration of the site.
Assessment against the SA Framework
3.1 In overall terms the smaller site focused on the previously developed land and frontage plots to Pedmore Lane would perform positively against the SA framework. The site would perform better than other land in the Green Belt that have been allocated for residential development. The following is an overview demonstrating this:
3.2 In relation to Cultural Heritage (Objective 1) the smaller site has been demonstrated to be in proximity to one scheduled monument (Wychbury Ring hillfort) and one Grade II listed building (Parish Church of St Peter) both lying within 500m of the site.
The intervening topography prevents any degree of intervisibility or co-visibility from the Grade I Hagley Hall Registered Park & Garden, and as such it is not considered that the site would form part of its setting. In consideration of the Church of St Peter, there is already some existing development between this and the site, negating the potential for the development of the site to have any significant impact upon its setting, or on its significance. The Grade II* Obelisk is located to the south of Wychbury Ring hillfort and is not visible from the site and as such it is not considered that the Site would form part of its setting or impact on its significance.

3.3 In regard to the Scheduled Monument, whilst its setting remains partially rural in general character, this is limited to the north and west in particular, where the southern edges of Stourbridge have been developed, and where existing buildings
form already-developed land, whilst that to the south, albeit partially encompassed by a designed landscape in the form of Hagley Hall, remains largely open. Views from the Scheduled Monument are limited if not completely negated, by virtue of the extent and nature of tree planting across its boundary, limiting the degree to which the promontory can be experienced and understood as a hill-fort. Views to the hill-fort from all directions are similarly harmed by this planting, and in particular, views from Pedmore Lane are already encumbered by existing buildings at Pedmore Hall Farm, both by their appearance as well as their scale and massing, and the trees and other landscape elements. In addition, due to the existing character and appearance of the Scheduled Monument, in particular the extensive tree cover, there may be some opportunity to improve the general understanding of the asset through improved publicly access and interpretation linked to redevelopment of the site.
3.4 This position is further detailed by the document attached as Appendix B, Initial
Heritage Assessment.
3.5 It is concluded for Landscape (Objective 2) that the smaller contained site area including previously developed land would provide an opportunity to enhance the landscape character with the removal of the large industrial appearance buildings that occupy and dominate the site detracting from the surrounding area. By taking a landscape led approach to future development features on site such as trees and vegetation along with field boundaries could in incorporated. There would also be some opportunities to enhance characteristics and connections to the wider landscape bringing positive benefits.
3.6 The impact of the site on the heritage of the landscape is considerably different from the wider area previously promoted. This is demonstrated through the site assessment attached as Appendix B and C. There will be no perceivable impact on the historic landscape character, thus negating the concern of impact on this historic landscape character. The potential visual envelope of the proposed development will be contained to within close proximity to the site due to the screening effect of the surrounding built form, the topography, and the existing trees and vegetation.
3.7 In relation to the Green Belt and the 5 purposes as set out in NPPF, the site provides a weaker contribution to Green Belt purposes 1-3 than that assessed in the Black Country Green Belt Study. For purpose 4 there is no contribution. The site is contained alongside Pedmore and would contribute to purpose 5 by re-developing and reusing part of the site that contains existing built form. The site would be able to define a clear defensible boundary using physical features that are readily recognisable and likely to be permanent.
3.8 This position is further detailed by the document attached as Appendix C,
Landscape Study and Appendix B.
3.9 In relation to Biodiversity, flora, fauna and geodiversity (Objective 3) the site has negligible / neutral impact due to the area covered and the distance to assets referenced in the assessment framework. There are opportunities for enhancements to be delivered as a result of future development with development focused on previously developed land and horse paddocks and retention and improvement of existing habitat features.
3.10 For Climate Change mitigation (Objective 4) the SA identifies at F .5.11 that sites with development of 95 dwellings or less would be likely to result in negligible contribution to Dudley's total carbon emissions. The site performs better than the wider area assessed.
3.11 The smaller site does not alter the location in relation to Flood Zones and the impact in relation to Climate Change adaptation (Objective 5).
3.12 The smaller site which includes previously developed land alters the consideration of the impact in relation to Natural resources (Objective 6) leading to more positive impacts.
3.13 Pollution (Objective 7), the SA identifies at F .8.5.2 that sites for the development of between ten and 99 dwellings could potentially have a minor negative impact on air pollution in the local area. The smaller site has limited impact when assessed against the framework.
3.14 In relation to Waste (Objective 8) the SA identifies at F.9.11 that sites for the development of 124 dwellings or less would be expected to have a negligible impact on household waste generation in comparison to current levels. The smaller site has limited impact when assessed against the framework.
3.15 For Transport and accessibility (Objective 9) the smaller site is still in an accessible location with many local services to meet the everyday needs of future residents located within walking and cycling distances and/or accessible by public transport.
3.16 It is recognised that the smaller site would result in a capacity of 99 dwellings or less and in line with F.11.1.1 of the SA would be expected to result in a minor positive impact on Housing provision (Objective 10). This change in impact must be balanced against the shift in impact from major negative impacts on Cultural Heritage, Green Belt and landscape aspects of the SA.
3.17 The smaller site does not alter the location in relation to the 10% most deprived LSOAs and so the assessment in relation to Equality (Objective 11) remains unchanged.
3.18 The smaller site does not alter the location and position in relation to Health (Objective 12). The smaller site is however better related to the existing urban area and residents will be able to access all services by public transport as well as walking and cycling to local provision.
3.19 The smaller site does not alter the location and proximity in relation to the performance against Economy (Objective 13).
3.20 The smaller site does not alter the location and proximity in relation to Education, skills and training (Objective 14).
3.21 It is clear that the smaller site boundary focused on the previously developed land, paddock and frontage plots, and within a contained and defined area would have an overall positive outcome against the SA Framework with minimal negative impacts. There would be positive social and economic benefits from development and opportunities to deliver environmental enhancements.
Conclusion
4.1 The Plan states that there are exceptional circumstances for releasing land from
Green Belt to meet housing needs.

4.2 The Plan however fails to identify sufficient land to meet its housing needs and there is no realistic strategy to address this. Further land needs to be identified within the Black Country to meet housing needs and ensure that the Plan can be found sound at examination.
4.3 By allocating land identified in Appendix A, that being a smaller parcel from that originally submitted via the call for site, a valuable contribution to meeting the acute housing needs of the Black Country can made.
4.4 If the BCA had taken a more reasoned and justified approach to assessing sites and fully considered the specific characteristics of the site submission they would find that a smaller parcel of land, as shown by Appendix A, would have performed positively against the SA Objectives and subsequently allocated land for housing. Detailed studies on heritage and landscape, attached to this submission, have been undertaken to assess the site and demonstrate this position.
4.5 The site:
• Is available now- the landowner is actively promoting the site through the Local
Plan.
• Offers a suitable location for development now- it contains previously developed land and has been demonstrated to be a sustainable location for development in line with the SA Framework.
• Is achievable with a realistic prospect that housing will be delivered within five years - the site has no constraints to bring forward development and requires no identified infrastructure to enable delivery.
4.6 The allocation of the site, as shown in Appendix A, for residential development can deliver significant local benefits further contributing to the exceptional circumstances case for its release from the Green Belt including:
• Delivering much needed housing with circa 75 homes including affordable and family housing.
• Redevelop previously developed land and buildings supporting the national objective to make effective use of land.
• The removal of visually detracting features from the landscape with the redevelopment of poor quality buildings.
• Opportunities to improve the understanding and appreciation of the Scheduled Monument.
• Improving the existing public footpath which is currently in poor condition.
• Retaining the south and east portions of the site as undeveloped allowing for opportunities for compensatory improvements to the environmental quality and accessibility.
• Through the design and layout take a landscape led approach incorporating existing landscape features and introducing better visual permeability.
• Define a defensible boundary using physical features that are readily recognisable and likely to be permanent.
4. 7 The BCA should therefore review their existing evidence base, reassessing sites and allocate further land, including Pedmore Hall Farm as shown in Appendix A, to meet their pressing and unmet housing need.

Object

Draft Black Country Plan

Policy HOU1 – Delivering Sustainable Housing Growth

Representation ID: 21794

Received: 11/10/2021

Respondent: Wood Abbey Ltd

Agent: Mr Richard Cowell

Representation Summary:

Introduction
1.1 This representation is made in response to the consultation on the Draft Black Country Plan 2039 (Regulation 18) (hereafter referred to as "the Plan").
1.2 This representation is objecting to the Plan and specifically in relation to the following policies and evidence base:
Policy
• Policy CSP1- Development Strategy
• Policy GB1- The Black Country Green Belt
• Policy HOU1 - Delivering Sustainable Housing Growth
Evidence base
• Black Country Green Belt Study
• Black Country landscape sensitivity assessment
• Sustainability Appraisal of the Black Country Plan
Basis of the objection
2.1 The Plan contains planning policies and land allocations to support the growth and regeneration of the Black Country over the years to 2039.
2.2 The Plan contains a Vision for the Black Country in 2039. This is underpinned by strategic objectives and priorities designed to deliver the Vision and associated outcomes. The proposed policy framework will guide and shape development across the Black Country and will set clear parameters for growth and transformation.
2.3 The Black Country Plan is being produced to, amongst other things, specifically facilitate the delivery of the right development types to meet identified and emerging needs in the most sustainable places; and to meet housing needs between now and 2039.
2.4 The importance of producing the Black Country Plan is to address local challenges and issues and specific reference is made to, "Providing good quality housing that meets the needs of a growing population - the Plan needs to identify sufficient land for housing to meet the needs of people who are likely to live in the area over the period of the plan."
2.5 The Black Country Housing Market Area Assessment sets out the housing need for the area with The Black Country Urban Capacity Update 2020 providing an updated statement on the current housing need. This is confirmed at paragraph 2.1.4 on page 7 as being 4,004 homes per annum, which equates to 76,076 homes over the Plan period 2020-39.
2.6 One of the core objectives of the Plan is, "Housing that meets all our needs".
2. 7 The Development Strategy for the Black Country is set out in Policy CSP1. The Policy provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039.
2.8 The housing target for the Black Country, as defined in Policy CSP1, is 47,837 new homes over the period 2020-39.
2.9 Compared to a local housing need of 76,076 homes the Plan has a shortfall of 28,239 homes.
2.10 The Black Country Urban Capacity Update 2020 concludes at paragraph 4.3 page 34 that "the identified shortfall -- that is the amount of housing need which cannot be accommodated in the Black Country urban areas - remains significant... 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."
2.11 This shortfall doesn't account for the current and emerging wider housing shortfall position across the Greater Birmingham and Black Country Housing Market Area (GBBCHMA), within which the Black Country is located.
2.12 The failure to deliver sufficient housing supply in the Black Country continues the failure from the Core Strategy period. As stated on page 16 of the Urban Capacity Update 2020 the Black Country as a whole has an under-supply of 10,347 homes at 2025/26 - 37% of the remaining target of 28,325 homes. The under-supply is continuous throughout the Plan period with the main reasons for the increased under-supply since 2019 being the further loss of supply on occupied employment land and the re-phasing of sites beyond 2026 to reflect realistic delivery timescales, in line with Government guidance on deliverability.
2.13 In order to meet this significant shortfall The Plan places an emphasis on the Duty to Cooperate, with The Plan stating that 28,239 homes will be exported through Duty to Co-operate.
2.14 The latest letters dated 2018 from neighbouring authorities identify their own challenges and inability to contribute to the level expected by the Black Country Authorities. The Reg 18 Duty to Cooperate Statement makes significant assumptions about contributions from other authorities to meeting housing needs in the Black Country. The Black Country cannot rely on solving their housing needs by exporting housing supply to neighbouring authorities, many of which are unable to meet their own needs.
2.15 The Black Country Plan currently fails to identify sufficient land to meet its needs. As a result over 30% of the housing needed in the Black Country is not provided for. This is a significant failure to comply with the National Planning Policy Framework. The Plan fails to provide a sufficient supply of land to meet the housing needs of local people and fails to meet the objectives that it has set for itself.
2.16 At para 3.15 of the Plan it is acknowledged that Black Country Authorities ("BCA") have demonstrated that exceptional circumstances exist to justify the redrawing of green belt boundaries around the urban edge to release land for development due to significant housing and employment needs and a deficit in the brownfield land supply within the Black Country.
2.17 Land should therefore be fully assessed not just against its suitability for green belt status but also with regard to the sustainability of the development it might accommodate.

2.18 At paragraph 3.16 the BCA have stated that they have undertaken an extensive Green Belt and landscape sensitivity assessment to identify land that, if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Green Belt boundaries.
2 .19 The review of the Green Belt has yielded land to supply 7,720 homes, however the assessment has failed to properly assess all land and identify sites which would meet the stated aims. It is also imperative that due to the extent of the housing shortfall the balance needs to be weighed in favour of delivering land for housing.
2.20 The site of Pedmore Hall Farm, as shown in Appendix A (the "site"), was promoted (site reference 203) through the call for sites and subsequently assessed as part of a wider area in the following:
• Dudley Landscape Sensitivity Assessment - reference BL 16
• Call for Sites Assessment - site reference SA-0031-DUD
• Green Belt Study - parcel ref B65
• Sustainability Appraisal - SA-0031-DUD-A.
2.21 In those assessments there was a failure to acknowledge the different characteristics, setting, and status of land, including existence of previously developed land and consider how parts of the site could be released from the Green Belt.
2.22 The release of a smaller parcel of land, as shown in Appendix A, would make an important contribution to meeting the significant housing shortfall in the area and deliver other important social and environmental benefits, further contributing to the exceptional circumstances for the site's release.
2.23 By drawing a tighter boundary to that originally promoted (reference 203) the conclusions of the various studies listed above would result in a positive consideration of the site.
Assessment against the SA Framework
3.1 In overall terms the smaller site focused on the previously developed land and frontage plots to Pedmore Lane would perform positively against the SA framework. The site would perform better than other land in the Green Belt that have been allocated for residential development. The following is an overview demonstrating this:
3.2 In relation to Cultural Heritage (Objective 1) the smaller site has been demonstrated to be in proximity to one scheduled monument (Wychbury Ring hillfort) and one Grade II listed building (Parish Church of St Peter) both lying within 500m of the site.
The intervening topography prevents any degree of intervisibility or co-visibility from the Grade I Hagley Hall Registered Park & Garden, and as such it is not considered that the site would form part of its setting. In consideration of the Church of St Peter, there is already some existing development between this and the site, negating the potential for the development of the site to have any significant impact upon its setting, or on its significance. The Grade II* Obelisk is located to the south of Wychbury Ring hillfort and is not visible from the site and as such it is not considered that the Site would form part of its setting or impact on its significance.

