Draft Black Country Plan

Comment

Representation ID: 23193

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

5.1. It is clear that the overwhelming housing need in the Black Country has resulted in the need to ensure the best use of land, but it is our opinion that the housing numbers proposed on a number of the allocated sites are unrealistic even considering the discounts applied to these sites as described in the justification to Policy HOU1.

Comment

Representation ID: 23194

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

5.2. Whilst the general principles behind the requirements of Policy HOU2 are supported, to ensure that appropriate housing densities are delivered in sustainable locations we are concerned that the densities proposed on a number of the proposed allocations have failed to consider the individual circumstances of each site. Rather a density of 45 or 35 net dwellings per hectare (dph) has been applied without proper consideration of the site constraints and as such, the number of homes to be delivered across the proposed allocations will not be as great in reality as the capacities indicated in the plan.

5.3. It is clear that as a consequence of the critical delivery and capacity issues facing the Black Country there is a need to consider all options, including increasing housing densities across the plan area. In all likelihood however, on the majority of allocated sites which are on the edges of the urban area, a substantial increase in density is unlikely to be achievable based on individual site characteristics, constraints and market demand for family housing

Comment

Representation ID: 23195

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

5.4. The Black Country Urban Capacity Review Update (May 2021) when assessing the potential to increase densities across the area acknowledges that character constraints such as listed buildings, conservation areas and existing local character/density reduces typical density to around 15-25 dph. The following table highlights some of the areas of concern in respect of the proposed densities which are likely to reduce the level of actual housing delivery on a number of the proposed allocations:

Table 1: Density and known constraints

[Headings:] Policy (SA Reference) / Proposed Density (dph) / Known Constraints

WSA1 (SA-/At least 35/SLINC, surrounding low density character, retention of exisitng buildings, site originally proposed at 15 dph.
0022-WAL)//
WSA2 (SA-/At least 35/

character.
0048-WAL)//
WSA3 (SA-/At least 35/Surrounding low density character.
0034-WAL)//
WSA4 (SA-/At least 35/Listed Buildings on site, SLINC, surrounding low density character.
0014-WAL)//
WSA5 (SA-/At least 35 and Site Assessment identifies 45/surrounding low density character.
0030-WAL)//
WSA6 (SA-/At least 35/SLINC (whole of the site), existing field patterns, surrounding low density character.
0012-WAL)//
WSA7 (SA-/At least 35//landscape/sensitivity,
0078-WAL)//Arboretum impacts//
WSA8 (SA-/At least 35 and Site Assessment identifies 45/Conservation Area, Listed Buildings, visual prominence and topography.
0017-WAL)//


5.5 located sites were to reduce by even 5 dwellings per hectare this would see an overall reduction in numbers across the allocations of over 800 dwellings. This further adds to the need for additional sites to be allocated for development in the plan.
6. Wider spatial planning for the Greater Birmingham and Black
Country Housing Market Area;


6.1. When considering the t is important to highlight that the Green Belt is a spatial planning land typology of and not a landscape designation. To that end it is important to consider the proposed allocations in the plan spatially in relation to the wider housing market area (HMA) and not just where they are bound by the administrative area of the plan.


6.2. Spatially it is clear that the delivery of new Green Belt sites is heavily weighted to Walsall.

However, the Site Assessments for a number of the proposed allocations located on the on the edge of the plan area have failed to fully consider their wider spatial and landscape impacts. Indeed, a number do not appear to have been appropriately considered in relation to the settlements beyond the Black Country boundary or their landscape impact beyond the Black Country boundary. Rather, they have been allocated based on historic administrative boundaries. This plan represents the opportunity to develop sites which can be developed more comprehensively, which would represent proper spatial planning

6.3. To this end, it is our opinion that appropriate sites that can be sustainably planned as a whole within the plan area, rather than relying on development in neighbouring authorities should be given greater weight than appears to be the case in the plan. This is certainly the case for the Bloor site, which follows the settlement pattern of the area and can be wholly planned and defined within the Black Country area.

Comment

Representation ID: 23196

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

6.4. When considering the somewhat questionable location and boundaries to sites on the edge of the plan area such as the proposed allocations under policies WAS4, WSA1, CSA1 and CSA2, the plan and its policies do little to consider the wider spatial or landscape impacts of developing these sites and appear to reduce the weight given to high (and moderate-high) levels of Green Belt and landscape harm in these areas favoring its central area.

6.5. The plan identifies the development of a network of Neighbourhood Growth Areas are proposed to be released from the Green Belt in sustainable locations. However, given the identified infrastructure requirements on each of these sites (noting that no fewer than 7 new Health Centres
are required by the allocating policies) it is our submission that these areas should be planned more holistically to ensure that wider benefits ensue from these allocations and that the delivery of the necessary infrastructure is actually viable and will be delivered where there is a proven need. To this end the term NGA, which is, by any other name, a housing allocation should be widened to provide for coordinated growth in areas where there is an identified need (or deficiency) of services and sites allocated in order to provide for both the much needed new homes but also new services and facilities.

Comment

Representation ID: 23197

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

6.4. When considering the somewhat questionable location and boundaries to sites on the edge of the plan area such as the proposed allocations under policies WAS4, WSA1, CSA1 and CSA2, the plan and its policies do little to consider the wider spatial or landscape impacts of developing these sites and appear to reduce the weight given to high (and moderate-high) levels of Green Belt and landscape harm in these areas favoring its central area.

6.5. The plan identifies the development of a network of Neighbourhood Growth Areas are proposed to be released from the Green Belt in sustainable locations. However, given the identified infrastructure requirements on each of these sites (noting that no fewer than 7 new Health Centres
are required by the allocating policies) it is our submission that these areas should be planned more holistically to ensure that wider benefits ensue from these allocations and that the delivery of the necessary infrastructure is actually viable and will be delivered where there is a proven need. To this end the term NGA, which is, by any other name, a housing allocation should be widened to provide for coordinated growth in areas where there is an identified need (or deficiency) of services and sites allocated in order to provide for both the much needed new homes but also new services and facilities.

Comment

Representation ID: 23198

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

6.4. When considering the somewhat questionable location and boundaries to sites on the edge of the plan area such as the proposed allocations under policies WAS4, WSA1, CSA1 and CSA2, the plan and its policies do little to consider the wider spatial or landscape impacts of developing these sites and appear to reduce the weight given to high (and moderate-high) levels of Green Belt and landscape harm in these areas favoring its central area.

6.5. The plan identifies the development of a network of Neighbourhood Growth Areas are proposed to be released from the Green Belt in sustainable locations. However, given the identified infrastructure requirements on each of these sites (noting that no fewer than 7 new Health Centres
are required by the allocating policies) it is our submission that these areas should be planned more holistically to ensure that wider benefits ensue from these allocations and that the delivery of the necessary infrastructure is actually viable and will be delivered where there is a proven need. To this end the term NGA, which is, by any other name, a housing allocation should be widened to provide for coordinated growth in areas where there is an identified need (or deficiency) of services and sites allocated in order to provide for both the much needed new homes but also new services and facilities.

Comment

Representation ID: 23199

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

6.4. When considering the somewhat questionable location and boundaries to sites on the edge of the plan area such as the proposed allocations under policies WAS4, WSA1, CSA1 and CSA2, the plan and its policies do little to consider the wider spatial or landscape impacts of developing these sites and appear to reduce the weight given to high (and moderate-high) levels of Green Belt and landscape harm in these areas favoring its central area.

6.5. The plan identifies the development of a network of Neighbourhood Growth Areas are proposed to be released from the Green Belt in sustainable locations. However, given the identified infrastructure requirements on each of these sites (noting that no fewer than 7 new Health Centres
are required by the allocating policies) it is our submission that these areas should be planned more holistically to ensure that wider benefits ensue from these allocations and that the delivery of the necessary infrastructure is actually viable and will be delivered where there is a proven need. To this end the term NGA, which is, by any other name, a housing allocation should be widened to provide for coordinated growth in areas where there is an identified need (or deficiency) of services and sites allocated in order to provide for both the much needed new homes but also new services and facilities.