3.3 In regard to the Scheduled Monument, whilst its setting remains partially rural in general character, this is limited to the north and west in particular, where the southern edges of Stourbridge have been developed, and where existing buildings
form already-developed land, whilst that to the south, albeit partially encompassed by a designed landscape in the form of Hagley Hall, remains largely open. Views from the Scheduled Monument are limited if not completely negated, by virtue of the extent and nature of tree planting across its boundary, limiting the degree to which the promontory can be experienced and understood as a hill-fort. Views to the hill-fort from all directions are similarly harmed by this planting, and in particular, views from Pedmore Lane are already encumbered by existing buildings at Pedmore Hall Farm, both by their appearance as well as their scale and massing, and the trees and other landscape elements. In addition, due to the existing character and appearance of the Scheduled Monument, in particular the extensive tree cover, there may be some opportunity to improve the general understanding of the asset through improved publicly access and interpretation linked to redevelopment of the site.
3.4 This position is further detailed by the document attached as Appendix B, Initial
Heritage Assessment.
3.5 It is concluded for Landscape (Objective 2) that the smaller contained site area including previously developed land would provide an opportunity to enhance the landscape character with the removal of the large industrial appearance buildings that occupy and dominate the site detracting from the surrounding area. By taking a landscape led approach to future development features on site such as trees and vegetation along with field boundaries could in incorporated. There would also be some opportunities to enhance characteristics and connections to the wider landscape bringing positive benefits.
3.6 The impact of the site on the heritage of the landscape is considerably different from the wider area previously promoted. This is demonstrated through the site assessment attached as Appendix B and C. There will be no perceivable impact on the historic landscape character, thus negating the concern of impact on this historic landscape character. The potential visual envelope of the proposed development will be contained to within close proximity to the site due to the screening effect of the surrounding built form, the topography, and the existing trees and vegetation.
3.7 In relation to the Green Belt and the 5 purposes as set out in NPPF, the site provides a weaker contribution to Green Belt purposes 1-3 than that assessed in the Black Country Green Belt Study. For purpose 4 there is no contribution. The site is contained alongside Pedmore and would contribute to purpose 5 by re-developing and reusing part of the site that contains existing built form. The site would be able to define a clear defensible boundary using physical features that are readily recognisable and likely to be permanent.
3.8 This position is further detailed by the document attached as Appendix C,
Landscape Study and Appendix B.
3.9 In relation to Biodiversity, flora, fauna and geodiversity (Objective 3) the site has negligible / neutral impact due to the area covered and the distance to assets referenced in the assessment framework. There are opportunities for enhancements to be delivered as a result of future development with development focused on previously developed land and horse paddocks and retention and improvement of existing habitat features.
3.10 For Climate Change mitigation (Objective 4) the SA identifies at F .5.11 that sites with development of 95 dwellings or less would be likely to result in negligible contribution to Dudley's total carbon emissions. The site performs better than the wider area assessed.
3.11 The smaller site does not alter the location in relation to Flood Zones and the impact in relation to Climate Change adaptation (Objective 5).
3.12 The smaller site which includes previously developed land alters the consideration of the impact in relation to Natural resources (Objective 6) leading to more positive impacts.
3.13 Pollution (Objective 7), the SA identifies at F .8.5.2 that sites for the development of between ten and 99 dwellings could potentially have a minor negative impact on air pollution in the local area. The smaller site has limited impact when assessed against the framework.
3.14 In relation to Waste (Objective 8) the SA identifies at F.9.11 that sites for the development of 124 dwellings or less would be expected to have a negligible impact on household waste generation in comparison to current levels. The smaller site has limited impact when assessed against the framework.
3.15 For Transport and accessibility (Objective 9) the smaller site is still in an accessible location with many local services to meet the everyday needs of future residents located within walking and cycling distances and/or accessible by public transport.
3.16 It is recognised that the smaller site would result in a capacity of 99 dwellings or less and in line with F.11.1.1 of the SA would be expected to result in a minor positive impact on Housing provision (Objective 10). This change in impact must be balanced against the shift in impact from major negative impacts on Cultural Heritage, Green Belt and landscape aspects of the SA.
3.17 The smaller site does not alter the location in relation to the 10% most deprived LSOAs and so the assessment in relation to Equality (Objective 11) remains unchanged.
3.18 The smaller site does not alter the location and position in relation to Health (Objective 12). The smaller site is however better related to the existing urban area and residents will be able to access all services by public transport as well as walking and cycling to local provision.
3.19 The smaller site does not alter the location and proximity in relation to the performance against Economy (Objective 13).
3.20 The smaller site does not alter the location and proximity in relation to Education, skills and training (Objective 14).
3.21 It is clear that the smaller site boundary focused on the previously developed land, paddock and frontage plots, and within a contained and defined area would have an overall positive outcome against the SA Framework with minimal negative impacts. There would be positive social and economic benefits from development and opportunities to deliver environmental enhancements.
Conclusion
4.1 The Plan states that there are exceptional circumstances for releasing land from
Green Belt to meet housing needs.

4.2 The Plan however fails to identify sufficient land to meet its housing needs and there is no realistic strategy to address this. Further land needs to be identified within the Black Country to meet housing needs and ensure that the Plan can be found sound at examination.
4.3 By allocating land identified in Appendix A, that being a smaller parcel from that originally submitted via the call for site, a valuable contribution to meeting the acute housing needs of the Black Country can made.
4.4 If the BCA had taken a more reasoned and justified approach to assessing sites and fully considered the specific characteristics of the site submission they would find that a smaller parcel of land, as shown by Appendix A, would have performed positively against the SA Objectives and subsequently allocated land for housing. Detailed studies on heritage and landscape, attached to this submission, have been undertaken to assess the site and demonstrate this position.
4.5 The site:
• Is available now- the landowner is actively promoting the site through the Local
Plan.
• Offers a suitable location for development now- it contains previously developed land and has been demonstrated to be a sustainable location for development in line with the SA Framework.
• Is achievable with a realistic prospect that housing will be delivered within five years - the site has no constraints to bring forward development and requires no identified infrastructure to enable delivery.
4.6 The allocation of the site, as shown in Appendix A, for residential development can deliver significant local benefits further contributing to the exceptional circumstances case for its release from the Green Belt including:
• Delivering much needed housing with circa 75 homes including affordable and family housing.
• Redevelop previously developed land and buildings supporting the national objective to make effective use of land.
• The removal of visually detracting features from the landscape with the redevelopment of poor quality buildings.
• Opportunities to improve the understanding and appreciation of the Scheduled Monument.
• Improving the existing public footpath which is currently in poor condition.
• Retaining the south and east portions of the site as undeveloped allowing for opportunities for compensatory improvements to the environmental quality and accessibility.
• Through the design and layout take a landscape led approach incorporating existing landscape features and introducing better visual permeability.
• Define a defensible boundary using physical features that are readily recognisable and likely to be permanent.
4. 7 The BCA should therefore review their existing evidence base, reassessing sites and allocate further land, including Pedmore Hall Farm as shown in Appendix A, to meet their pressing and unmet housing need.

Object

Draft Black Country Plan

Policy CSP1 - Development Strategy

Representation ID: 21795

Received: 11/10/2021

Respondent: Wood Abbey Ltd

Agent: Mr Richard Cowell

Representation Summary:

Introduction
1.1 This representation is made in response to the consultation on the Draft Black Country Plan 2039 (Regulation 18) (hereafter referred to as "the Plan").
1.2 This representation is objecting to the Plan and specifically in relation to the following policies and evidence base:
Policy
• Policy CSP1- Development Strategy
• Policy GB1- The Black Country Green Belt
• Policy HOU1 - Delivering Sustainable Housing Growth
Evidence base
• Black Country Green Belt Study
• Black Country landscape sensitivity assessment
• Sustainability Appraisal of the Black Country Plan
Basis of the objection
2.1 The Plan contains planning policies and land allocations to support the growth and regeneration of the Black Country over the years to 2039.
2.2 The Plan contains a Vision for the Black Country in 2039. This is underpinned by strategic objectives and priorities designed to deliver the Vision and associated outcomes. The proposed policy framework will guide and shape development across the Black Country and will set clear parameters for growth and transformation.
2.3 The Black Country Plan is being produced to, amongst other things, specifically facilitate the delivery of the right development types to meet identified and emerging needs in the most sustainable places; and to meet housing needs between now and 2039.
2.4 The importance of producing the Black Country Plan is to address local challenges and issues and specific reference is made to, "Providing good quality housing that meets the needs of a growing population - the Plan needs to identify sufficient land for housing to meet the needs of people who are likely to live in the area over the period of the plan."
2.5 The Black Country Housing Market Area Assessment sets out the housing need for the area with The Black Country Urban Capacity Update 2020 providing an updated statement on the current housing need. This is confirmed at paragraph 2.1.4 on page 7 as being 4,004 homes per annum, which equates to 76,076 homes over the Plan period 2020-39.
2.6 One of the core objectives of the Plan is, "Housing that meets all our needs".
2. 7 The Development Strategy for the Black Country is set out in Policy CSP1. The Policy provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039.
2.8 The housing target for the Black Country, as defined in Policy CSP1, is 47,837 new homes over the period 2020-39.
2.9 Compared to a local housing need of 76,076 homes the Plan has a shortfall of 28,239 homes.
2.10 The Black Country Urban Capacity Update 2020 concludes at paragraph 4.3 page 34 that "the identified shortfall -- that is the amount of housing need which cannot be accommodated in the Black Country urban areas - remains significant... 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."
2.11 This shortfall doesn't account for the current and emerging wider housing shortfall position across the Greater Birmingham and Black Country Housing Market Area (GBBCHMA), within which the Black Country is located.
2.12 The failure to deliver sufficient housing supply in the Black Country continues the failure from the Core Strategy period. As stated on page 16 of the Urban Capacity Update 2020 the Black Country as a whole has an under-supply of 10,347 homes at 2025/26 - 37% of the remaining target of 28,325 homes. The under-supply is continuous throughout the Plan period with the main reasons for the increased under-supply since 2019 being the further loss of supply on occupied employment land and the re-phasing of sites beyond 2026 to reflect realistic delivery timescales, in line with Government guidance on deliverability.
2.13 In order to meet this significant shortfall The Plan places an emphasis on the Duty to Cooperate, with The Plan stating that 28,239 homes will be exported through Duty to Co-operate.
2.14 The latest letters dated 2018 from neighbouring authorities identify their own challenges and inability to contribute to the level expected by the Black Country Authorities. The Reg 18 Duty to Cooperate Statement makes significant assumptions about contributions from other authorities to meeting housing needs in the Black Country. The Black Country cannot rely on solving their housing needs by exporting housing supply to neighbouring authorities, many of which are unable to meet their own needs.
2.15 The Black Country Plan currently fails to identify sufficient land to meet its needs. As a result over 30% of the housing needed in the Black Country is not provided for. This is a significant failure to comply with the National Planning Policy Framework. The Plan fails to provide a sufficient supply of land to meet the housing needs of local people and fails to meet the objectives that it has set for itself.
2.16 At para 3.15 of the Plan it is acknowledged that Black Country Authorities ("BCA") have demonstrated that exceptional circumstances exist to justify the redrawing of green belt boundaries around the urban edge to release land for development due to significant housing and employment needs and a deficit in the brownfield land supply within the Black Country.
2.17 Land should therefore be fully assessed not just against its suitability for green belt status but also with regard to the sustainability of the development it might accommodate.

2.18 At paragraph 3.16 the BCA have stated that they have undertaken an extensive Green Belt and landscape sensitivity assessment to identify land that, if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Green Belt boundaries.
2 .19 The review of the Green Belt has yielded land to supply 7,720 homes, however the assessment has failed to properly assess all land and identify sites which would meet the stated aims. It is also imperative that due to the extent of the housing shortfall the balance needs to be weighed in favour of delivering land for housing.
2.20 The site of Pedmore Hall Farm, as shown in Appendix A (the "site"), was promoted (site reference 203) through the call for sites and subsequently assessed as part of a wider area in the following:
• Dudley Landscape Sensitivity Assessment - reference BL 16
• Call for Sites Assessment - site reference SA-0031-DUD
• Green Belt Study - parcel ref B65
• Sustainability Appraisal - SA-0031-DUD-A.
2.21 In those assessments there was a failure to acknowledge the different characteristics, setting, and status of land, including existence of previously developed land and consider how parts of the site could be released from the Green Belt.
2.22 The release of a smaller parcel of land, as shown in Appendix A, would make an important contribution to meeting the significant housing shortfall in the area and deliver other important social and environmental benefits, further contributing to the exceptional circumstances for the site's release.
2.23 By drawing a tighter boundary to that originally promoted (reference 203) the conclusions of the various studies listed above would result in a positive consideration of the site.
Assessment against the SA Framework
3.1 In overall terms the smaller site focused on the previously developed land and frontage plots to Pedmore Lane would perform positively against the SA framework. The site would perform better than other land in the Green Belt that have been allocated for residential development. The following is an overview demonstrating this:
3.2 In relation to Cultural Heritage (Objective 1) the smaller site has been demonstrated to be in proximity to one scheduled monument (Wychbury Ring hillfort) and one Grade II listed building (Parish Church of St Peter) both lying within 500m of the site.
The intervening topography prevents any degree of intervisibility or co-visibility from the Grade I Hagley Hall Registered Park & Garden, and as such it is not considered that the site would form part of its setting. In consideration of the Church of St Peter, there is already some existing development between this and the site, negating the potential for the development of the site to have any significant impact upon its setting, or on its significance. The Grade II* Obelisk is located to the south of Wychbury Ring hillfort and is not visible from the site and as such it is not considered that the Site would form part of its setting or impact on its significance.