Comment

Representation ID: 23200

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

7.1. The Site Assessment Report: Assessment and Selection Methodology and Results (August 2021) (SAR) paper is part of the evidence base which informs the plan. It draws including the
Sustainability Appraisal of the Black Country Plan (Lepus Consulting June 2021 and

July 2021 versions). It is by consequence the main document which appears to have


justification for its spatial strategy.



7.2. The assessment undertaken is a multi-stage one. In simple terms, sites which progressed removed were then subject to more detailed site assessment against a range of criteria grouped under the headings: Green Belt and landscape sensitivity; Environmental; , amber, and
The Bloor site passed the initial filter stages and is not . For the avoidance of doubt, a red score is negative and green positive. It is not clear from the assessments or the published methodology what weight is given to each of the scoring criteria. The following section considers the Bloor site alongside a number of the proposed allocations under each of the wider headings.


Green Belt and landscape sensitivity


7.3. This element of the assessment is based on the Black Country Landscape Sensitivity

Assessment (LUC September 2019) and the Black Country Green Belt Study - Stage 2

Report (LUC September 2019). The SAR identifies that sites considered in the assessment as being likely to cause very high harm to the remaining Green Belt and where landscape sensitivity is likely to be moderate-high or high, have been considered




7.4. The Bloor site scores very high in terms of its Green Belt harm and moderate-high in terms of its landscape sensitivity and it is assumed that this is the main reason for it
.
7.5. In comparison, it is noteworthy and a cause of significant concern that a number of allocated sites score the same in terms of harm against these same criteria as the Bloor site (see Table 2 below) begging obvious questions around the fairness and robustness of the Site Assessment process especially in the context of such a significant housing shortfall. The SAR does go on to state that the Green Belt and Landscape assessments were based on larger parcels of land, and where the Council consider that a smaller site is judged to result in a lower level of harm, the level of harm has been downgraded as per the commentary in the table below.

7.6. It is our opinion that the landscape sensitivity rating for the Bloor site has incorrectly

- from the wider parcel, where the site itself

shoul Architects landscape evidence. These detailed assessments consider that the site as originally proposed (circa 700 dwellings) would not result in residual landscape effects beyond moderate significance, which is also the case for the reduced site. The Council has erred in not judging this site separately from the wider landscape parcel, as they have with a number of the proposed allocations as detailed in the table below. As our evidence shows if the Bloor site had been considered separately from the wider parcel the site would score better in the assessment of landscape sensitivity than a number of allocated sites and should have been considered suitable for development and allocated accordingly.

Table 2: Green Belt Harm and Landscape Sensitivity

Table 2: Green Belt Harm and Landscape Sensitivity

[Headings:] Policy (SA Reference) / Green Belt Harm / Landscape Sensitivity / Corrected Landscape Sensitivity Score / Comments

Stencils Farm/Very High/Moderate -/Moderate/The detailed comments
(SA-0066-WAL)//High//repeat the comments of the wider parcel assessment with no specific comments on the site itself.
Land north of/Very High/Moderate -/Moderate - High/Considered to have a high
Stonnall Road,//High//sensitivity based on its
Aldridge WSA3////topography (in places) and

(SA-0034-WAL)////its strongly rural and
////undeveloped character.
/////Overall conclusion
/////considered the site to have

limited visual impact due to
/////surrounding uses and
/////topography.
Calderfields/Very High/Moderate/-/Moderate - High/The comments note that
West WSA7//High///the site may have to be
(SA-0078-WAL)/////reduced to minimise impact
on the Green Belt and landscape sensitivity. No
/////explicit mention of this
/////within the allocating policy.
Land between/Very High/Moderate/-/Moderate - High/The fact that the assessed
Doe Bank Lane//High///parcel is larger than the
and Aldridge/////proposed site is noted as is
Road WSA8/////mention of the edge to
(SA-0017-WAL)/////Pheasey being more open

and forming a hard edge
/////which is considered to
/////reduce the landscape
/////sensitivity to less than
/////moderate-high or high.

Comments on the proposed allocations detailed above


7.7. WSA3 Land north of Stonnall Road, Aldridge: In terms of Policy WSA3 (Land north of Stonnall Road, Aldridge) the assessment appears to miss the conclusion to the Landscape Sensitivity Judgement. That is, the land to the north of the golf course (which includes the site) is considered to have a slightly higher (than moderate-high) sensitivity to residential development, and views of the site are considered to have sensitivity to development by virtue of the open views of the site. This assessment runs contrary to the conclusion of the SAR which considers the site to have limited visual impact due to surrounding uses and topography.


7.8. WSA7 Calderfields West: In reaching a judgement on the allocated site directly to the south of the Bloor site, WSA7 (Calderfields West), rather than disagree with the level of harm in the assessment, the SAR merely identifies the fact that the site area may need to be reduced. It does not appear that the same level of flexibility has been given to the Bloor site in undertaking these assessments, and we are happy to consider suggestions
by the Council which appear to have been missed for our site but forthcoming on a number of allocations including WSA7 which is immediately adjacent to the Bloor site with the same landscape and Green Belt harms ratings. In simple terms, if the landscape and Green Belt harm ratings are the same for this site which is adjacent to the Bloor site, and there are no other gateway constraints identified by the council, then there is no objective or evidence based reason to not allocate the Bloor site.

7.9. WSA8 Land between Doe Bank Lane and Aldridge Road: The assessment for site WSA8 (Land between Doe Bank Lane and Aldridge Road) is considered to underplay both the local and wider sensitivity of developing the site. The small-scale fields to the southeast between Doe Bank Lane and Birdle Lane are considered to have a higher sensitivity to development as detailed within the Landscape Sensitivity Assessment, with the Great Barr Conservation Area and Grade II Listed Buildings also identified as having higher sensitivity to development. The site contributes to the rural gap between these settlements. Large scale development would disrupt the small-scale field pattern, particularly to the east of Doe Bank Lane, which provides a rural and open backdrop to Streetly and Pheasey.

7.10. Instead, the SAR appears to concentrate on a small comment on the Landscape Sensitivity Assessment which is that the settlement edge of Pheasey becomes more open, forming a hard edge. This comment is not considered to relate to the draft allocated site, it is more a comment on the existing development on the western side of Doe Bank Lane. In terms of Green Belt harm the assessment is accepted that is, the development of the site would result in a very high level of harm and the site currently preserves the separation of Streetly and Pheasey as set out in the assessment which would be entirely lost by the development of the site. Correct consideration of the Landscape Sensitivity Assessment undertaken would not see the site proposed for allocation.
Environmental


7.11. The environmental assessments undertaken are generally accepted in relation to Stencils Farm (the Bloor site), but it is necessary to highlight what appears to be a contradictory statement made in relation to the impacts on visual amenity (which includes impact on adjacent land users and local character) insofar as this assessment comments West. The limited leisure uses to the South contribute to a rural character which would be lost if the site was developed. Limited impact on nearby residential outlook due to the orientation of houses. For these reasons there would be a significant local impact, due to the topography and surrounding development there would be a limited wider impact. This conclusion is welcomed as a site-specific assessment rather than the wider landscape harm identified when a larger parcel of land was assessed under the Landscape Sensitivity and Green Belt assessments. Nevertheless, the site scored red in this assessment which would appear to be an incorrect score based on the observations made in the assessment. This view is further evidenced in the Paul Gray Landscape Architects landscape evidence appended to this submission.


7.12. A number of the proposed allocations also score red in this assessment namely WSA2, WSA4 and WSA5. The table below considers the Bloor site against sites proposed for allocation which also score red in the assessment and proposed allocation WSA8 which scores amber. However, in our opinion, WSA8 should score red due to the significant local impacts identified. In addition, we disagree than the wider impacts would be reduced to such an extent that it performs better than the Bloor site in this element of the assessment.

Table 3: Impact on Visual Amenity

[Headings:] Policy (SA Reference)/Impact on Visual Amenity/RAG Score/Corrected RAG Score/Assessment Comments

Stencils Farm///Large open site prominent from
(SA-0066-WAL)///Aldridge Road and Open Space to the

North West. The limited leisure uses to
///the South contribute to a rural
///character which would be lost if the site was developed. Limited impact on
///nearby residential outlook due to the
///orientation of houses. For these
///reasons there would be a significant local impact. due to the topography and surrounding development there would be a limited wider impact.
Land at Vicarage Road, High Heath WSA2 (SA-0048- WAL)///Significant impact on visual amenities

from existing dwellings and users of
///PROW. Existing semi-rural character
///lost. Location close to existing
///development and favourable
///topography limits wider harm
Yeildsfield Farm///Strong local impacts by residents and
WSA4 (SA-0014-///users of the highway. Landscape
WAL)///design could mitigate this impact. The
site would be seen some distance away on Stafford Road. Semi-rural
///landscape lost and the visual
///separation between Bloxwich and
///Great Wyrley reduced. On balance mitigation can be achieved though sensitive design and mitigation.
Land at Yorks///The canal is a barrier between Pelsall
Bridge WSA5///and the rural character, any
(SA-0030-WAL)///development beyond the canal will have a significant detrimental impact on the visual amenities of the canal and local occupiers. Flat topography results in a moderate wider impact.
Land between///Significant local impact from residents

who face the site (on three of four sides). The site is level with Queslett Road and it is considered that this impact would reduce any wider visual impact.
Doe Bank Lane///
and Aldridge///
Road///

7.13. The assessments in the main identify significant local harm, and whilst the weighting in the final scoring of sites from this part of the assessment is unclear, it remains in our opinion that the Bloor site performs much better in this assessment that a number of the proposed allocations.


Economic



7.14. The main area of concern within the Economic section of the SAR relates to the inconsistency with which the Highway a




7.15. More specifically, the individual site assessments identify that 7 of the proposed allocations have not been appropriately assessed for their impacts on the wider highway network which raises concerns as to their deliverability. In addition, the consistency with which these constraints are identified within the assessments vary in terms of their RAG score, specifically relating to the impact on the wider road network. The RAG scoring for Highway Access and Transportation relates to the following: Red = Access constraints
/ severe highway safety impact which cannot be viably overcome; Amber = Access constraints / highway safety impact which can be viably overcome; Green = No / negligible access constraint. The table below highlights a number of anomalies / questionable scoring.

Table 4: Impact on the wider road network corrected RAG scoring

[Headings:] Policy (SA Reference)/RAG Score/Corrected RAG Score/Comments

Stencils Farm

(SA-0066-WAL)///Impact assessment of highway

capacity required.
Home Farm, Sandhills WSA1 (SA-0022-WAL)///No assessment of the capacity

of Chester and Lichfield Road undertaken.
Land north of Stonnall Road, Aldridge WSA3 (SA-0034-WAL)///Highway impact assessment

required to fully assess what infrastructure works required.


7.16. When considering the proposed corrections in the RAG scoring it is important to highlight the scoring from comparable allocations where similar identified constraints score amber rather than green as tabulated in table 5 below:

Table 5: Impact on the wider road network appropriate RAG scoring

[Headings:] Policy (SA Reference/RAG Score/Comments

Land at Vicarage//Likely significant wider impacts
Road, High Heath//identified and a requirement for a
WSA2 (SA-0048-//traffic impact assessment identified.
WAL)//
Land at Yorks//A highway impact assessment is

required.
Bridge WSA5 (SA-

0030-WAL)//
Land off Sutton//Could be wider impacts which may

need to be assessed
Road WSA6 (SA-

0012-WAL)//
Calderfields West//Housing numbers proposed are likely
WSA7 (SA-0078-//to require a Highways Impact
WAL)//Assessment.
Land between Doe//Surveys would be required to assess

impacts.
Bank Lane and//
Aldridge Road//
WSA8 (SA-0017-//
WAL)//

7.17. It is unclear how proposed allocation WSA2 with its red score i.e. there is a very substantial negative effect that is unlikely to be capable of mitigation in terms of its impact on the wider road network has been allocated for development without certainly that the network can accommodate the development.


7.18. Stencils Farm (the Bloor site), scored red in the same assessment with a simple comment that an impact assessment of highway capacity is required. This is even when a site accessed from the same road (Aldridge Road) proposed as an allocation (WSA7) scores amber. This is clearly an error that requires correcting and removes another of

Social



7.19. The scoring in this respect is generally accepted. However, there appears to be an error in the scoring for all sites albeit the comments clarify the scoring. The methodology for access time, which details the times identified will be walking times for access to primary schools only with other times being public transport times. As such the site should only score red for the walking times to a primary school (noting that a primary school is proposed on the site which would overcome this minor shortcoming of the site) and not for access to a GP/Health Centre/Walk in or Centre/Foodstore.


Conclusion on the Site Assessments



7.20. Having regard to these significant assessment anomalies it is asserted that the site should not have been discounted for housing development. With corrected assessment scores as detailed above the site scores at least as well if not better than the sites proposed for allocation under policies WSA3, WSA7 and WSA8 in terms of landscape sensitivity, better than proposed allocations under policies WSA2, WSA4, WSA5 and WSA8 in terms of visual amenity, and better than proposed allocation WSA2 and equal to WSA1, WSA3, WSA5, WSA6, WSA7 and WSA8 in terms of impact on the highway network. Proper consideration of the Bloor site within the Site Assessments would see the site allocated, which raises serious questions about the robustness and fairness of

8. Conclusion and case for allocation of the site.



8.1. The inability for the existing urban areas of the Black Country to accommodate the housing need arising over the plan period is fully acknowledged and the case for Green Belt release fully accepted by the Black Country Authorities. Bloor welcome this stance.


8.2. Of great concern however is the fact that despite some Green Belt release to deliver new homes, the Plan falls a long way short of delivering sufficient homes to get anywhere close to meeting the identified housing need.

8.3. We submit that basing a plan on the non-delivery of almost 30,000 homes and the expectation that the wider housing market area can and will deliver them is an entirely unsound strategy. This is particularly so in the context of a HMA which has struggled with the legacy of significant unmet arising from Birmingham City in the recent past and where question marks remain over the successful absorption of those homes amongst neighbouring authorities.

8.4. We submit that the plan should meet its housing need in full and that if Green Belt release is fully accepted as mechanism to do this, then there is further capacity within the Green Belt to allow additional homes to be delivered within the Black Country.

8.5. The Bloor site represents additional capacity in a sustainable location where the



allocation WAS7.


8.6. We contend that any landscape harm identified is not of a sufficient magnitude so as to prevent the allocation of the site in full. Nevertheless, Bloor remain committed to exploring options for a lesser quantum of development on the site in order to overcome any landscape concerns that the council may perceive. We note that such flexibility has been extended to other allocations.

8.7. There are no substantive reasons not to allocate the Stencils Farm site which can be delivered in the early years of the plan.

Object

Representation ID: 23275

Received: 11/10/2021

Respondent: Bloor Homes Midlands

Agent: Cerda Planning Ltd

[Site Ref: Land at Stencils Farm, Aldridge Road, Walsall Sustainability Appraisal References SA-0019-WAL / SA-0066-WAL]


[Attachment: Rep Form]

Please see attached representation.

----------- REP FORM ENDS -----------

[Attachment: Executive Summary]

CERDA

Black Country Plan (2018 - 2039)

Regulation 18 Consultation October 2021



1. Executive Summary



1.1. The Black Country Plan fails to deliver anywhere close to its identified housing need, with a reliance on neighbouring authorities to deliver homes that are needed now within the Black Country. The reliance on such an approach without a firm commitment from all of the neighbouring authorities is not considered to be a sound approach to plan making. Especially when sites such as Stencils Farm are available within the plan area without any significant constraints to development.


1.2. There are clear errors in the evidence which underpins the plan, in particular within the individual Site Assessments which themselves justify the proposed housing allocations. These errors and inconsistency in the application of evidence in the assessments is a
significant and fundamental flaw of the plan.

1.3 The Stencils Farm site is not subject to any 'gateway constraints' that would prevent its development. The harms attributed to the site within the evidence are misleadingly overstated and there are no substantive reasons for the site not to be allocated for development. The allocation of Stencils Farm site would enable the Black Country Authorities to reduce its housing delivery deficit and move closer to meeting its critical need for new homes without any demonstrable negative impacts.