3.3 In regard to the Scheduled Monument, whilst its setting remains partially rural in general character, this is limited to the north and west in particular, where the southern edges of Stourbridge have been developed, and where existing buildings
form already-developed land, whilst that to the south, albeit partially encompassed by a designed landscape in the form of Hagley Hall, remains largely open. Views from the Scheduled Monument are limited if not completely negated, by virtue of the extent and nature of tree planting across its boundary, limiting the degree to which the promontory can be experienced and understood as a hill-fort. Views to the hill-fort from all directions are similarly harmed by this planting, and in particular, views from Pedmore Lane are already encumbered by existing buildings at Pedmore Hall Farm, both by their appearance as well as their scale and massing, and the trees and other landscape elements. In addition, due to the existing character and appearance of the Scheduled Monument, in particular the extensive tree cover, there may be some opportunity to improve the general understanding of the asset through improved publicly access and interpretation linked to redevelopment of the site.
3.4 This position is further detailed by the document attached as Appendix B, Initial
Heritage Assessment.
3.5 It is concluded for Landscape (Objective 2) that the smaller contained site area including previously developed land would provide an opportunity to enhance the landscape character with the removal of the large industrial appearance buildings that occupy and dominate the site detracting from the surrounding area. By taking a landscape led approach to future development features on site such as trees and vegetation along with field boundaries could in incorporated. There would also be some opportunities to enhance characteristics and connections to the wider landscape bringing positive benefits.
3.6 The impact of the site on the heritage of the landscape is considerably different from the wider area previously promoted. This is demonstrated through the site assessment attached as Appendix B and C. There will be no perceivable impact on the historic landscape character, thus negating the concern of impact on this historic landscape character. The potential visual envelope of the proposed development will be contained to within close proximity to the site due to the screening effect of the surrounding built form, the topography, and the existing trees and vegetation.
3.7 In relation to the Green Belt and the 5 purposes as set out in NPPF, the site provides a weaker contribution to Green Belt purposes 1-3 than that assessed in the Black Country Green Belt Study. For purpose 4 there is no contribution. The site is contained alongside Pedmore and would contribute to purpose 5 by re-developing and reusing part of the site that contains existing built form. The site would be able to define a clear defensible boundary using physical features that are readily recognisable and likely to be permanent.
3.8 This position is further detailed by the document attached as Appendix C,
Landscape Study and Appendix B.
3.9 In relation to Biodiversity, flora, fauna and geodiversity (Objective 3) the site has negligible / neutral impact due to the area covered and the distance to assets referenced in the assessment framework. There are opportunities for enhancements to be delivered as a result of future development with development focused on previously developed land and horse paddocks and retention and improvement of existing habitat features.
3.10 For Climate Change mitigation (Objective 4) the SA identifies at F .5.11 that sites with development of 95 dwellings or less would be likely to result in negligible contribution to Dudley's total carbon emissions. The site performs better than the wider area assessed.
3.11 The smaller site does not alter the location in relation to Flood Zones and the impact in relation to Climate Change adaptation (Objective 5).
3.12 The smaller site which includes previously developed land alters the consideration of the impact in relation to Natural resources (Objective 6) leading to more positive impacts.
3.13 Pollution (Objective 7), the SA identifies at F .8.5.2 that sites for the development of between ten and 99 dwellings could potentially have a minor negative impact on air pollution in the local area. The smaller site has limited impact when assessed against the framework.
3.14 In relation to Waste (Objective 8) the SA identifies at F.9.11 that sites for the development of 124 dwellings or less would be expected to have a negligible impact on household waste generation in comparison to current levels. The smaller site has limited impact when assessed against the framework.
3.15 For Transport and accessibility (Objective 9) the smaller site is still in an accessible location with many local services to meet the everyday needs of future residents located within walking and cycling distances and/or accessible by public transport.
3.16 It is recognised that the smaller site would result in a capacity of 99 dwellings or less and in line with F.11.1.1 of the SA would be expected to result in a minor positive impact on Housing provision (Objective 10). This change in impact must be balanced against the shift in impact from major negative impacts on Cultural Heritage, Green Belt and landscape aspects of the SA.
3.17 The smaller site does not alter the location in relation to the 10% most deprived LSOAs and so the assessment in relation to Equality (Objective 11) remains unchanged.
3.18 The smaller site does not alter the location and position in relation to Health (Objective 12). The smaller site is however better related to the existing urban area and residents will be able to access all services by public transport as well as walking and cycling to local provision.
3.19 The smaller site does not alter the location and proximity in relation to the performance against Economy (Objective 13).
3.20 The smaller site does not alter the location and proximity in relation to Education, skills and training (Objective 14).
3.21 It is clear that the smaller site boundary focused on the previously developed land, paddock and frontage plots, and within a contained and defined area would have an overall positive outcome against the SA Framework with minimal negative impacts. There would be positive social and economic benefits from development and opportunities to deliver environmental enhancements.
Conclusion
4.1 The Plan states that there are exceptional circumstances for releasing land from
Green Belt to meet housing needs.

4.2 The Plan however fails to identify sufficient land to meet its housing needs and there is no realistic strategy to address this. Further land needs to be identified within the Black Country to meet housing needs and ensure that the Plan can be found sound at examination.
4.3 By allocating land identified in Appendix A, that being a smaller parcel from that originally submitted via the call for site, a valuable contribution to meeting the acute housing needs of the Black Country can made.
4.4 If the BCA had taken a more reasoned and justified approach to assessing sites and fully considered the specific characteristics of the site submission they would find that a smaller parcel of land, as shown by Appendix A, would have performed positively against the SA Objectives and subsequently allocated land for housing. Detailed studies on heritage and landscape, attached to this submission, have been undertaken to assess the site and demonstrate this position.
4.5 The site:
• Is available now- the landowner is actively promoting the site through the Local
Plan.
• Offers a suitable location for development now- it contains previously developed land and has been demonstrated to be a sustainable location for development in line with the SA Framework.
• Is achievable with a realistic prospect that housing will be delivered within five years - the site has no constraints to bring forward development and requires no identified infrastructure to enable delivery.
4.6 The allocation of the site, as shown in Appendix A, for residential development can deliver significant local benefits further contributing to the exceptional circumstances case for its release from the Green Belt including:
• Delivering much needed housing with circa 75 homes including affordable and family housing.
• Redevelop previously developed land and buildings supporting the national objective to make effective use of land.
• The removal of visually detracting features from the landscape with the redevelopment of poor quality buildings.
• Opportunities to improve the understanding and appreciation of the Scheduled Monument.
• Improving the existing public footpath which is currently in poor condition.
• Retaining the south and east portions of the site as undeveloped allowing for opportunities for compensatory improvements to the environmental quality and accessibility.
• Through the design and layout take a landscape led approach incorporating existing landscape features and introducing better visual permeability.
• Define a defensible boundary using physical features that are readily recognisable and likely to be permanent.
4. 7 The BCA should therefore review their existing evidence base, reassessing sites and allocate further land, including Pedmore Hall Farm as shown in Appendix A, to meet their pressing and unmet housing need.

Object

Draft Black Country Plan

A. Dudley

Representation ID: 21799

Received: 11/10/2021

Respondent: Wood Abbey Ltd

Agent: Mr Richard Cowell

Representation Summary:

Introduction
1.1 This representation is made in response to the consultation on the Draft Black Country Plan 2039 (Regulation 18) (hereafter referred to as "the Plan").
1.2 This representation is objecting to the Plan and specifically in relation to the following policies and evidence base:
Policy
• Policy CSP1- Development Strategy
• Policy GB1- The Black Country Green Belt
• Policy HOU1 - Delivering Sustainable Housing Growth
Evidence base
• Black Country Green Belt Study
• Black Country landscape sensitivity assessment
• Sustainability Appraisal of the Black Country Plan
Basis of the objection
2.1 The Plan contains planning policies and land allocations to support the growth and regeneration of the Black Country over the years to 2039.
2.2 The Plan contains a Vision for the Black Country in 2039. This is underpinned by strategic objectives and priorities designed to deliver the Vision and associated outcomes. The proposed policy framework will guide and shape development across the Black Country and will set clear parameters for growth and transformation.
2.3 The Black Country Plan is being produced to, amongst other things, specifically facilitate the delivery of the right development types to meet identified and emerging needs in the most sustainable places; and to meet housing needs between now and 2039.
2.4 The importance of producing the Black Country Plan is to address local challenges and issues and specific reference is made to, "Providing good quality housing that meets the needs of a growing population - the Plan needs to identify sufficient land for housing to meet the needs of people who are likely to live in the area over the period of the plan."
2.5 The Black Country Housing Market Area Assessment sets out the housing need for the area with The Black Country Urban Capacity Update 2020 providing an updated statement on the current housing need. This is confirmed at paragraph 2.1.4 on page 7 as being 4,004 homes per annum, which equates to 76,076 homes over the Plan period 2020-39.
2.6 One of the core objectives of the Plan is, "Housing that meets all our needs".
2. 7 The Development Strategy for the Black Country is set out in Policy CSP1. The Policy provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039.
2.8 The housing target for the Black Country, as defined in Policy CSP1, is 47,837 new homes over the period 2020-39.
2.9 Compared to a local housing need of 76,076 homes the Plan has a shortfall of 28,239 homes.
2.10 The Black Country Urban Capacity Update 2020 concludes at paragraph 4.3 page 34 that "the identified shortfall -- that is the amount of housing need which cannot be accommodated in the Black Country urban areas - remains significant... 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."
2.11 This shortfall doesn't account for the current and emerging wider housing shortfall position across the Greater Birmingham and Black Country Housing Market Area (GBBCHMA), within which the Black Country is located.
2.12 The failure to deliver sufficient housing supply in the Black Country continues the failure from the Core Strategy period. As stated on page 16 of the Urban Capacity Update 2020 the Black Country as a whole has an under-supply of 10,347 homes at 2025/26 - 37% of the remaining target of 28,325 homes. The under-supply is continuous throughout the Plan period with the main reasons for the increased under-supply since 2019 being the further loss of supply on occupied employment land and the re-phasing of sites beyond 2026 to reflect realistic delivery timescales, in line with Government guidance on deliverability.
2.13 In order to meet this significant shortfall The Plan places an emphasis on the Duty to Cooperate, with The Plan stating that 28,239 homes will be exported through Duty to Co-operate.
2.14 The latest letters dated 2018 from neighbouring authorities identify their own challenges and inability to contribute to the level expected by the Black Country Authorities. The Reg 18 Duty to Cooperate Statement makes significant assumptions about contributions from other authorities to meeting housing needs in the Black Country. The Black Country cannot rely on solving their housing needs by exporting housing supply to neighbouring authorities, many of which are unable to meet their own needs.
2.15 The Black Country Plan currently fails to identify sufficient land to meet its needs. As a result over 30% of the housing needed in the Black Country is not provided for. This is a significant failure to comply with the National Planning Policy Framework. The Plan fails to provide a sufficient supply of land to meet the housing needs of local people and fails to meet the objectives that it has set for itself.
2.16 At para 3.15 of the Plan it is acknowledged that Black Country Authorities ("BCA") have demonstrated that exceptional circumstances exist to justify the redrawing of green belt boundaries around the urban edge to release land for development due to significant housing and employment needs and a deficit in the brownfield land supply within the Black Country.
2.17 Land should therefore be fully assessed not just against its suitability for green belt status but also with regard to the sustainability of the development it might accommodate.

2.18 At paragraph 3.16 the BCA have stated that they have undertaken an extensive Green Belt and landscape sensitivity assessment to identify land that, if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Green Belt boundaries.
2 .19 The review of the Green Belt has yielded land to supply 7,720 homes, however the assessment has failed to properly assess all land and identify sites which would meet the stated aims. It is also imperative that due to the extent of the housing shortfall the balance needs to be weighed in favour of delivering land for housing.
2.20 The site of Pedmore Hall Farm, as shown in Appendix A (the "site"), was promoted (site reference 203) through the call for sites and subsequently assessed as part of a wider area in the following:
• Dudley Landscape Sensitivity Assessment - reference BL 16
• Call for Sites Assessment - site reference SA-0031-DUD
• Green Belt Study - parcel ref B65
• Sustainability Appraisal - SA-0031-DUD-A.
2.21 In those assessments there was a failure to acknowledge the different characteristics, setting, and status of land, including existence of previously developed land and consider how parts of the site could be released from the Green Belt.
2.22 The release of a smaller parcel of land, as shown in Appendix A, would make an important contribution to meeting the significant housing shortfall in the area and deliver other important social and environmental benefits, further contributing to the exceptional circumstances for the site's release.
2.23 By drawing a tighter boundary to that originally promoted (reference 203) the conclusions of the various studies listed above would result in a positive consideration of the site.
Assessment against the SA Framework
3.1 In overall terms the smaller site focused on the previously developed land and frontage plots to Pedmore Lane would perform positively against the SA framework. The site would perform better than other land in the Green Belt that have been allocated for residential development. The following is an overview demonstrating this:
3.2 In relation to Cultural Heritage (Objective 1) the smaller site has been demonstrated to be in proximity to one scheduled monument (Wychbury Ring hillfort) and one Grade II listed building (Parish Church of St Peter) both lying within 500m of the site.
The intervening topography prevents any degree of intervisibility or co-visibility from the Grade I Hagley Hall Registered Park & Garden, and as such it is not considered that the site would form part of its setting. In consideration of the Church of St Peter, there is already some existing development between this and the site, negating the potential for the development of the site to have any significant impact upon its setting, or on its significance. The Grade II* Obelisk is located to the south of Wychbury Ring hillfort and is not visible from the site and as such it is not considered that the Site would form part of its setting or impact on its significance.