2. Introduction



2.1 Cerda Planning has been instructed by Bloor Homes Midlands (hereafter referred to as Bloor) to prepare and submit these representations to the Draft Black Country Plan 2039 (Regulation 18) Consultation.


2.2 Bloor have an interest in the land and are the prospective developer of the site known as Land at Stencils Farm, Aldridge Road, Walsall Sustainability Appraisal References SA-0019-WAL / SA-0066-WAL (the site).

2.3 These representations are made in the context of the requirement for Local Plans to be legally compliant and sound. The tests of soundness are set out at paragraph 35 of the Framework. In brief, a plan will be sound if it is:


Positively prepared; Justified;
Effective; and

Consistent with national policy


2.4 These representations raise concerns with the draft plan's soundness, more specifically with the strategy, both in terms of overall levels of housing growth proposed without an agreed strategy for meeting the shortfall and the distribution of homes within the plan area. Concerns are also raised with the council's evidence base, specificates the robustness and fairness of the site assessment work which has informed the decisions made on the draft allocations.

2.5 In raising these concerns, we submit that the Bloor site represents a sustainable option to help address the identified deficiencies in the soundness of the plan through the delivery of circa 700 new homes (including up to 30% affordable), in a highly sustainable location that both sustainable housing growth and boosts the supply of housing that is deliverable within the early part of the plan.
2.6 Accordingly, these representations seek a revision to the plan such that the Bloor site is included as a housing allocation to assist in ensuring the plan delivers certainty and ultimately, succeeds as a tool for meeting the housing needs.

2.7 Bloor have previously submitted a Vision Document to Walsall Metropolitan Borough Council which demonstrates technical deliverability of up to 700 homes. For ease of reference this document is included with these submissions. Bloor have taken the opportunity to revisit the Vision D nce base and a revised Development Options Document has been prepared in order to demonstrate how the site could be delivered with a reduced developable area and lower quantum of homes (circa 350).

2.8 In terms of format, the representations are split in to 6 sections which consider the following main issues:


Assessment of the site - Stencils Farm

The overall housing need within the Black Country; Delivery from the proposed allocations;
Wider spatial planning for the Greater Birmingham and Black Country Housing

Market Area;

The Site Assessments;

Conclusion and case for allocation of the site.



2.9 In addition, the following documents are attached as appendices to this representation:


Vision Document July 2019 (Submitted with the Call for Sites submission) Development Options Document September 2021
Landscape + Visual Appraisal November 2018 (Submitted with the Call for Sites submission)
Landscape + Visual Appraisal Addendum October 2021

Landscape Sensitivity Review October 2021
3. Stencils Farm, Aldridge Road, Walsall



3.1 The site, which lies immediately adjacent to the eastern edge of St Mathews (Walsall), extends to some 37.8 ha in area and is irregular in form. The land gently rises from the northern and southern edges to an elevated central area. The greater part of the western boundary is formed by existing residential development and field boundaries with agricultural land beyond. The Daw End Branch canal defines the eastern and north eastern boundaries of the site.


3.2 The southern edge of the site is contained by the A454 Aldridge Road, which, for almost



which provides access to Calderfields Golf Club and the Dilke pub/restaurant which are to the south. Land to the south is proposed to be allocated within the plan for around
592 houses under Policy WSA7 (Calderfields West).



3.3 As demonstrated within the previously submitted Vision Document, the location is a highly sustainable one for which there are no technical constraints to delivery. The council evidently share this view given the decision to allocate the land to the immediate south for circa 600 homes (Policy WSA7 (Calderfields West).


3.4 The land at Stencils Farm could accommodate circa 700 dwellings (both market, affordable and specialist), extensive areas of public open space including a canal side country park, a new 2FE Primary School and Local Centre (including if required provision of healthcare facilities). The site is free of any major infrastructure requirements such that it could be realistically delivered during the early years of the plan period. The ty. As demonstrated in the revised Development Options Document, the site could also be developed to a lesser extent, delivering circa 350 homes along with significant areas of public open space.


Landscape Assessment


3.5 Having regard to the site assessment work that the council have undertaken and the

, the site appears to been discounted as an allocation for housing development largely as a consequence of the perceived impacts on landscape. Bloor have significant concerns
with the robustness of the both the site itself but also in relation to the consistency by which the evidence base has been applied to other sites in the site selection process.


3.6 The co



assessment makes reference to a landscape appraisal (the FPCR appraisal)

commissioned by others prior to Bloor acquiring their interest in the site.



3.7 Bloor commissioned Paul Gray Landscape Architects to prepare a full Landscape and Visual Impact Assessment to inform the masterplanning of the site and the subsequent Vision Document, which was submitted to the council following its call for sites submission. The full version of this report was sent to the council electronically on 19th September 2019. Whilst the council has nevertheless undertaken their own Landscape Assessment (LUC), we assert that the council must have regard to the LVIA which has informed previously submitted masterplan as part of its site assessment work. The LVIA demonstrates that the site is able to accommodate the proposed residential development of the site without causing undue harm to the landscape character and visual amenity of the site and surrounding countryside and footpath network. For the avoidance of any doubt, this original LVIA is included with this submission.


Landscape Sensitivity Review


3.8 Following the publication of the Council s landscape evidence base a Landscape Sensitivity Review (attached) has been undertaken by Paul Gray Landscape Architects in order to consider the conclusions drawn on the site and wider landscape parcel within the LUC assessment.


3.9 The Walsall Landscape Sensitivity Assessment, undertaken in support of the plan, is not considered to be sufficiently detailed for each of the sites assessed within the plan to be considered a robust assessment upon which to base an assessment of landscape sensitivity of each individual site, and in particular the Bloor site at Stencils Farm. The major flaw in the assessment relates to the fact that the assessments were undertaken based on extensive parcels of land which contain areas of land with varying landscape qualities and sensitivities. Where areas of higher landscape sensitivity exist within a larger parcel of less sensitive land the higher landscape sensitivity scoring has been applied as a blanket grade rather than the larger parcel being considered in more detail.
This board brush assessment unfairly sterilises areas with potential for development.

3.10 The Bloor site represents approximately 14% of the total parcel of land assessed (Parcel BL32) in the LUC, and there are multiple landscape attributes with varying degrees of sensitivity within the wider parcel. The site itself having been considered in detail in the assessments undertaken by Paul Gray Landscape Architects demonstrate that the landscape sensitivity score for the site itself (and not the wider parcel of land) should be


landscape and visual sensitivities beyond the site boundaries and should be re-scored for its landscape sensitivity and accordingly should be allocated for residential development.

3.11 The oderate high rating attributed to the site in the Site Assessment must have been based upon sensitive areas within the wider parcel of land such as the Rushall Hall Scheduled Monument and Conservation Area, Park Lime Pots Local Nature Reserve, Daw End Railway Cutting SSSI and the canal corridor. The sensitivity grading of the site is therefore not reflective of the finer granular nature of the wider character area which means it usefulness and effectiveness as a tool to inform an assessment is obviously flawed and does not provide an appropriate evidence base for making decisions on site allocations.

3.12 It is of significant concern that this blanket scoring has been carried through to the



the small scale field pattern which contributes to the settlement setting of Walsall, made up of a large scale field pattern, with the smaller more intimate fields being located within the wider landscape parcel, in particular in the area to the north and east of Daw End Branch Canal which is outside the site and the attributed landscape sensitivity score is incorrect.

3.13 In addition, notwithstanding any difference of professional opinion that may persist on landscape impact and our view that the Site Assessment is flawed for the original proposal an updated LVIA (Landscape + Visual Appraisal Addendum October 2021) considers the landscape impacts of a reduced development site and how a reduced quantum of development could robustly address the concerns (albeit in our opinion unfounded) raised in the LUC assessment.
4. The overall housing need within the Black Country



4.1. The Plan identifies an overall housing need of 76,076 homes across the four councils that make up the plan for period up to 2039. The plan acknowledges that there is an inability to accommodate that need over the plan period within the existing built-up area. More specifically, it is our submission that there is a significant housing shortfall of at least 38,469 as evidenced in the Black Country Urban Capacity Review Update (May
2021) prepared by Barton Wilmore on behalf of Bloor. There is, as a consequence, a recognised need and urgent requirement to release land from the Green Belt to meet



4.2. In is notable that this shortfall up to 2039 has increased significantly in the last two years by 10,000 homes. This is as a result of abandoned housing allocations on occupied employment sites and the increase in housing need in Wolverhampton as a result of the new standard method (Wolverhampton being subject to the 35% uplift). The identified shortfall over the plan period has now risen to exceed 50% of the total housing need for the area. The latest Urban Capacity Review confirms this.