3.3 In regard to the Scheduled Monument, whilst its setting remains partially rural in general character, this is limited to the north and west in particular, where the southern edges of Stourbridge have been developed, and where existing buildings
form already-developed land, whilst that to the south, albeit partially encompassed by a designed landscape in the form of Hagley Hall, remains largely open. Views from the Scheduled Monument are limited if not completely negated, by virtue of the extent and nature of tree planting across its boundary, limiting the degree to which the promontory can be experienced and understood as a hill-fort. Views to the hill-fort from all directions are similarly harmed by this planting, and in particular, views from Pedmore Lane are already encumbered by existing buildings at Pedmore Hall Farm, both by their appearance as well as their scale and massing, and the trees and other landscape elements. In addition, due to the existing character and appearance of the Scheduled Monument, in particular the extensive tree cover, there may be some opportunity to improve the general understanding of the asset through improved publicly access and interpretation linked to redevelopment of the site.
3.4 This position is further detailed by the document attached as Appendix B, Initial
Heritage Assessment.
3.5 It is concluded for Landscape (Objective 2) that the smaller contained site area including previously developed land would provide an opportunity to enhance the landscape character with the removal of the large industrial appearance buildings that occupy and dominate the site detracting from the surrounding area. By taking a landscape led approach to future development features on site such as trees and vegetation along with field boundaries could in incorporated. There would also be some opportunities to enhance characteristics and connections to the wider landscape bringing positive benefits.
3.6 The impact of the site on the heritage of the landscape is considerably different from the wider area previously promoted. This is demonstrated through the site assessment attached as Appendix B and C. There will be no perceivable impact on the historic landscape character, thus negating the concern of impact on this historic landscape character. The potential visual envelope of the proposed development will be contained to within close proximity to the site due to the screening effect of the surrounding built form, the topography, and the existing trees and vegetation.
3.7 In relation to the Green Belt and the 5 purposes as set out in NPPF, the site provides a weaker contribution to Green Belt purposes 1-3 than that assessed in the Black Country Green Belt Study. For purpose 4 there is no contribution. The site is contained alongside Pedmore and would contribute to purpose 5 by re-developing and reusing part of the site that contains existing built form. The site would be able to define a clear defensible boundary using physical features that are readily recognisable and likely to be permanent.
3.8 This position is further detailed by the document attached as Appendix C,
Landscape Study and Appendix B.
3.9 In relation to Biodiversity, flora, fauna and geodiversity (Objective 3) the site has negligible / neutral impact due to the area covered and the distance to assets referenced in the assessment framework. There are opportunities for enhancements to be delivered as a result of future development with development focused on previously developed land and horse paddocks and retention and improvement of existing habitat features.
3.10 For Climate Change mitigation (Objective 4) the SA identifies at F .5.11 that sites with development of 95 dwellings or less would be likely to result in negligible contribution to Dudley's total carbon emissions. The site performs better than the wider area assessed.
3.11 The smaller site does not alter the location in relation to Flood Zones and the impact in relation to Climate Change adaptation (Objective 5).
3.12 The smaller site which includes previously developed land alters the consideration of the impact in relation to Natural resources (Objective 6) leading to more positive impacts.
3.13 Pollution (Objective 7), the SA identifies at F .8.5.2 that sites for the development of between ten and 99 dwellings could potentially have a minor negative impact on air pollution in the local area. The smaller site has limited impact when assessed against the framework.
3.14 In relation to Waste (Objective 8) the SA identifies at F.9.11 that sites for the development of 124 dwellings or less would be expected to have a negligible impact on household waste generation in comparison to current levels. The smaller site has limited impact when assessed against the framework.
3.15 For Transport and accessibility (Objective 9) the smaller site is still in an accessible location with many local services to meet the everyday needs of future residents located within walking and cycling distances and/or accessible by public transport.
3.16 It is recognised that the smaller site would result in a capacity of 99 dwellings or less and in line with F.11.1.1 of the SA would be expected to result in a minor positive impact on Housing provision (Objective 10). This change in impact must be balanced against the shift in impact from major negative impacts on Cultural Heritage, Green Belt and landscape aspects of the SA.
3.17 The smaller site does not alter the location in relation to the 10% most deprived LSOAs and so the assessment in relation to Equality (Objective 11) remains unchanged.
3.18 The smaller site does not alter the location and position in relation to Health (Objective 12). The smaller site is however better related to the existing urban area and residents will be able to access all services by public transport as well as walking and cycling to local provision.
3.19 The smaller site does not alter the location and proximity in relation to the performance against Economy (Objective 13).
3.20 The smaller site does not alter the location and proximity in relation to Education, skills and training (Objective 14).
3.21 It is clear that the smaller site boundary focused on the previously developed land, paddock and frontage plots, and within a contained and defined area would have an overall positive outcome against the SA Framework with minimal negative impacts. There would be positive social and economic benefits from development and opportunities to deliver environmental enhancements.
Conclusion
4.1 The Plan states that there are exceptional circumstances for releasing land from
Green Belt to meet housing needs.

4.2 The Plan however fails to identify sufficient land to meet its housing needs and there is no realistic strategy to address this. Further land needs to be identified within the Black Country to meet housing needs and ensure that the Plan can be found sound at examination.
4.3 By allocating land identified in Appendix A, that being a smaller parcel from that originally submitted via the call for site, a valuable contribution to meeting the acute housing needs of the Black Country can made.
4.4 If the BCA had taken a more reasoned and justified approach to assessing sites and fully considered the specific characteristics of the site submission they would find that a smaller parcel of land, as shown by Appendix A, would have performed positively against the SA Objectives and subsequently allocated land for housing. Detailed studies on heritage and landscape, attached to this submission, have been undertaken to assess the site and demonstrate this position.
4.5 The site:
• Is available now- the landowner is actively promoting the site through the Local
Plan.
• Offers a suitable location for development now- it contains previously developed land and has been demonstrated to be a sustainable location for development in line with the SA Framework.
• Is achievable with a realistic prospect that housing will be delivered within five years - the site has no constraints to bring forward development and requires no identified infrastructure to enable delivery.
4.6 The allocation of the site, as shown in Appendix A, for residential development can deliver significant local benefits further contributing to the exceptional circumstances case for its release from the Green Belt including:
• Delivering much needed housing with circa 75 homes including affordable and family housing.
• Redevelop previously developed land and buildings supporting the national objective to make effective use of land.
• The removal of visually detracting features from the landscape with the redevelopment of poor quality buildings.
• Opportunities to improve the understanding and appreciation of the Scheduled Monument.
• Improving the existing public footpath which is currently in poor condition.
• Retaining the south and east portions of the site as undeveloped allowing for opportunities for compensatory improvements to the environmental quality and accessibility.
• Through the design and layout take a landscape led approach incorporating existing landscape features and introducing better visual permeability.
• Define a defensible boundary using physical features that are readily recognisable and likely to be permanent.
4. 7 The BCA should therefore review their existing evidence base, reassessing sites and allocate further land, including Pedmore Hall Farm as shown in Appendix A, to meet their pressing and unmet housing need.
Appendix A - Site Plan
Appendix B - Initial Heritage Assessment
Appendix C - Landscape Study
Initial Site Allocation Heritage Assessment
LAND OFF PEDMORE LANE, STOURBRIDGE, WEST MIDLANDS
October 2021
Wood Abbey
CONTENTS
1. Introduction
2. Identification of Assets and Assessment of Significance
3. Development Potential
4. General Development Parameters
5. Conclusion
Appendices
A. Statutory List Description
B. Legislative and Policy Framework
C. Methodology