4.3. A key aim of the Black Country Plan must be to meet all of the housing need within the Black Country. This will necessitate the development of sites which are currently in the Green Belt.

4.4. The exportation of homes to meet this identified to other local authorities within the HMA should be a last resort. It is of great concern therefore that the emerging spatial strategy is underpinned by a desire to export 28,239 homes (37% of overall housing need) over the plan period to other authorities within the GBBCHMA, with little or no certainty at this stage that the delivery of these houses elsewhere is feasible.

4.5. We consider this to be an unsound basis on which to make a plan. Notwithstanding the fact that the plan should be meeting its housing need in full within its own administrative area, relying on other authorities to deliver such a significant proportion of the Black



4.6. The Black Country is at a critical point in its plan making process and we submit that given the scale of the unmet need and the inherent difficulties that are faced in exporting the delivery of homes to other plans, the Black Country Plan needs to revisit its spatial
strategy to ensure that it meets its own housing in full. This will require the identification of further sustainable, Green Belt sites.

4.7. It should also be noted that 28,239 homes which the plan fails to plan for represents further unmet need within a housing market area within which there has, in the recent past, been a significant level of recogised unmet need arising out of Birmingham City (circa 37,000 homes). Question marks remain over how robustly that need has been met to date.

4.8. We eagerly await an updated position statement in terms of housing need and supply in relation to the whole Greater Birmingham and Black Country Housing Market Area (GBBCHMA) following the 3rd position statement (3PS) published in July 2020., Without this it is difficult to accurately ascertain exactly what the shortfall in delivery is and how much of the
delivered elsewhere within the GBBCHMA within the plan period. In addition, we consider that there is currently a lack of robust evidence to support the actual unmet need in the GBBCHMA (noting that the Black Country shortfall identified above is likely to be the most up to date and increases the shortfall identified in the 3PS for the Black Country by over 30%). It is critical that the overall unmet need is identified and addressed over a consistent timeframe.

4.9. It is also important to note that the contributions from other Local Authorities in the GBBCHMA in order to meet the needs of the Black Country (and Birmingham) are unlikely to increase by any significant extent above the contributions set out in the 3PS. Indeed, the contributions are more likely to decrease. An example of this is contribution which has decreased from 4,000 in the 3PS to 2,665 in their Regulation 19 draft plan. In addition, this plan s Duty to Cooperate Statement (July 2021) also identifies that Cannock are now likely to contribute homes at the lower end of the 500 2,500 range suggested in the 3PS, with a figure of 500 confirmed in their Preferred Options (February 2021).

4.10. The Duty to Cooperate Statement (DTCS) identifies what we consider to be a best-case scenario for the delivery of new homes against the exported need. The DTCS identifies potential (not secured) contributions to the shortfall across the whole GBBCHMA of
14,750 homes.

8,000. These offers and potential contributions relate to meeting the needs of both the Black Country and Birmingham and whilst the DTCS identifies that apportionment of these contributions is to be addressed during and after this Regulation 18 consultation
it remains that there will inevitably be a significant shortfall over the plan period in particular across the Black Country.

4.11. In light of this certain significant shortfall, it is our opinion that more sites that are confirmed as deliverable should be allocated within the plan (including the Bloor site), and that greater flexibility should be provided in the plan itself in order to make up some of this inevitable shortfall. This is accepting that the unmet need will never be fully met by the other Local Planning Authorities in the HMA. This plan needs to grapple with the issue of this significant unmet need and find ways to deliver more homes.

4.12. Whilst housing need and supply is a moving feast, the housing requirements for the Black Country will undoubtedly increase whereas actual delivery will in all likelihood decrease as the plan moves towards adoption. A more innovative and holistic view of the supply and delivery of the homes that the Black Country needs, must be adopted. In simple terms additional sustainable and deliverable sites within the Black Country must be found. The Bloor site meets these requirements.
5. Delivery from proposed allocations;



5.1. It is clear that the overwhelming housing need in the Black Country has resulted in the need to ensure the best use of land, but it is our opinion that the housing numbers proposed on a number of the allocated sites are unrealistic even considering the discounts applied to these sites as described in the justification to Policy HOU1.

5.2. Whilst the general principles behind the requirements of Policy HOU2 are supported, to ensure that appropriate housing densities are delivered in sustainable locations we are concerned that the densities proposed on a number of the proposed allocations have failed to consider the individual circumstances of each site. Rather a density of 45 or 35 net dwellings per hectare (dph) has been applied without proper consideration of the site constraints and as such, the number of homes to be delivered across the proposed allocations will not be as great in reality as the capacities indicated in the plan.

5.3. It is clear that as a consequence of the critical delivery and capacity issues facing the Black Country there is a need to consider all options, including increasing housing densities across the plan area. In all likelihood however, on the majority of allocated sites which are on the edges of the urban area, a substantial increase in density is unlikely to be achievable based on individual site characteristics, constraints and market demand for family housing

5.4. The Black Country Urban Capacity Review Update (May 2021) when assessing the potential to increase densities across the area acknowledges that character constraints such as listed buildings, conservation areas and existing local character/density reduces typical density to around 15-25 dph. The following table highlights some of the areas of concern in respect of the proposed densities which are likely to reduce the level of actual housing delivery on a number of the proposed allocations:

Table 1: Density and known constraints

[Headings:] Policy (SA Reference) / Proposed Density (dph) / Known Constraints

WSA1 (SA-/At least 35/SLINC, surrounding low density character, retention of exisitng buildings, site originally proposed at 15 dph.
0022-WAL)//
WSA2 (SA-/At least 35/

character.
0048-WAL)//
WSA3 (SA-/At least 35/Surrounding low density character.
0034-WAL)//
WSA4 (SA-/At least 35/Listed Buildings on site, SLINC, surrounding low density character.
0014-WAL)//
WSA5 (SA-/At least 35 and Site Assessment identifies 45/surrounding low density character.
0030-WAL)//
WSA6 (SA-/At least 35/SLINC (whole of the site), existing field patterns, surrounding low density character.
0012-WAL)//
WSA7 (SA-/At least 35//landscape/sensitivity,
0078-WAL)//Arboretum impacts//
WSA8 (SA-/At least 35 and Site Assessment identifies 45/Conservation Area, Listed Buildings, visual prominence and topography.
0017-WAL)//


5.5 located sites were to reduce by even 5 dwellings per hectare this would see an overall reduction in numbers across the allocations of over 800 dwellings. This further adds to the need for additional sites to be allocated for development in the plan.
6. Wider spatial planning for the Greater Birmingham and Black
Country Housing Market Area;


6.1. When considering the t is important to highlight that the Green Belt is a spatial planning land typology of and not a landscape designation. To that end it is important to consider the proposed allocations in the plan spatially in relation to the wider housing market area (HMA) and not just where they are bound by the administrative area of the plan.


6.2. Spatially it is clear that the delivery of new Green Belt sites is heavily weighted to Walsall.

However, the Site Assessments for a number of the proposed allocations located on the on the edge of the plan area have failed to fully consider their wider spatial and landscape impacts. Indeed, a number do not appear to have been appropriately considered in relation to the settlements beyond the Black Country boundary or their landscape impact beyond the Black Country boundary. Rather, they have been allocated based on historic administrative boundaries. This plan represents the opportunity to develop sites which can be developed more comprehensively, which would represent proper spatial planning

6.3. To this end, it is our opinion that appropriate sites that can be sustainably planned as a whole within the plan area, rather than relying on development in neighbouring authorities should be given greater weight than appears to be the case in the plan. This is certainly the case for the Bloor site, which follows the settlement pattern of the area and can be wholly planned and defined within the Black Country area.

6.4. When considering the somewhat questionable location and boundaries to sites on the edge of the plan area such as the proposed allocations under policies WAS4, WSA1, CSA1 and CSA2, the plan and its policies do little to consider the wider spatial or landscape impacts of developing these sites and appear to reduce the weight given to high (and moderate-high) levels of Green Belt and landscape harm in these areas favoring its central area.

6.5. The plan identifies the development of a network of Neighbourhood Growth Areas are proposed to be released from the Green Belt in sustainable locations. However, given the identified infrastructure requirements on each of these sites (noting that no fewer than 7 new Health Centres
are required by the allocating policies) it is our submission that these areas should be planned more holistically to ensure that wider benefits ensue from these allocations and that the delivery of the necessary infrastructure is actually viable and will be delivered where there is a proven need. To this end the term NGA, which is, by any other name, a housing allocation should be widened to provide for coordinated growth in areas where there is an identified need (or deficiency) of services and sites allocated in order to provide for both the much needed new homes but also new services and facilities.

6.6. The Bloor site for example, combined with the proposed allocation on the southern side of Aldridge Road (WAS7), provides such an opportunity. Co-ordinated education facilities, a local centre incorporating a Health Centre and Foodstore would provide for the needs of both sites and meet deficiencies already evident in the local area. The allocation under WAS7 being for only 592 dwellings is unlikely be able to viably deliver infrastructure requirements of the policy i.e. a new primary school and local health centre. Increasing the growth within this wider area which the council consider suitable for sustainable development is an appropriate mechanism for securing the required housing growth alongside new shared and sustainable infrastructure.
7. The Site Assessments



7.1. The Site Assessment Report: Assessment and Selection Methodology and Results (August 2021) (SAR) paper is part of the evidence base which informs the plan. It draws including the
Sustainability Appraisal of the Black Country Plan (Lepus Consulting June 2021 and

July 2021 versions). It is by consequence the main document which appears to have


justification for its spatial strategy.



7.2. The assessment undertaken is a multi-stage one. In simple terms, sites which progressed removed were then subject to more detailed site assessment against a range of criteria grouped under the headings: Green Belt and landscape sensitivity; Environmental; , amber, and
The Bloor site passed the initial filter stages and is not . For the avoidance of doubt, a red score is negative and green positive. It is not clear from the assessments or the published methodology what weight is given to each of the scoring criteria. The following section considers the Bloor site alongside a number of the proposed allocations under each of the wider headings.


Green Belt and landscape sensitivity


7.3. This element of the assessment is based on the Black Country Landscape Sensitivity

Assessment (LUC September 2019) and the Black Country Green Belt Study - Stage 2

Report (LUC September 2019). The SAR identifies that sites considered in the assessment as being likely to cause very high harm to the remaining Green Belt and where landscape sensitivity is likely to be moderate-high or high, have been considered




7.4. The Bloor site scores very high in terms of its Green Belt harm and moderate-high in terms of its landscape sensitivity and it is assumed that this is the main reason for it
.
7.5. In comparison, it is noteworthy and a cause of significant concern that a number of allocated sites score the same in terms of harm against these same criteria as the Bloor site (see Table 2 below) begging obvious questions around the fairness and robustness of the Site Assessment process especially in the context of such a significant housing shortfall. The SAR does go on to state that the Green Belt and Landscape assessments were based on larger parcels of land, and where the Council consider that a smaller site is judged to result in a lower level of harm, the level of harm has been downgraded as per the commentary in the table below.

7.6. It is our opinion that the landscape sensitivity rating for the Bloor site has incorrectly

- from the wider parcel, where the site itself

shoul Architects landscape evidence. These detailed assessments consider that the site as originally proposed (circa 700 dwellings) would not result in residual landscape effects beyond moderate significance, which is also the case for the reduced site. The Council has erred in not judging this site separately from the wider landscape parcel, as they have with a number of the proposed allocations as detailed in the table below. As our evidence shows if the Bloor site had been considered separately from the wider parcel the site would score better in the assessment of landscape sensitivity than a number of allocated sites and should have been considered suitable for development and allocated accordingly.

Table 2: Green Belt Harm and Landscape Sensitivity

Table 2: Green Belt Harm and Landscape Sensitivity

[Headings:] Policy (SA Reference) / Green Belt Harm / Landscape Sensitivity / Corrected Landscape Sensitivity Score / Comments

Stencils Farm/Very High/Moderate -/Moderate/The detailed comments
(SA-0066-WAL)//High//repeat the comments of the wider parcel assessment with no specific comments on the site itself.
Land north of/Very High/Moderate -/Moderate - High/Considered to have a high
Stonnall Road,//High//sensitivity based on its
Aldridge WSA3////topography (in places) and

(SA-0034-WAL)////its strongly rural and
////undeveloped character.
/////Overall conclusion
/////considered the site to have

limited visual impact due to
/////surrounding uses and
/////topography.
Calderfields/Very High/Moderate/-/Moderate - High/The comments note that
West WSA7//High///the site may have to be
(SA-0078-WAL)/////reduced to minimise impact
on the Green Belt and landscape sensitivity. No
/////explicit mention of this
/////within the allocating policy.
Land between/Very High/Moderate/-/Moderate - High/The fact that the assessed
Doe Bank Lane//High///parcel is larger than the
and Aldridge/////proposed site is noted as is
Road WSA8/////mention of the edge to
(SA-0017-WAL)/////Pheasey being more open

and forming a hard edge
/////which is considered to
/////reduce the landscape
/////sensitivity to less than
/////moderate-high or high.

Comments on the proposed allocations detailed above


7.7. WSA3 Land north of Stonnall Road, Aldridge: In terms of Policy WSA3 (Land north of Stonnall Road, Aldridge) the assessment appears to miss the conclusion to the Landscape Sensitivity Judgement. That is, the land to the north of the golf course (which includes the site) is considered to have a slightly higher (than moderate-high) sensitivity to residential development, and views of the site are considered to have sensitivity to development by virtue of the open views of the site. This assessment runs contrary to the conclusion of the SAR which considers the site to have limited visual impact due to surrounding uses and topography.


7.8. WSA7 Calderfields West: In reaching a judgement on the allocated site directly to the south of the Bloor site, WSA7 (Calderfields West), rather than disagree with the level of harm in the assessment, the SAR merely identifies the fact that the site area may need to be reduced. It does not appear that the same level of flexibility has been given to the Bloor site in undertaking these assessments, and we are happy to consider suggestions
by the Council which appear to have been missed for our site but forthcoming on a number of allocations including WSA7 which is immediately adjacent to the Bloor site with the same landscape and Green Belt harms ratings. In simple terms, if the landscape and Green Belt harm ratings are the same for this site which is adjacent to the Bloor site, and there are no other gateway constraints identified by the council, then there is no objective or evidence based reason to not allocate the Bloor site.

7.9. WSA8 Land between Doe Bank Lane and Aldridge Road: The assessment for site WSA8 (Land between Doe Bank Lane and Aldridge Road) is considered to underplay both the local and wider sensitivity of developing the site. The small-scale fields to the southeast between Doe Bank Lane and Birdle Lane are considered to have a higher sensitivity to development as detailed within the Landscape Sensitivity Assessment, with the Great Barr Conservation Area and Grade II Listed Buildings also identified as having higher sensitivity to development. The site contributes to the rural gap between these settlements. Large scale development would disrupt the small-scale field pattern, particularly to the east of Doe Bank Lane, which provides a rural and open backdrop to Streetly and Pheasey.

7.10. Instead, the SAR appears to concentrate on a small comment on the Landscape Sensitivity Assessment which is that the settlement edge of Pheasey becomes more open, forming a hard edge. This comment is not considered to relate to the draft allocated site, it is more a comment on the existing development on the western side of Doe Bank Lane. In terms of Green Belt harm the assessment is accepted that is, the development of the site would result in a very high level of harm and the site currently preserves the separation of Streetly and Pheasey as set out in the assessment which would be entirely lost by the development of the site. Correct consideration of the Landscape Sensitivity Assessment undertaken would not see the site proposed for allocation.
Environmental


7.11. The environmental assessments undertaken are generally accepted in relation to Stencils Farm (the Bloor site), but it is necessary to highlight what appears to be a contradictory statement made in relation to the impacts on visual amenity (which includes impact on adjacent land users and local character) insofar as this assessment comments West. The limited leisure uses to the South contribute to a rural character which would be lost if the site was developed. Limited impact on nearby residential outlook due to the orientation of houses. For these reasons there would be a significant local impact, due to the topography and surrounding development there would be a limited wider impact. This conclusion is welcomed as a site-specific assessment rather than the wider landscape harm identified when a larger parcel of land was assessed under the Landscape Sensitivity and Green Belt assessments. Nevertheless, the site scored red in this assessment which would appear to be an incorrect score based on the observations made in the assessment. This view is further evidenced in the Paul Gray Landscape Architects landscape evidence appended to this submission.