October 2021
1. Introduction
1.1. Report Background
This initial heritage assessment for a site allocation (the 'report') has been prepared by RP Heritage on behalf of Wood Abbey (the Client). The purpose of the report is to ascertain and assess the impact of proposed allocation of land for housing at land at Pedmore Hall Farm (the Site) on the heritage significance of heritage assets both consisting of the Site and surrounding and within the vicinity of the Site (Figure 1.1 and Plate 1.1). At this stage, the document seeks to provide an overview of the significance of heritage assets likely to be affected, together with an overview of the potential impact upon such significance and on their setting, as far as this contributes to such significance.
Other documents have been referred to in the writing of this report and should also form important background reading for the report. These include (but not exclusively) the list descriptions for nearby heritage assets, and both national and local government policy and guidance. The findings of this high level report are based on initial research of the Site and its surroundings, a site visit undertaken carried out in October 2021, together with an application of professional judgement.
1.2. Site Description
The Site is centred at approximately SO 91525 82103 wand consists of several fields, separated by either modern fencing and/or low level planting/hedging. Several large, modern buildings lie within the centre of the Site, with an access track leading from Pedmore Lane. The fields are generally currently used for horses, with one associated temporary field stable in the north-western field. The topography of the land slopes away from the south, with the agricultural buildings being at the northern edge of the steeper slope running from Wychbury hill-fort, and sitting on a flat element of land, most likely as a result of man-made land formation during the mid to late twentieth century. To the east of the track leading from Pedmore Lane, the topography is slightly steeper than that to the west, which has a berm, with flatter land beyond to Pedmore Lane.
1.3. Heritage Assets
There is a requirement under national policy for an applicant of development proposals to ascertain what constitutes the 'significance' of any heritage assets identified, what potential effects the development proposals will have on that heritage asset's significance, and how such effects would be mitigated. Section 2 sets out the heritage assets considered within this report, and provides a description of the assets, together with an analysis of their significance and the degree to which their setting contributes to their significance. This assessment follows the Historic England guidance and methodologies set out in GPA 2 and GPA3, whilst referencing English Heritage's Conservation Principles (EH, 2008) to ascertain what constitutes an asset's significance or its 'heritage values', as well as the Principles of Selection for Listed Buildings, with specific regard to the principle of group value listing. Appendix C provides a detailed description of these documents, and how they have been used to inform this assessment.
1.4. Development Proposals
The initial proposals are for examining the site as a potential site allocation, for development, taking account of additional areas for green space and associated infrastructure..
2. Identification of Assets and Assessment of Significance
2.1. Heritage Assets Identified
An inspection of the relevant databases and sources, including the Historic Environment Record (HER), the National Heritage List for England (NHLE), and the Council's web-site, has identified one scheduled monument (Wychbury Ring hill• fort) and one Grade II listed building (Parish Church of St Peter) as lying within 500m of the Site: whilst the Grade I Hagley Hall Registered Park & Garden lies just beyond this search radius. In addition to this, the former Pedmore Hall lies to the south of the Site.
During the Site Allocation assessment, a larger site was considered (Figure 2.1), and this was considered to have a "high overall sensitivity to residential development due to the distinctive landform, historic features, settlement setting and visual character of the area", whilst also "lying within an Area of High Historic Landscape Value 'Ped more and Foxcote Landscape Heritage Area' The site is in close proximity to Wychbury Hill Scheduled Ancient Monument and Grade I Hagley Hall Registered Park and Garden". Whilst not a designation, the Pedmore and Foxcote Landscape Heritage Area is assumed to consist of the band of land running between Cradley, Hasbury, Hayley Green, Wollescote and Pedmore, identified within the general characterisation of the Black Country Historic Landscape Characterisation as consisting largely of nineteenth century field systems. However, when considered in more detail, the Site covers several areas, including the existing farm buildings dating to the 1960's to 1970s, which post-date previous buildings on the Site (HBL1438), identified on the nineteenth century Ordnance Survey maps, as well as a small element of the 1960s development (HBL1387) (Figure 2.2). In addition, the eastern part of the Site is identified as part of a wider field system had probably formed part of an open field in the medieval period, and where ridge and furrow is noted (HBL1458). However, the area covered by the Site has been severed from the wider, ore open, field system by virtue of planting and the existing footpath, whilst the ridge and furrow can be identified from satellite imagery as predominantly lying to the north-east, adjacent to the junction of Pedmore Lane and Gauden Road, with none being identified within the Site itself. The final element, forming the south-western corner of the Site is identified in the HLC as being an enclosed field system of unknown date with a semi regular pattern with sinuous boundaries (HBL1444) - however, this character has now all but disappeared, with the fields now largely either open or defined by tree boundaries. As such, the impact of the Site on the heritage of this landscape is considerably different from the previous Site, and will have no perceivable impact on this historic landscape character, thus negating the concern of impact on this historic landscape character.
As such, Table 1 and Figure 3.1 set out the heritage assets considered within this report, with no impact considered to the significance of other heritage assets. However, due to the intervening built form and topography between the majority of these assets, an overview of their significance and setting is generally provided, excepting for Wychbury Ring hill-fort, in particular as the size and boundary of this Site has largely negated any potential impact on their setting and significance.
The level of detail provided should be proportionate to the importance of each heritage asset, and no more than is sufficient to understand the potential impact that may arise from the development proposals.
Description
Sitting across the promontory directly to the south-east of the Site, this scheduled monument covers a total area of c.6ha, and is centred across the top of the hill. Much of the hill-fort is now covered in dense tree-cover, although when within its confines, its earthworks can be readily experienced - two entrances can easily be identified from these earthworks - that to the west, where the remains of the earthworks are high and clear, leading through both the internal and external ditches and ramparts, whilst the second lies to the south-east, again clearly defined by the access through the remnants of the clearly defined earthworks forming the holloway leading up to and through the entrance. The earthworks vary in their prominence, with those to the north being largely eroded, with the hill escarpment providing an clear edge to the monument - considering the steepness of this scarp, it may be that this side was never completely defended, although there has been no significant exploration or excavation across the monument in order to confirm this.
Significance
The significance of this Scheduled Monument is considerable in particular as multivallate hill-forts tend to be of a substantial size, and whilst the total area of this exceeds what would generally be classified as a small multivallate hill-fort (being in the region of 6.5-8ha), it is still small in comparison to many nationally (the largest being around 85-1 00ha). It thus represents a small minority of such monuments. With their purpose being part defence and part centre of occupation (whether permanent or at times of risk), the relative size of hill-forts has to be taken in the context of the effort for their construction, design and ability to defend. In terms of the larger hill-forts, these generally have been found to contain large areas of occupation, with houses, granaries, roads and areas of manufactory, being able to sustain a considerable population, often with additional areas of occupation outside (and generally focused to the entrances), and thus the effort of construction, mostly over several phases, could be off-set by the population which they supported. In contrast, smaller multivallate hill-forts, by the nature of their size, would often only have supported a small population, and evidence from those already excavated have shown a smaller range of activities, mainly restricted to occupation or as secondary, outlying defences of a wider population - considering the size, height and nature of their defences against the relatively small population, they are thus an llustration of the importance of the area and of the site itself, with a great need for such defence - this is further evidenced by the general location of these across the country, with the majority being focused around the Welsh Marches. They therefore have substantial evidential value, in their ability to provide archaeological evidence for settlement hierarchy and formation during the Iron Age. Whilst Wychbury Ring has only had a small excavation during the end of the nineteenth century, and thus little is known about the type, nature and extent of such evidence it may provide, the fact that this evidence remains in situ, and that the evidence from other similarly sized hill-forts can be used to extrapolate information from Wychbury, means that its potential for considerable evidential value is high, although it is unclear as to how the extensive tree cover may have affected such potential.
In terms of its other heritage values of Wychbury Ring, the aesthetic value largely arise from the formation and appearance of the ditches and ramparts, which, as stated above, are generally experienced from their immediate context, although those to the north and north-west appear to have suffered from considerable silting. There is also considerable illustrative value in these, through their representation of the defences dating from the fifth century BC.
Setting
In terms of the setting of Wychbury Ring hill-fort, as would be expected, the position of the monument on top of a hill would have provided it with clear views across the surrounding landscape, most likely in all directions, with the site being chosen explicitly for this purpose, as can be seen in the 3D modelling in Figures 2.4-2.7. However, when standing within the monument, the current tree cover completely negates the ability to understand this relationship between the hill-fort and the surrounding landscape, whether when the trees are in full leaf in summer months or bare in winter.
When looking at the hill-fort from the surrounding landscape, it is readily seen due to its position in the landscape, as illustrated in Figures 2.4-2.7, but its defences cannot be either experienced or appreciated in any form, due to the extent of the tree-cover, and thus its high significance as a small multivallate hill-fort cannot be reasonably understood - this only happening when within its immediate confines and even then, only through the extent and scale of the defences. Whilst its immediate setting in all directions is largely of open landscape, this is heavily defined to the north and north-east by existing twentieth century development on Pedmore Lane, consisting of a range of two storey dwellings (primarily to the north) and three-storey apartments (to the north-east); by Ped more Hall Lane and Hagley Road to the west; and Hagley Hill and Birmingham Road to the south. In addition, there is a cluster of built form to the north-west formed by Ped more Hall (now mostly a late twentieth century house), the farm-buildings on the Site which sit at a height of high two-storey dwellings with a considerably larger planform, and several dwellings on the southern side of Pedmore Lane, resulting in development already encroaching on this element of its setting. To the south and south-east lies with Grade Registered Park & Garden of Hagley Hall, the closest element of which is the northern-most element of the park, itself separated from the rest of the parkland by the Birmingham Road (A456).
In short, whilst its setting remains partially rural in general character, this is limited to the north and west in particular, where the southern edges of Stourbridge have been developed, and where existing buildings form already-developed land, whilst that to the south, albeit partially encompassed by a designed landscape in the form of Hagley Hall, remains largely open. Views from the Scheduled Monument are limited if not completely negated, by virtue of the extent and nature of tree planting across its boundary, limiting the degree to which the promontory can be experienced and understood as a hill-fort. Views to the hill-fort from all directions are similarly harmed by this planting, and in particular, views from Pedmore Lane are already encumbered by existing buildings on the Site, both by their appearance, as well as their scale and massing.
Church of St Peter
This Grade II listed church primarily dates to the nineteenth century, although the listing description notes that it has earlier, most likely eleventh century albeit these elements appear to be contained internally. The church itself is constructed in red sandstone, with ashlar Perpendicular windows.
In terms of its significance, this is largely through its aesthetic appearance, with large blocks of coursed sandstone, with a squat tower, and Perpendicular windows. Whilst an internal inspection was not possible at the time of writing, from the listing description the internal elements contribute to the illustrative value through the Medieval elements retained within the church during its rebuilding, whilst it also has some value through the Victorian construction and repairs, reflecting the trend at this time for such works to churches throughout the country.
In terms of its setting, the church is largely contained within an enclosed churchyard, with eighteenth century rectory sitting to the east which make some contribution to the aesthetic and illustrative values of the listed church, whilst the more modern development to all sides make no particular contribution to its significance. The Site, lying beyond modern development, including the cricket ground, again makes no contribution, primarily due to the severing of the Site and the listed building, together with the lack of intervisibility and co-visibility and the lack of any historic association between the two.
Hagley Hall Registered Park & Garden
This Registered Park and Garden also contains several listed buildings, the closest of which is the Grade II listed Obelisk. The Park and Garden was focused around the Grade I listed Hagley Hall, although the northern-most section, forming the area of parkland closest to the Site, is now severed from the main area by virtue of the Birmingham Road (A449). The northern area of parkland rises up towards Wychbury Hill, and consists of an open field system, largely framed by woodland. Due to the rising topography, this northern area of parkland is visible from the main grounds and house, with the Obelisk forming one of two focal points and eye-catchers.
In terms of its significance, this is multi-fold, partially through its overall aesthetic value, which the northern part of the parkland makes a considerable contribution to, as do views of the south side of Wychbury Ring hill-fort. However, the Site, sitting behind and under the hill-fort is not visible from the Registered Park & Garden, in contrast to the previous Site Allocation proposal, and makes no particular contribution to any of the heritage values of the Grade I heritage asset.
Pedmore Hall
Present on the first edition Ordnance Survey maps, Pedmore Hall appears to have been a substantial hall, constructed in red brick, with a slate hipped roof, together with additional outbuildings including a stable block sitting to the north, similarly constructed in a red brick with slate roof, siting on a north-south alignment, with a projecting rear wing. The main house has been considerably altered and extended, with a large two-storey front extension and portico, with all windows appearing now to be replaced in PVCu, with additional extensions to the rear to house an indoor swimming pool. The stable-block, being the building closest to the Site, retains some architectural detailing, such as the spandrel to the front elevation contained within a central gable
Although this building has origins in the nineteenth century, it has been subject to considerable alterations, in particular during the early twenty-first century, with its overall planform and appearance having now largely been so heavily altered as to negate the appreciation and understanding of its historic planform and appearance, and as such its potential historic interest. Whilst elements, such as the stable block, still retain some degree of their original architecture, these, as with the main house, have seen considerable alteration, together with unsympathetic additions, linking them to the main house. Considering these alterations, the building has little aesthetic value in terms of heritage value, whilst its historic illustrative value as a country hall with clear links to the surrounding rural landscape has been largely compromised. As such, this assessment considers that the building, as it stands today, would not have sufficient heritage interest as to warrant consideration as a non-designated heritage asset.
Conclusion
Whilst the Site has been shown to lie within the setting of Wychbury Ring, this assessment has shown that the Site does not make any contribution to the significance of any of the other identified heritage assets, and in terms of its overall heritage interest, identified through the Historic Landscape Characterisation study for the Black Country, the reduced scale of the proposed allocation has addressed the previous concerns, in particular through focusing on land which has no identified elements such as ridge and furrow, whilst in part comprising land which is identified as elements of mid-twentieth century development. Overall, the conclusion here is that the Site would not impinge on land which would be reconsidered as being of high historic landscape value, and would not affect the significance of the majority of the heritage assets identified in this assessment, resulting in a neutral impact on their significance and setting, insofar as this contributes to significance. As such, the following section focuses on the potential impact on the significance of Wychbury Ring hill-fort.
3. Development Potential
The following considers the potential for residential development on the Site, taking account of relative sensitivities, including areas which have already been developed, and the setting of the scheduled monument, including views to and from it. The Site sits across c.5.1 ha of land, with existing buildings, (currently serving as stabling and associated storage) sitting roughly central to the Site. A public footpath runs along the north-eastern boundary.
The Site can be roughly divided into five elements (Figure 3.1):
1. Land fronting Ped more Lane, consisting of two field parcels divided by the access track;
2. The existing buildings;
3. Land to the south-west of the existing buildings, defined by trees to the north and west, and by the track leading to Ped more Hall to the east;
4. Land sitting to the rear of the existing buildings; and
5. Land sitting to the east, defined by the trees to the side of the existing buildings.
Area 1
Currently in use for horses, the topography of this element is varied, with the eastern part rising more sharply towards the existing buildings, whilst the western element, separated by the access road, is flatter, with a sharp rise at its southern end. This area is largely experienced in a semi-urban context. Views across this area toward the scheduled monument, from 30 Pedmore Lane to the dwellings on the corner with Pedmore Hall Lane, are heavily interrupted by the existing buildings, which either form a heavy distraction from these views, or completely block any views to the hill and thus to the asset. As such, these views are considered as being of a lower relative sensitivity (Figure 3.2) and this area is considered as having a very low sensitivity in terms of the setting of the designated heritage asset.
Area2
Consideration is given here to the presence of the existing buildings, their scale, appearance and massing - the buildings are of modern brick construction with the highest building also having the upper elements constructed in vertical timber boarding. All buildings appear to have corrugated asbestos roofing, and sit over two to two and 1/2 storeys, forming a visual front-drop to views from Pedmore Lane. Access to the buildings is already provided via an unmade access road. Due to their character and appearance, and sitting within a semi-urban context, they are considered as having a low negative impact on views to the hill, and make no contribution to the wider significance of the designated heritage asset. Considering that it already consists of built form, this area is considered as having a very low sensitivity in terms of the setting of the scheduled monument.
Area 3
Sitting to the rear of the buildings, and between the buildings and Ped more Hall Lane, this area in part forms the backdrop of part of Area 1, whilst also providing a green-fringe to Pedmore Hall Lane. With no views between this Area and the scheduled monument, and in particular with Pedmore Hall lying between the two, and it being heavily screened, it makes no contribution to the significance or setting of Wychbury Ring hill-fort, and thus development on this area would unlikely to have any effect on the significance of this asset. As such, it is considered as having a very low sensitivity in terms of the scheduled monument.
Area 4
Sitting to the rear of the existing buildings, and largely out of public view, albeit with some oblique views (Figure 3.2) from Pedmore Lane, this area retains a more rural character than Areas 1-3, by virtue of its physical and visual separation from Pedmore Lane, and thus provides a more rural front-drop for the scheduled monument and is of moderately more sensitive than these previous areas. However, the presence of built form across this area may result in a degree of harm to the designated heritage asset, through bringing development closer to the asset, and thus this is considered as being of moderate sensitivity, although other elements of development may be considered here, such as green space or other similar elements, which would retain a more open character in this element of setting.
Area 5
Although this element of setting has been shown not to make a significant contribution to Wychbury Ring hill-fort, nonetheless, views to the hill are afforded from Pedmore Lane (Figure 3.2), with the clearest views to the asset being gained from the northern section of Pedmore Lane, where, between 30 Ped more Lane to the south-west and the junction of Ped more Lane and Gauden Road to the north• east, where the hill is seen across an existing field, including the eastern-most parcel of the Site. Whilst these views are filtered by trees forming the northern boundary to this field, and by other trees in the foreground, they still allow for a semi-rural front-drop for this designated heritage asset. As such, this area is considered to be of a higher relative sensitivity.