7.12. A number of the proposed allocations also score red in this assessment namely WSA2, WSA4 and WSA5. The table below considers the Bloor site against sites proposed for allocation which also score red in the assessment and proposed allocation WSA8 which scores amber. However, in our opinion, WSA8 should score red due to the significant local impacts identified. In addition, we disagree than the wider impacts would be reduced to such an extent that it performs better than the Bloor site in this element of the assessment.

Table 3: Impact on Visual Amenity

[Headings:] Policy (SA Reference)/Impact on Visual Amenity/RAG Score/Corrected RAG Score/Assessment Comments

Stencils Farm///Large open site prominent from
(SA-0066-WAL)///Aldridge Road and Open Space to the

North West. The limited leisure uses to
///the South contribute to a rural
///character which would be lost if the site was developed. Limited impact on
///nearby residential outlook due to the
///orientation of houses. For these
///reasons there would be a significant local impact. due to the topography and surrounding development there would be a limited wider impact.
Land at Vicarage Road, High Heath WSA2 (SA-0048- WAL)///Significant impact on visual amenities

from existing dwellings and users of
///PROW. Existing semi-rural character
///lost. Location close to existing
///development and favourable
///topography limits wider harm
Yeildsfield Farm///Strong local impacts by residents and
WSA4 (SA-0014-///users of the highway. Landscape
WAL)///design could mitigate this impact. The
site would be seen some distance away on Stafford Road. Semi-rural
///landscape lost and the visual
///separation between Bloxwich and
///Great Wyrley reduced. On balance mitigation can be achieved though sensitive design and mitigation.
Land at Yorks///The canal is a barrier between Pelsall
Bridge WSA5///and the rural character, any
(SA-0030-WAL)///development beyond the canal will have a significant detrimental impact on the visual amenities of the canal and local occupiers. Flat topography results in a moderate wider impact.
Land between///Significant local impact from residents

who face the site (on three of four sides). The site is level with Queslett Road and it is considered that this impact would reduce any wider visual impact.
Doe Bank Lane///
and Aldridge///
Road///

7.13. The assessments in the main identify significant local harm, and whilst the weighting in the final scoring of sites from this part of the assessment is unclear, it remains in our opinion that the Bloor site performs much better in this assessment that a number of the proposed allocations.


Economic



7.14. The main area of concern within the Economic section of the SAR relates to the inconsistency with which the Highway a




7.15. More specifically, the individual site assessments identify that 7 of the proposed allocations have not been appropriately assessed for their impacts on the wider highway network which raises concerns as to their deliverability. In addition, the consistency with which these constraints are identified within the assessments vary in terms of their RAG score, specifically relating to the impact on the wider road network. The RAG scoring for Highway Access and Transportation relates to the following: Red = Access constraints
/ severe highway safety impact which cannot be viably overcome; Amber = Access constraints / highway safety impact which can be viably overcome; Green = No / negligible access constraint. The table below highlights a number of anomalies / questionable scoring.

Table 4: Impact on the wider road network corrected RAG scoring

[Headings:] Policy (SA Reference)/RAG Score/Corrected RAG Score/Comments

Stencils Farm

(SA-0066-WAL)///Impact assessment of highway

capacity required.
Home Farm, Sandhills WSA1 (SA-0022-WAL)///No assessment of the capacity

of Chester and Lichfield Road undertaken.
Land north of Stonnall Road, Aldridge WSA3 (SA-0034-WAL)///Highway impact assessment

required to fully assess what infrastructure works required.


7.16. When considering the proposed corrections in the RAG scoring it is important to highlight the scoring from comparable allocations where similar identified constraints score amber rather than green as tabulated in table 5 below:

Table 5: Impact on the wider road network appropriate RAG scoring

[Headings:] Policy (SA Reference/RAG Score/Comments

Land at Vicarage//Likely significant wider impacts
Road, High Heath//identified and a requirement for a
WSA2 (SA-0048-//traffic impact assessment identified.
WAL)//
Land at Yorks//A highway impact assessment is

required.
Bridge WSA5 (SA-

0030-WAL)//
Land off Sutton//Could be wider impacts which may

need to be assessed
Road WSA6 (SA-

0012-WAL)//
Calderfields West//Housing numbers proposed are likely
WSA7 (SA-0078-//to require a Highways Impact
WAL)//Assessment.
Land between Doe//Surveys would be required to assess

impacts.
Bank Lane and//
Aldridge Road//
WSA8 (SA-0017-//
WAL)//

7.17. It is unclear how proposed allocation WSA2 with its red score i.e. there is a very substantial negative effect that is unlikely to be capable of mitigation in terms of its impact on the wider road network has been allocated for development without certainly that the network can accommodate the development.


7.18. Stencils Farm (the Bloor site), scored red in the same assessment with a simple comment that an impact assessment of highway capacity is required. This is even when a site accessed from the same road (Aldridge Road) proposed as an allocation (WSA7) scores amber. This is clearly an error that requires correcting and removes another of

Social



7.19. The scoring in this respect is generally accepted. However, there appears to be an error in the scoring for all sites albeit the comments clarify the scoring. The methodology for access time, which details the times identified will be walking times for access to primary schools only with other times being public transport times. As such the site should only score red for the walking times to a primary school (noting that a primary school is proposed on the site which would overcome this minor shortcoming of the site) and not for access to a GP/Health Centre/Walk in or Centre/Foodstore.


Conclusion on the Site Assessments



7.20. Having regard to these significant assessment anomalies it is asserted that the site should not have been discounted for housing development. With corrected assessment scores as detailed above the site scores at least as well if not better than the sites proposed for allocation under policies WSA3, WSA7 and WSA8 in terms of landscape sensitivity, better than proposed allocations under policies WSA2, WSA4, WSA5 and WSA8 in terms of visual amenity, and better than proposed allocation WSA2 and equal to WSA1, WSA3, WSA5, WSA6, WSA7 and WSA8 in terms of impact on the highway network. Proper consideration of the Bloor site within the Site Assessments would see the site allocated, which raises serious questions about the robustness and fairness of

8. Conclusion and case for allocation of the site.



8.1. The inability for the existing urban areas of the Black Country to accommodate the housing need arising over the plan period is fully acknowledged and the case for Green Belt release fully accepted by the Black Country Authorities. Bloor welcome this stance.


8.2. Of great concern however is the fact that despite some Green Belt release to deliver new homes, the Plan falls a long way short of delivering sufficient homes to get anywhere close to meeting the identified housing need.

8.3. We submit that basing a plan on the non-delivery of almost 30,000 homes and the expectation that the wider housing market area can and will deliver them is an entirely unsound strategy. This is particularly so in the context of a HMA which has struggled with the legacy of significant unmet arising from Birmingham City in the recent past and where question marks remain over the successful absorption of those homes amongst neighbouring authorities.

8.4. We submit that the plan should meet its housing need in full and that if Green Belt release is fully accepted as mechanism to do this, then there is further capacity within the Green Belt to allow additional homes to be delivered within the Black Country.

8.5. The Bloor site represents additional capacity in a sustainable location where the



allocation WAS7.


8.6. We contend that any landscape harm identified is not of a sufficient magnitude so as to prevent the allocation of the site in full. Nevertheless, Bloor remain committed to exploring options for a lesser quantum of development on the site in order to overcome any landscape concerns that the council may perceive. We note that such flexibility has been extended to other allocations.

8.7. There are no substantive reasons not to allocate the Stencils Farm site which can be delivered in the early years of the plan.