4. General Development Parameters
In terms of ensuring that the setting of Wychbury Ring hill-fort is preserved, insofar as the setting contributes to its significance, the following sets out some general parameters for development, identifying three separate potential character areas.
Area 1
This area has been shown to have the lowest sensitivity, and when considering the existing buildings, residential development across this area, incorporating associated infrastructure, should be of a maximum of three storey to Pedmore Lane, reducing in height to the south to a maximum of two storeys. Existing access arrangements would provide an ideal opportunity for main access to the Site. The existing buildings, due to their scale and massing, may provide some precedent for building, whether residential or community centres or similar, where the scale of buildings would be seen in the context of the existing buildings, and where there would be some clear benefit in terms of general visual amenity. There is also opportunity to strengthen and improve the character and appearance of the existing footpath leading up to Wychbury Ring, perhaps through the introduction of native species of hedging and the general improvement of management of this boundary, thus enhancing the initial approach to the asset from Pedmore Lane, as well as the south-eastern boundary, through the redefining of the historic field boundary, again perhaps through the introduction of appropriate hedging and tree planting.
Area 2
Whilst this area has been identified as being of moderate sensitivity, as already mentioned, there may be some opportunity for sensitive development in this area, although this should be more associated with infrastructure than of built form • elements such as car-parking, play areas or SUDS may be appropriate in this area, although again, this should be defined at its eastern edges through appropriate screening and boundary treatment, which would assist in both screening any such development, as well as reintroducing a more sympathetic character to this area.
Area 3
This area, due to the views gained across it towards Wychbury Ring with the topography rising sharply towards the scheduled monument, as well as its closer proximity to the asset at the south-western corner, should be retained clear of development, and retained as green space. There are considerable opportunities here to improve the general character and appearance of the eastern boundary abutting the footpath, continuing the improvements suggested for Area 1. Other features, such as existing tree planting, should be retained, and strengthened where feasible.
5. Conclusion
Historic Environment

This assessment has shown that, whilst there are several heritage assets, both designated and potentially non-designated, within the surroundings ofthe proposed site, the reduced scale of this from the previously considered potential allocation has negated the potential impact on the significance and setting of the majority of these, with potential impacts only remaining on the scheduled monument of Wychbury Ring hill-fort. In addition, the reduced scale has also negated the potential impact on the heritage landscape of the Wychbury and Foxbury landscape, with areas now including already developed land, most of which has been subject of development during the mid twentieth century, whilst also ensuring that areas of high archaeological potential, such as those where ridge and furrow are evident and historic fieldscapes can still be identified, remain unaffected by the proposed allocation, resulting in a neutral impact on each of these areas of consideration ..
With regards to the potential impact on Wychbury Ring, whilst the allocation of this site would see some alteration to its setting, it has been shown that the existing setting makes little, if any, contribution to its significance - in addition, the following section concludes that there are several clear opportunities for enhancement to the significance and ability to understand and appreciate this heritage asset of high value.
General Opportunities
There are some clear opportunities for the development of the Site, in terms of improving the understanding and appreciation of the Scheduled Monument, some of which are outside the Site boundary. For instance, the general approach up to Wychbury Ring along the existing public footpath is currently in poor condition, and there may be some opportunity to improve this access, both through appropriate boundary treatment, as well as improvement to the actual footpath itself, helping to improve the quality and experience of the overall approach to the asset.
In addition, due to the existing character and appearance of the monument, in particular the extensive tree cover, there may be some opportunity to improve the general understanding of the asset through improved publicly accessed interpretation, such as information boards leading up to the Site along the footpath. In addition, the potential for improvement of the understanding of the archaeology of the Site and whether it provided any degree of use during the occupation of the hill-fort would assist in the known archaeological record.
Overall Conclusion
The Site has been shown to make no contribution to many of the surrounding heritage assets, with the new boundary now ensuring that the historic environment is now largely preserved from harm. Whilst it does lie within the setting f the Wychbury Ring hill-fort, there are some clear and exciting opportunities which would negate, if not outweigh, any perceived harm to the setting of this heritage asset, and which would enhance the understanding, appreciation and context of this scheduled monument, resulting in an overall net benefit to the significance of this heritage asset.

Document: Landscape Study
Project: Land at Pedmore Hall Farm
Client: Wood Abbey Ltd.

CONTENTS
1.0 INTRODUCTION
1.1. Scope
1.2. Statement Methodology
2.0 GREEN BELT POLICIES AND LANDSCAPE DESIGNATIONS
2.1. NATIONAL AND LOCAL POLICY
2.2. Designations
3.0 PROMOTION OF DEVELOPMENT
4.0 LANDSCAPE CHARACTER STUDY
4.1. Landscape Context
4.2. Site-specific landscape review
5.0 VISUAL AMENITY STUDY
5.1. Visual Baseline
5.2. Visual Receptors
6.0 GREEN BELT STUDY
6.1. The site's contribution to the purposes of the green belt
7.0 SUMMARY AND CONCLUSIONS
7 .1. Scope
7.2. Summary of Findings
APPENDIX 01: FIGURES
Land at Pedmore Hall Farm: Landscape Study
1.0 INTRODUCTION
1.1. Scope
1.1.1 Tetra Tech is instructed by Wood Abbey Ltd to prepare this Landscape Study, which relates to the promotion of housing development on Land at Pedmore Hall Farm, see Figure LA.01-1 for site location. The site is located within the West Midlands Green Belt in Dudley, which forms part of the extensive Green Belt area around Birmingham. The National Planning Policy Framework (NPPF) requires that "Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation orupdating of plans."
1.1.2 This Landscape Study reviews the potential for the site to be developed for housing. At this early stage, there is no detailed masterplan for the site, but that one will be produced taking a landscape led approach to the parameters for development. It is assumed that trees and vegetation would be retained, where possible, and some areas of the site would be exempt from built development.
1.2. Statement Methodology
1.2.1 The methodology used for reviewing the surrounding landscape character and visual amenity is broadly based on the recommendations in Guidelines for Landscape and Visual Impact Assessment 3rd Edition published by The Landscape Institute and the Institute of Environmental Management & Assessment in 2013 (GLVIA3).
1.2.2 The Landscape Study process comprises of high-level desk studies and field surveys. A Chartered Landscape Architect from Tetra Tech visited the site and surrounding area on 5th October 2021 during dry weather with good visibility.
Guidance
1.2.3 In addition to GLVIA3, the Landscape lnstitute's Technical Guidance Note, Visual Representation of Development Proposals, September 2019 was referred to. Relevant local planning policy, landscape character assessments, and other contextual information sources were also referred to.
1.2.4 In reviewing the Green Belt, reference has been made to the Landscape lnstitute's Landscape Briefing: Green Belt Policy, April 2018. It recognises that "Green Belt is a spatial planning tool, not a designation that provides landscape protection. Current Green Belt policy does not require Green Belt to be of high landscape quality or even particularly attractive."3
1.2.1 Relevant Green Belt policy, landscape character assessments, and other contextual information sources were also referred to, including:
• Landscape and seascape character assessments, published by Natural England, 20144
• An Approach to Landscape Character Assessment, Natural England 20145
• Natural England character area descriptions, 2013
• NPPF policies and guidance relevant to Green Belt, regional and local policy and studies in relation to Green Belt including Black Country Core Strategy, Dudley Borough Development Strategy, Black Country Green Belt Study, Black country Landscape Sensitivity Assessments.
• Regional and local landscape character assessment including Worcestershire County Council Landscape Character Assessment, and Black Country Historic Landscape Characterisation Study.
2.0 GREEN BELT POLICIES AND LANDSCAPE DESIGNATIONS
2.1. NATIONAL AND LOCAL POLICY National Planning Policy Framework
2.1.1 The National Planning Policy Framework (NPPF), July 2021°, sets out the Government's planning policies for England and how these should be applied. The NPPF 'is a material consideration in planning decisions. Planning policies and decisions must also reflect relevant international obligations and statutory requirements.' The key principles that are of relevance to landscape, Green Belt, and the proposed development include:
• Section 12: Achieving well-designed places, paragraph 130 states "Planning policies and decisions should ensure that developments:
a) will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development;
b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;
c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities);
d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;
e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and
f) create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.
• Section 13: Protecting Green Belt land, 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."
• Paragraph 138 lists the five purposes that the Green Belt serves:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land."
• Paragraph 147 states "Inappropriate development is, by definition, harmful to the Green
Belt and should not be approved in except in very special circumstances."
• Paragraph 149 states "A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are:
[ ... ]
g) limited infilling or the partial or complete redevelopment of previously developed land, whether redundant or in continuing use (excluding temporary buildings), which would:
- not have a greater impact on the openness of the Green Belt than the existing development; or
- not cause substantial harm to the openness of the Green Belt, where the development would re-use previously developed land and contribute to meeting an identified affordable housing need within the area of the local planning authority."
NPPF Guidance: Green Belt
2.1.2 The Green Belt Guidance, published 22 July 2019 provides advise on the role of Green Belt in the planning system.7 Of relevance to the proposed development and landscape and visual aspects is:
• "What factors can be taken into account when considering the potential impact of development on the openness of the Green Belt?
Assessing the impact of a proposal on the openness of the Green Belt, where it is relevant to do so, requires a judgment based on the circumstances of the case. By way of example, the courts have identified a number of matters which may need to be taken into account in making this assessment. These include, but are not limited to:
openness is capable of having both spatial and visual aspects -- in other words, the visual impact of the proposal may be relevant, as could its volume
[ ... ]"
Local Policy
2.1.3 Planning policy for the area is provided by the Dudley Local Plan, which is made up of the following documents: The Black Country Core Strategy, February 2011; Dudley Borough Development Strategy, February 2017; and Dudley Area Action Plan. Policies relevant to the
Black Country Green Belt and the proposed development include:
Black Country Core Strategy
• Policy CSP2 Development Outside the Growth Network states "By 2026, the areas outside the Strategic Centres and Regeneration Corridors will provide:
• A strong Green Belt to promote urban renaissance within the urban area and provide easy access to the countryside for urban residents where the landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible;
[ ... ]"
The policy goes on to state that "Green Belt boundaries will be maintained and protected from inappropriate development."
Dudley Borough Development Strategy
• Policy 523 - Green Belt states "There shall be a presumption against inappropriate development in the Dudley Borough's designated Green Belt... Within the Green Belt, development will not be permitted except for circumstances set out in the National Planning Policy Framework..."
Black Country Green Belt Study
2.1.4 The Black Country Green Belt Study was published in September 2019, which provided an assessment of the performance of the Green Belt in the City of Wolverhampton, Dudley, Sandwell and Walsall in line with NPPF. "The Study draws out variations in the contribution of land to the five Green Belt purposes, identifying areas of land whose performance ranges from relatively weak to relatively strong in Green Belt terms."
2.1.5 The first stage of the study defined 140 strategic parcels in the Green Belt and assessed their contribution the Green Belt purposes. The study strategically assessed each parcel in relation to their contribution the five of the purposes of the Green Belt using the following three-point scale:
Moderate contribution Green Belt performs moderately well against the purpose

Weak/ No contribution Green Belt makes a weak or no contribution to the purpose
2.1.6 In relation to Green Belt Purpose 5, to assist in urban regeneration, by encouraging the recycling of derelict and other urban land, the study concluded that "all Green Belt land within the Black Country makes a strong contribution"° to the purpose.
2.1.7 The site is located in the southwest of parcel B65: Wychbury Hill, Foxcote and Lutley, see Figure LA.01-2. The parcel size is 302 hectares and covers land between the settlement boundary of Pedmore to the north and the local authority boundary between Dudley and
8 Paragraph 1.3, Black Country Green Belt Study Stage 1 and 2 Report, Prepared by LUC, September 2019
9 Page 38, Table 4.1 Green Belt Contribution Ratings Black Country Green Belt Study Stage 1 and 2 Report, Prepared by LUC, September 2019
• Paragraph 4.27, Black Country Green Belt Study Stage 1 and 2 Report, Prepared by LUC, September 2019
Land at Pedmore Hall Farm: Landscape Study
Bromsgrove to the south. It stretches east from Hagley Road to the settlement edge of Halesowen.
2.1.8 Table 1 below provides a summary of the assessments for parcel B65 in relation to its contribution to the 5 Green Belt purposes.
Table 1: Parcel B65 assessment summary of parcel contribution to Green Belt purposes11
Green Belt purpose B65: Assessment
Purpose 2: To prevent neighbouring towns merging into one another
Moderate
"Land contributes to separation between Stourbridge and Halesowen... but development to the north has compromised the sense of distinction between the two."
Purpose: To preserve the setting and special character of historic towns
Weak/ No contribution
"Land does not contribute to the setting or character of a historic town."
2.1.9 The study then went on to sub-divided some parcels. Parcel B65 was sub-divided into parcels B65A, B65B, and B65C. Scenarios within each sub-parcel assessed the harm of releasing land. The site is located in sub-parcel B65A: Wychbury Hill, which covers 73.7 hectares stretching east from Hagley Road to the southwest of Hodge Hill (excludes the areas of to the south of Foxcote and Lutley). Scenario 1 covers 64.05 hectares within sub-parcel B65A, which is also partly covered by the promoted housing site 203 that covers the site and areas beyond the site boundary and was assessed as very high to the harm as "The release of uncontained land in this sub-parcel would result in a significant expansion of the urban edge and would weaken the integrity of surrounding Green Belt land."


Black Country Landscape Sensitivity Assessment
2.1.10 Black Country Landscape Sensitivity Assessment was published in September 2019, which sets out the findings of the landscape sensitivity assessment in relation to housing and commercial development on Green Belt in the Black Country. The purpose of the study was to "provide an assessment of the extent to which the character and quality of the landscape... within the Black Country... is, in principle, susceptible to change as a result of introducing built development." The study considered specific areas of Green Belt land identified at Stage 2 of the LUC Green Belt Study.
2.1.11 The overall landscape sensitivity assessment study area was divided into landscape assessment areas. The site is located in landscape assessment area BL 16, which covers 76.2 hectares stretching east from Hagley Road to the southwest of Hodge Hill (broadly the same as parcel B65A in the Green Belt Study, but also includes part of the Wychbury Ring Scheduled Monument).
2.1.12 Landscape assessment area BL16 is concluded to have a High overall sensitivity to residential development "due to the distinctive landform, historic features, settlement setting and visual character of the area."1
2.1.13 The definition for High sensitivity is "The landscape has strong character and qualities with notable features which are highly sensitive to change as a result of introducing built development."15
2.2. Designations
2.2.1 Designations provide an indication of landscape value. They are areas that have been recognised for qualities such as scenic beauty and the recreational potential of the landscape. Designations are shown on Figure LA.01-1.
National & Local landscape designations
National Park/ AONB/ Local landscape designations
2.2.2 The site and 1km study area are not located within a National Park, Area of Outstanding Natural Beauty (AONB), or non-statutory landscape designations such as Areas of Great Landscape Value/ Special Landscape Areas. National Parks, AONBs, and local landscape designations have therefore been scoped out from further review in this study.
Ancient woodland
2.2.3 The 1km study area contains some small, scattered blocks of ancient woodland. The nearest block to the site is Roundhill Wood Ancient and Semi-Natural Woodland located circa 330m to the southeast of the site, which partially covers the Wychbury Ring Scheduled Monument.
Historic and cultural landscape designations
2.2.4 Relevant historic and cultural designations are shown on Figure LA.01-1. The setting of historic and cultural designations is a consideration during the preparation of landscape studies as these features inform the overall landscape character, quality, and value of the area. The Landscape Study does not address the effects on heritage assets however it considers the contribution these features make to landscape value and scenic quality.
Conservation areas and listed buildings
2.2.5 There are no conservation areas within the 1km study area.
2.2.6 There are no listed buildings within the site. The nearest listed building is the Grade II listed Parish Church of St Peter, which is located circa 135m to the northwest of the site and on the west side of Pedmore Hall Lane.
2.2.7 Circa 600m to the southeast of the site is the Grade II* Obelisk About¾ Mile North of Hagley Hall.
Scheduled Monuments
2.2.8 Approximately 225m to the southeast of the site is Wychbury Ring, which is an enclosed hillfort. The scheduled monument is set within an area of woodland on top of the rounded hill.
2.2.9 There are no other scheduled monuments within the study area.
Registered Parks and Gardens
2.2.10 Hagley Hall is located circa 500m to the southeast of the site at its nearest point. Within the study area, the registered park and garden mainly covers south facing slopes with the top of the hill featuring an Obelisk, south of Roundhill Wood, and extends further south and beyond the study area. Hagel Hill A456 dual carriageway bisects the northern part of the registered park and garden, just within the 1km study area.
2.2.11 The topography of south facing slopes and the adjacent woodland provides separation between the site and the registered park and garden in relation to both landscape character and visual amenity, Hagley Hall is therefore scoped out from further consideration in this landscape study.
Public access
2.2.12 Public access is shown on Figure LA.01-1. There are no National Cycle Routes or areas of access land as defined under the CRoW Act within the 1km study area and are therefore scoped out from further consideration in this Landscape Study.
Long distance footpaths (LDFP)
2.2.13 Part of the Monarch's Way LDFP skirts the northeast boundary of the site as it heads in an east direction up the slopes of Wychbury Hill before heading south down the hill and connecting to the A456 Hagley Hill dual carriageway. Adjacent to the north of the site, the LDFP connects to Pedmore Lane and heads in a northeast direction before heading northwest through the residential area of Pedmore.
Public rights of way (PRoW)
2.2.14 There is a sparse network of public rights of way within the 1km study area, which all comprise of public footpaths. Footpaths are mainly located within the settlement area of Ped more to the west of the site or are located beyond 500m of the site to the south and east, providing a connection between local roads or to the Monarch's Way LDFP.
3.0 PROMOTION OF DEVELOPMENT
3.1.1 This section describes the main principles of the potential proposed development on the site which may affect landscape and/or visual amenity, refer to Figure LA.02.
3.1.2 At this stage, development proposals for the site are currently being considered, but the main feature of the proposals would include the demolition of the existing large 2 - 2.5 storey buildings with an industrial appearance, the removal of horse paddocks in the north and central areas of the site, and the construction of residential dwellings within the north and central areas of the site. The residential dwellings would comprise a mix of units which would reflect the design and materials of the surrounding residential area.
3.1.3 Residential development proposals on the site would be landscape led and could include the retention of existing trees on site, where possible, and proposals for new tree and hedgerow planting. Areas within the site could also be excluded from residential development and provide the opportunity for areas of public open space, connection to the Monarch's Way LDFP, and some new tree and hedgerow planting.
3.1.4 There is also an opportunity to upgrade the existing concrete access road on the site and to create a vista towards the backdrop of Wychbury Hill and woodland to enhance the visual relationship between the site and surrounding landscape.
4.0 LANDSCAPE CHARACTER STUDY
4.1. Landscape Context
4.1.1 The landscape baseline is a description and analysis of the existing landscape. The landscape is described, first, by reference to landscape character assessments for the area in which the site is located, at national and local levels, and then, from site-specific surveys and analysis carried out for the purposes of this statement.
National landscape character assessment
4.1.2 The desk study has made reference to National Character Areas for England. National Character Areas (NCAs) divide England into 159 distinct natural areas. Each NCA 'is defined by a unique combination of landscape, biodiversity, geodiversity and cultural and economic activity. Their boundaries follow natural lines in the landscape rather than administrative boundaries, making them a good decision-making framework for the natural environment.'
4.1.3 The site is located within the east of National Character Area 66: Mid Severn Sandstone Plateau see Figure LA.01. The key characteristics which are relevant to the site and study area are identified as:
• Extensive sandstone plateau in the core and east of the NCA underpins an undulating landscape with tree-lined ridges...
• The plateau is drained by the rivers Worfe and Stour and fast-flowing streams in small wooded, steep-sided streamside dells, locally known as dingles.
• Interlocking blocks of mixed woodland... provide a well-wooded landscape and conifer plantations combine with parklands to give an estate character...
• Large, open arable fields with a weak hedgerow pattern on the plateau contrast with mixed arable and pasture land with smaller, irregular shaped fields bounded by hedgerows with hedgerow oaks in the west.
• The Stour and Severn valleys contain frequent villages and there are a number of attractive historic towns...
Local landscape character assessments
Worcestershire County Council Landscape Character Assessment
4.1.4 The most recently published Landscape Character Assessment of relevance to the site is the Worcester Landscape Character Assessment', which was published August 2012. The assessment only covers areas beyond the settlement boundary. The site is located in Landscape Type Estate Farmlands. The key characteristics that are of relevance to the site described below:
Primary:
• Hedgerow boundaries to fields
• Planned woodland character
Secondary:
• Mixed farming land use
• Discrete settlement clusters and small estate villages
• Medium-framed views
Tertiary:
• Semi-regular pattern of medium-to-large fields
• Small geometric plantations and belts of trees
• Large country houses set in mature grounds
• Rolling lowland with occasional steep-sided hills and escarpments
Black Country Historic Landscape Characterisation Study
4.1.5 The Black Country Historic Landscape Characterisation Study was published in 2009 and covers the authorities of Sandwell and Dudley Metropolitan Borough Councils, City of Wolverhampton Council, and Walsall Council. The site is located within Character Area
DY08: Pedmore & Lutley, which covers mostly undeveloped land between Stourbridge and Halesowen up to the boundary of Worcestershire boundary to the south. The modern character is described as:
"A narrow strip of agricultural land, it forms a rural buffer between the towns of Halesowen and Stourbridge... The Character Area is crossed by a number of transport routes... These include the... dual carriageway of the A491. With the exception of post-war housing alongside this route and nearby Ped more Hall, almost all of the settlement in the area is accounted for by farmsteads."
4.2. Site-specific landscape review
4.2.1 The following paragraphs provide descriptions of the site and should be read alongside
Figures LA.03 Site Photographs.
The landscape features, characteristics, and aesthetics of the site

4.2.2 The site is located immediately to the south of Pedmore, a suburb of Stourbridge. It is situated on the lower northwest facing slope of Wychbury Hill, north of Hagley.
4.2.3 The west boundary of the site is defined by Pedmore Hall Lane and the curtilages of the adjacent properties located on the south side of Pedmore Lane. The northwest boundary of the site is defined by Pedmore Lane and the settlement edge of Pedmore and the northeast boundary is defined by Monarch's Way LDFP. The southeast and south boundaries of the site are defined by a small group of trees, the north curtilage boundary of Pedmore Hall, and horse paddock boundaries.
4.2.4 The site is comprised of grassland that has been separated into several horse paddocks by post and wire fencing. In the central area of the site there are large buildings that are currently used as horse stables. The buildings have an industrial appearance constructed from brick with some glazed windows, roller shutters, with pitched roofs and includes a loading bay. To the south of the buildings there is a level concreate area used for vehicle parking. A concrete access road leads from the buildings in a northwest direction to connect to Ped more Lane.
4.2.5 In the west of the site there is a small pond surrounded by mature trees and vegetation. There are also some tree lines along a few of the small historic field boundaries within the site and some individual tree along the northwest boundary of the site.
4.2.6 The topography of the site slopes down in a southeast to northwest direction. The highest point of the site is along the southeast boundary at circa 165m Above Ordinance Datum (AOD). The landform steeply falls in the east of the site before becoming a more gently gradient in the northwest of the site with the lowest point at circa 130m AOD along the northwest boundary.
4.2.7 The northern area of the site is influenced by its residential context alongside Pedmore. There are open views of the properties along the Ped more Lane, which form the backdrop to the site. Within the central area of the site, just above the roofscape of properties along Pedmore Lane, there are distant views to the hills in the northwest which contributes to the sense of openness and suburban context. The existing buildings in the central area of the site have an industrial appearance, although used as stables, and forms a detracting feature and contributes to the suburban context. To the south of the building the combination of built form, existing trees, and the steep slopes of Wychbury Hill provides a sense of enclosure in the south of the site.
Land at Pedmore Hall Farm: Landscape Study
4.2.8 Wychbury Hill to the southeast of the site forms the backdrop to the site with views of the lower grassland slopes and wooded rounded hilltop. The east of the site forms part of the setting to the hill with connected landscape features and characteristics.
The landscape of the surrounding area
4.2.9 The surrounding landscape of the study area contrasts between the suburban in the north•
western half and more rural in the south-eastern half.
4.2.10 Along the northside of Ped more Lane there is a mix of 2-2.5 storey detached houses with detached bungalows. The front curtilages of the properties generally comprise a driveway and a small amenity grass area with small boarders of shrub planting, if any, and no garden boundaries. Adjacent to the northeast and west boundaries of the site are detached 2 storey properties, which are screened from the site by a high Leylandii hedge to the west and a Cherry Laurel Hedge to the northeast, which lines the Monarch's Way LDFP.
4.2.11 The Monarch's Way LDFP provides a direct walking route from Pedmore to the top of Wychbury Hill to the southeast of the site. The route follows the adjacent pasture field boundaries and is lined by trees and vegetation. As the route approaches the top of Wychbury Hill, the route becomes more open and offers long distance views to the northwest. The route passes through a small area of Roundhill Wood before the landscape transitions into open large-scale grassland associated with the south facing slopes of Hagley Hall Registered Park and Garden.
4.2.12 To the south of the site, the landscape is also comprised of pasture with some tree lines along part of the medium sized regular shaped historic field boundaries. As the landscape rises up Wychbury Hill, the fieldscape becomes less distinctive with small groups and individual trees scattered on the steeper slopes. Round hill Wood covers the rounded peaks of Wychbury Hill with smaller blocks of woodland in the surrounding area associated with small watercourse within small valleys.
Public access
4.2.13 There is no public access on the site. Public access surrounding the site and in the wider 1km study area is described in paragraphs 2.2.14 -2.2.16 above.
5.0 VISUAL AMENITY STUDY
5.1. Visual Baseline
5.1.1 The visual baseline review has involved desk study and field survey analysis work to identify and record views of the site from publicly accessible land within the surrounding landscape. Three viewpoints illustrate the site and its appearance in publicly available views, see viewpoint Figures LA.05. Context views were also taken to show views of the site from within the surrounding landscape, see Figures LA.04. The location of each viewpoint and context view are shown on Figure LA. 01.
5.1.2 Views towards the site are contained to within 0.5km of the site boundary to the south and east due to the topography and woodland blocks screening views towards the site. To the north and west of the site, views towards the site are restricted to locations in close proximity due to the surrounding residential development screening views.
5.2. Visual Receptors
5.2.1 The review of potential visual effects is described by considering how the different groups of "visual receptors" may be affected. The following is a review of the viewers (the visual receptors) and the views available to them at the selected representative locations:
People in settlements and residential properties
5.2.2 Viewpoint 01 illustrates views towards the site for nearby residents along Pedmore Lane.
Residents immediately opposite the site are likely to have open views into the site, although some views may be partially screened by individual trees along the site boundary. Existing views of the site include the concrete access track with horse paddocks either side. There are views of the existing 2-2.5 storey buildings that have an industrial appearance comprised of brick facades with some glazed windows, loading bay, roller shutters, and pitched roofs. To the right of the buildings, mature trees form the backdrop to part of the view and screen views towards Pedmore Hall. Above the industrial buildings, the wooded rounded hill of Wychbury forms the backdrop with some views of its lower grassed slopes.
5.2.3 As distance increases from the site along Pedmore Lane, views towards the site for nearby residents are likely to be more oblique and screened. Viewpoint 03 illustrates that views of the site are limited to the most northern part of the site, alongside Pedmore Lane.
5.2.4 It is likely that residents immediately opposite the site would have open views of the potential development proposals within the site. However, as distance increases from the site, views of any development proposals are likely to become more restricted due to the screening effect of surrounding residential properties, trees and vegetation.
5.2.5 For residents immediately to the west of the site and on the south side of Pedmore Lane, it is unlikely that there would be views of the site or potential development proposals within the site due to the high leylandii hedge that lines the east curtilage of the property, refer to viewpoint 03.
5.2.6 To the southwest of the site, it is unlikely that residents along Ped more Hall Lane would have views of the site or potential development proposals within the site due to the dense trees and vegetation that line the road that screen and restrict views towards the site.
5.2.7 To the southeast of the site trees and vegetation line the curtilage of Pedmore Hall. Any views of the site and potential development proposals for residents are likely to be restricted to filtered and partial views between any gaps in the surrounding vegetation.
5.2.8 Beyond the immediate vicinity of the site, it is unlikely that residents would have views of the site or any potential development proposals on the site due to the screening effect of existing residential development, dense trees and vegetation.
Users of public rights of way
5.2.9 Viewpoint 02 illustrates the view for users of Monarch's Way LDFP immediately to the northeast of the site. It shows there are open views of the site from a short section of the route adjacent to the site. However, as the route heads eastwards, views towards the site become more restricted in places by trees and vegetation that line the boundary of the site.
Existing views comprise of horse paddocks bounded by post and wire fencing, which are backdropped by mature trees that screen views further to the west. There are also views of the existing buildings to the southeast, which screen further to the southeast.
5.2.10 Site photograph 03 illustrates the view of the site from a field gateway along the LDFP to the north of the existing buildings.
5.2.11 Context view 01 illustrates the existing view of the site for users of the LDFP. The existing view comprises of sloping grassland with individual mature trees and groups screening views of the northern part of the site. There are roofscape views of the existing buildings on site, which is viewed in context to the roofscape views of Pedmore. To the southwest, there are also partial views of Pedmore Hall. Potential residential development would be excluded from the east of the site. any views of the potential residential development are likely to be restricted to roofscape views between gaps in the existing/ proposed trees and vegetation, which would be viewed in context to the residential roofscape of Pedmore.
5.2.12 To the east, as the LDFP climbs further up Wychbury Hill, views towards the site and any potential development proposals on the site for users of the LDFP would become more restricted and limited due to the screening effect of the surrounding topography and mature trees, see Context view 02.
5.2.13 From the other surrounding public footpaths within the study area, it is unlikely that users of the routes would have views of the site or the potential development proposals within the site.
5.2.14 Viewpoints 01 and 03 illustrate the view towards the site for users of the pavement along Pedmore Lane, refer to paragraphs 5.2.2 and 5.2.3 above.
Road users
5.2.15 Views of the site for road users are limited to locations along Ped more Lane, see viewpoints 01 and 03, due to the screening effects of surrounding built development and trees and vegetation. Any views of the potential development proposals would be short in duration and oblique or partially screened, which would be viewed in context to the surrounding residential area along Pedmore Lane.
6.0 GREEN BELT STUDY
6.1. The site's contribution to the purposes of the green belt
6.1.1 As stated above in the Green Belt Policy section, NPPF identifies five purposes that Green Belt serves, which are: to check the unrestricted sprawl of large built-up areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; to preserve the setting and special character of historic towns; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Relevant Green Belt purposes are discussed below in relation to the landscape and visual studies.
To check unrestricted sprawl of large built-up areas
6.1.2 The Black Country Green Belt Study assessed parcel B65 as providing a strong contribution to this Green Belt purpose as it "contains no significant urban development, and has strong openness. It retains a relatively strong relationship with the wider countryside." However, the site contains large buildings with an industrial appearance, which contributes to the sense of enclosure on some parts of the site and forms a detracting feature that is not typical of the surrounding area. Whilst the east of the site has a strong relationship with Wychbury Hill and its lower slopes, the north and west part of the site is influenced by the residential context of Pedmore and associated road sound from Pedmore Lane.
6.1.3 The site is located immediately to the south of Pedmore and immediately to the west and east of residential dwellings located on the south side of Ped more Lane. Some areas of the site would be exempt from built development, with potential residential development mainly contained within the north of the site and on areas that are currently occupied by large buildings with an industrial appearance.
6.1.4 The surrounding topography also contributes to the containment of the site and is a key constraint in the east of the site. It is therefore considered that potential development on the site would not contribute to the unrestricted sprawl of large built-up areas.
To prevent neighbouring towns merging into one another
6.1.5 The Black Country Green Belt Study assesses parcel B65 as having a moderate contribution to the Green Belt purpose as the "Land contributes to separation between Stourbridge and Halesowen..."

6.1.6 The site is located immediately to the south of Pedmore. The next nearest built-up area is Hagley, which is located circa 820m to the south of the site. At its nearest point, Halesowen is located circa 2.65km to the east of the site.
6.1. 7 Potential development would occupy a small area of contained land immediately to the south of Pedmore. Due to the distance of the site between the two nearest settlement areas and the small area of land that the potential development would occupy, it is considered that potential development on the site would not result in two neighbouring towns merging into one another.
To assist in safeguarding the countryside from encroachment
6.1.8 The Black Country Green Belt Study assessed parcel B65 as providing a strong contribution to this Green Belt purpose as the "Land contains the characteristics of open countryside and does not have a stronger relationship with the urban area than with the wider countryside." However, the site occupies a much smaller area within the wider B65 parcel, which includes areas that have different characteristics to the site.
6.1.9 The existing site functions as equine grazing with the site broken up into paddocks by post and wire fencing. Existing 2-2.5 storey building with an industrial appearance also occupy the site. To accommodate any potential development on the site, the paddocks would be cleared, and the existing industrial looking buildings and structures would be demolished. The landscape led approach to the potential development on the site would seek to retained trees and vegetation, where possible, within the site. Some areas of the site would also be excluded from any potential residential development, particularly in the east of the site where the landscape design would seek to retain the landscape character and visual relationship with Wychbury Hill and its lower slopes.
6.1.10 Although the site is located within the countryside i.e., it is located outside of the settlement boundary, Pedmore to the north influences the character and aesthetics of the site. The site covers a small and contained area that is partially occupied by large buildings with an industrial appearance. Proposals for the site would seek to maintain its relationship with the surrounding countryside, particularly with Wychbury Hill and its lower slopes, and to provide opportunities to enhance key landscape characteristics of the surrounding area.
To preserve the setting and special character of historic towns
6.1.11 The site is not located in, or within the setting of a historic town and therefore does not contribute to this purpose of the Green Belt, which was also concluded in the Black Country Green Belt Study. Potential residential development within the site would therefore have no effect on this Green Belt purpose.
To assist in urban regeneration, by encouraging the recycling of derelict and other urban land
6.1.12 The Black Country Green Belt Study assessed all parcels of land as providing a strong and equal contribution to this Green Belt purpose.
6.1.13 Part of the site is occupied by large buildings with an industrial appearance and associated concrete access road. Development proposals on the site would include the demolition of the existing buildings on the site to accommodate potential new residential development. There would also be opportunities to upgrade the existing concrete access route on site to provide residential access.
6.1.14 The potential residential development proposals are considered to make a contribution to this Green Belt purpose as part of the site would be re-developed, demolishing large industrial looking buildings to accommodate the potential new residential development.
7.0 SUMMARY AND CONCLUSIONS
7.1. Scope
7.1.1 This Landscape Study has been prepared in relation to the promotion of housing on the site at Pedmore Hall Farm. The site is also located within the West Midlands Green Belt in Dudley. National Planning Policy Framework (NPPF) requires that "Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans."8
7.1.2 The study has reviewed the likely effects on the landscape character and visual amenity within a 1km study area should the site be developed for residential use. At this early stage, there is no detailed masterplan for the site, but the design of the site would be landscape led. It is assumed that trees and vegetation would be retained, where possible, and some areas of the site would be exempt from built development.
7.1.3 The methodology used for reviewing the landscape character and visual amenity were broadly based on the recommendations in GLIVA319. The application of the guidance document established an appropriate scope for this review to be undertaken.
7.1.4 This study has also considered the site and the promotion of housing in relation to fundamental aim of the Green Belt and its five purposes as defined in NPPF paragraph 138.
7.2. Summary of Findings
7.2.1 The Black Country Landscape Sensitivity Assessment provided an assessment in relation to areas being developed for housing and commercial development on land within the Green Belt. The site is located in a small part of parcel BL 16, which was assessed as having a high sensitivity to residential development "due to the distinctive landform, historic features, settlement setting and visual character of the area."?
7.2.2 Parcel BL 16 covers a wider area of 76.2 hectares, where as the site only covers circa 5.45 hectares. The site is contained alongside Pedmore Lane and contains some varying features and characteristics to the wider parcel, which is set out below.
7.2.3 The landscape character review, specific to the site, considers the potential impact on landscape receptors should the site be promoted for residential development.
7.2.4 Desk studies reviewed landscape designations, public access, and referred to national, regional, and local landscape character assessments. The studies confirmed that the site is not located in a statutory or non-statutory designated landscapes and does not contain any important historic features. The site is also located adjacent to the Monarch's Way Long Distance Footpath (LDFP).
7.2.5 In relation to the national, regional, and local landscape character assessments, key characteristics of the site and surrounding landscape include the undulating landscape with a planned woodland character, medium sized pasture fields with large country houses set within mature grounds.

7.2.6 The site-specific landscape review confirmed the site's location on the edge of suburban residential development, immediately south of Pedmore. The site is comprised of grassland that has been separated into several horse paddocks with large buildings that have an industrial appearance. The sloping site also contains some mature trees and vegetation on the few historic field boundaries.
7.2.7 The northern area of the site is influenced by its residential context alongside Pedmore. Some parts of the site have a sense of openness with distant views to the northwest above the roofscape along Ped more Lane, but areas in the south of the site have a sense of enclosure due to the combination of built form and existing trees on site, and the steep slopes of Wychbury Hill to the southeast. Wychbury Hill forms the backdrop to the site with east of the site forming part of the setting to the hill with connected landscape features and characteristics.
7.2.8 The landscape led approach to the potential development of the site would seek to retain existing trees on site, where possible, and could and enhance the green infrastructure on the through the planting of new trees and hedgerows that could reflect the former historic field boundaries and parkland setting of Wychbury Hill. The east part of the site could be excluded from residential development, preserving the setting of Wychbury Hill.
7.2.9 Proposals for the site would provide the opportunity to demolish the existing buildings on the site that have an industrial appearance and form a detracting feature that is uncharacteristic of the wider area.
7.2.10 Residential development within the site would reflect the residential context of Ped more with opportunities to reflect the existing front curtilages along Pedmore Lane and mixed architectural styles of suburban character.
7.2.11 The visual relationship with Wychbury Hill would also need to be considered. There could be opportunities to design a vista from Pedmore Lane towards the hill, enhancing the backdrop and setting to the site, whilst maintain a sense of openness.
7.2.12 Overall, it is considered that potential residential development on the site could retain some key features and characteristics of the site without detrimentally harming the wider landscape character of the area. There could also be some opportunities to enhance characteristics and connections to the wider landscape.
Visual amenity review
7.2.13 To confirm the baseline studies of designations, public access, and landscape character mapping, and site visit, a total of 3no. viewpoints were photographed for the visual review, which represent key receptors including residents, users of the Monarch's Way LDFP, and users of nearby local roads. All the viewpoints were taken from locations within circa 75m of the site due to the visual containment of the site by the existing topography, built form, and trees and vegetation.
7.2.14 The visual review concluded that residents opposite the site are likely to have open views of the development proposals. Existing views of equine pasture and large buildings with an industrial appearance would change to the residential development proposals backdropped by Wychbury Hill. However, as distance increases from the site, views of the potential development proposals are likely to become more oblique and screened.
7.2.15 Users of Monarch's Way LDFP adjacent to the site are likely to have open views of the potential development proposals, but as distance increases from the site and as the elevation of the route increases up Wychbury Hill, any views of the development proposals are likely to become limited to roofscape views between gaps in trees and vegetation, which would be viewed in context to the roofscape of Ped more.
7.2.16 For road users of Pedmore Lane, views of the potential development proposals would be short in duration and viewed in context to the residential development of Pedmore. Some views are likely to be partially screened by retained or proposed trees and vegetation.
7.2.17 Overall, the potential visual envelope of development proposals on the site would be contained due to the screening effects of the surrounding topography, existing built form and trees and vegetation. Existing views of equine grazing with large buildings of an industrial appearance, that form a detracting feature in views, would be replaced by new residential development.
7.2.18 The landscape led approach to the layout of the site would seek to minimise and mitigate the potential visual impact for nearby sensitive receptors by considering the layout and pattern of development, retaining existing trees where possible, and planting of new trees, hedgerows, and shrub planting to partially screen and filter views.
Green Belt review
7.2.19 The Black Country Green Belt Study provided assessments for parcel of land located in Green
Belt and their contribution to the 5 Green Belt purposes as set out in NPPF. The site is located in a small and contained part of parcel B65, which was assessed has having a strong contribution to purpose 1: to check unrestricted sprawl of large built up areas; purpose 3: to assist in safeguarding the countryside from encroachment; and purpose 5: to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Purpose 2: to prevent neighbouring towns merging into one another was assessed as having a moderate contribution, and purpose 4: to preserve the setting and special character of historic towns was concluded that the parcel does not contribute to this purpose as it not located in or within the setting of an historic town.
7.2.20 The Green Belt review confirmed that the site does not contribute to Green Belt purpose 4: to preserve the setting and special character of historic towns. It also considered that potential development on the site would not result in neighbouring towns from merging into one another as the site is contained and the next nearest settlement area from the site is circa 820m to the south at Hagley. Green Belt purpose 2 would therefore not be affected.
7.2.21 In relation to purpose 1: to check unrestricted sprawl of large built-up areas and purpose 3: to assist in safeguarding the countryside from encroachment, it is considered that should the site be released for residential development, these purposes would not be detrimentally affected. The site is contained, located immediately to the south of Pedmore with the topography of Wychbury Hill to the southeast forming a significant constraint and a constraint in the east of the site. The potential development on the site would be confined to the north of the site and on areas that are currently occupied by large buildings of industrial appearance. The landscape led approach to the development of the site could seek to maintain its relationship with the surrounding countryside and to provide opportunities to enhance key landscape characteristics of the surrounding area.
7.2.22 In relation to Green Belt purpose 5: to assist in urban regeneration, by encouraging the recycling of derelict and other land, the potential residential development proposals are considered to make a contribution to this Green Belt purpose as part of the site would be re• developed, demolishing large industrial looking buildings to accommodate the potential new residential development.
7.2.23 Overall, it is considered that the site provides a weaker contribution to the Green Belt purposes 1-3 compared to the wider B65 parcel as identified in the Black Country Green Belt Study. The site comprises different features and characteristics compared to the wider B65 parcel, including the existing 2-2.5 buildings that have an industrial appearance and form a detracting feature.
Conclusion
7.2.24 This Landscape Study concludes that the site represents an opportunity to release the site from Green Belt for potential residential development. The study reviewed the potential effects on landscape character and visual amenity, which concluded that there is an opportunity to enhance the landscape character with the removal of large buildings that occupy the site, which have an industrial appearance and form a detracting feature of the surrounding area. Future development could take a landscape led approach which could seek to retain key landscape features on the site such as trees and vegetation along some historic fields boundaries, and the character and visual relationship with Wychbury Hill. The proposals would also seek to reflect and maintain the residential context of Pedmore.
7.2.25 The potential visual envelope of the proposed development is likely to be contained to within close proximity to the site due to the screening effect of the surrounding built form, topography, and existing trees and vegetation.
7.2.26 In relation to the Green Belt and the 5 purposes as set out in NPPF, it is considered that site provides a weaker contribution to Green Belt purposes 1-3 than assessed in the Black Country Green Belt Study. The site is contained alongside Pedmore and would contribute to purpose by re-developing and reusing part of the site that contains existing built form.

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