----------------------- EXECUTIVE SUMMARY ENDS ------------------

[Attachment: Vision Document]

Contents

Executive Summary Page 03

1.0 Introduction Page 07

2.0 Creating a new Gateway & Garden Suburb Page 11

3.0 Planning Policy Background Page 23

4.0 Working with the Site Page 27

5.0 Creating a New Neighbourhood Page 41

6.0 Summary Page 51



EXECUTIVE SUMMARY
Purpose
This Vision Document has been prepared on behalf
of Bloor Homes by a professional, multi-disciplinary
team in support of the land at Stencils Farm, Walsall
n recognition Of the work which is being undertaken
by the respective Black Country Authorities to review
the Black Country Core Strategy and with it the
acknowledged need to release a significant quantum
of land from the Green Belt in order to deliver additional
houses within the Black Country, this document
considers the suitability Of the land at Stencils Farm
for residential development It advocates its release
from the Green Belt so as to assist in meeting these
identified housing needs
The primary purpose ofthis documentis to demonstrate
the site is suitable to be released from the Green
Belt having regard to the purpose it serves and by
consequence, that the site is suitable and available
to deliver a significant quantum of homes to meet the
need which is identified across the Black Country
To this end, it supports the Call for Sites submission
which has already been made to the Review; this site
being identified as No 125, 'Land at Stencils Farm,
Aldridge Road, Walsalll The document builds on the
previous work which has been presented previously
The purpose Of the statement is therefore fully aligned
with the acknowledged commitment by the Black
Country Authorities (BCA) to undertake a full Green
Belt review so as to enable the identification and
allocation of new sites to meet the acknowledged
residential need as part Of the preparation Of its Core
Strategy review
The site at Stencils Farm represents a logical and
sustainable extension to Walsall on its eastern edge,
contiguous with the existing settlement boundary and
within close proximity to existing services, employment
opportunities and public transport links
The following sections of this document set out the
site specific approach to creating a sustainable and
deliverable residential led development at Stencils
Farm Ultimately, it is a development which works
with the existing landscape form, takes full account
of the site's existing features and is therefore truly
responsive to its context
Through this process we will demonstrate Bloor
Homes' credentials as a developer that is sympathetic
to the environment and the communities in which it
works and that the site at Stencils Farm represents
a logical, sustainable and deliverable one which it is
entirely appropriate to release from the Green Belt
Ultimately it is a development which will create a
thriving community and will be a positive asset for
Walsall Borough and the Black Country more generally
Bloor Homes looks forward to continuing a constructive
dialogue with the BCA and is committed to promoting
the land at Stencils Farm through future stages of the
Core Strategy Review process
Headline Benefits
Key benefits of the proposed scheme include the
delivery of:
• approximately 700 market and affordable homes
with a range Of housing sizes and tenures to help
meet the demand for new housing in the area;
• new areas of public open space;
• a new two form entry primary school
• a new Local Centre;
• a development which respects the adjoining
neighbours in terms Of providing landscape buffers
between existing and proposed homes,
• a sensitive, high quality green infrastructure network
that maintains and improves the wildlife corridors
and biodiversity in the area, whilst maintaining much
Of the existing planting, hedgerows and trees; and
• a development which works with the existing
constraints to ensure that the purposes of the
retained Green Belt are strengthened, notdiminished
by creating this new sustainable urban extension

1.0 INTRODUCTION
[Page 8] Figure 01:01 Site Location Plan
11

111

Backdrop to the Stencils Farm Vision

Work is now well underway towards the preparation

of the Black Country Core Strategy Review which will

take the plan period to 2036 The Issues and Options

have been published and the Council are, at the time

of writing, undertaking the work necessary to produce

a Preferred Options Document Publication of this is

expected in the Autumn of 2019

The May 2018 Black Country Urban Capacity Review

confirms that the Black Country and South Staffordshire

Strategic Housing Market Assessment 2017 housing

need (2014 to 2036) is 78,190 homes The total

confirmed supply for the same period however is just

60,377 homes

There is therefore an acknowledged supply shortfall

for the plan period 2014 to 2036 Of some 17,813

homes based on local objectively assessed need It

is acknowledged that the shortfall drops slightly to

17,263 when using the government's new proposed

standardised methodology

Added to this shortfall is a further 3,000 homes

on account Of the BCA's stated commitment to

accommodate a share Of the unmet need from

Birmingham City Council Thus, the total acknowledged

shortfall across the Black Country is 20,813 homes for

the plan period 2014 to 2036 (using local objectively

assessed need)

The May 2018 Black Country Urban Capacity Review

confirms that despite reviewing the additional potential

housing numbers through a series Of structured

assumptions based around density and windfall sites,

the amount of homes that cannot be accommodated

within the existing Black Country urban areas remains

significant

Given the urban areas within the Black Country are, for

the most part, contained by the West Midlands Green

Belt, the Urban Capacity Review concludes that the

exceptional circumstances needed to trigger a Green

Belt review in the Black Country in order to meet both

housing and employment needs are met.

As a consequence, the BCA have issued a fresh cal

for sites and with this the acceptance that sites within

the Green Belt will need to play a significant role in

meeting the BCAs housing requirement over the

Review plan period

Bloor Homes are confident that this site, which adjoins

the eastern edge Of Walsall and is contiguous with the

existing residential development is a logical, highly

sustainable and therefore obvious candidate for site

allocation in the Core Strategy Review

1.9

The Site

The site which currently comprises agricultural land

split into a series Of fields, extends to approximately

37 8 hectares and is irregular in form The land gently

rises from the northern and southern edges to an

elevated central area The greater part of the western

boundary abuts existing residential development,

fields abut the remainder of the site to the west/north

west whilst the Daw End Branch canal defines the

north/north east edges

1 10 The southern edge of the site is contained by the A454

Aldridge Road, which for almost the full length of the

site's southern edge is dual carriageway and includes

a traffic island which provides access to Calderfields

Golf Club and the Dilke pub/restaurant which are to

the south

Bloor Homes currently controls the land as illustrated in

the Site Location Plan (Figure 01:01 ) and is committed

to the delivery of a high-quality, contextually responsive

and comprehensive residential-led scheme providing

much needed new housing and community facilities

for the local area

1 12 As we go on to discuss in this document, the site


2.0 Creating a new Gateway & Garden Suburb


• the foundations on which Garden Cities are founded;

• how current best practice (New Urbanism) has

delivered recent schemes which have a similar

ethos;

• and, thus how those principles need to be updated

and renewed-

The following narrative addresses the above bullet

points in order to aid our informed development Of the

masterplan for Stencils Farm

Evolution of the Garden City

2 10 Garden Cities were initially

A New Sustainable Urban Extension

2 1 Bloor Homes wishes to work closely with the BCA and

other key stakeholders, including the local community,

in order to deliver a comprehensively planned

development Of the highest quality at Stencils Farm

This site will create a new sustainable urban extension

in the form of a Garden Suburb The development

shall flow with the existing topography and respect the

existing landscape features to create a 21st Century

Garden Suburb on the north eastern edge Of Walsall

2 2 n response to the local policy setting Of the Green

Belt and the need to ensure a strong green gap is

preserved between Walsall and Aldridge, a Garden

Suburb with green credentials and high quality design is

proposed With this in mind, this chapter demonstrates

the thorough understanding and appreciation Of the

above requirements and the need to ensure that the

use of Garden City principles delivers a site specific

response in terms of a strong Vision and robust set of

development principles in order to inform the design

process-

2 3 This chapter clearly sets out the factors which need to

be incorporated and considered in the development of

the design philosophy, Vision and principles to ensure

it delivers a sustainable, contemporary, high quality

21st Century Garden Suburb-

Developing the Design Philosophy

24 The client and design team have spent time

considering the design philosophy that should

underpin the masterplan The site already has

a strong Green Infrastructure network within and

around it A sympathetic approach to development is

required, working with the grain Of the landscape The

following paragraphs therefore set out the evolution Of

the design philosophy which we have developed to

underpin the masterplan

e•SCAPE Urbanists has followed a 'landscape led'

masterplanning approach, whereby the existing site

features, topography and general flow of the landscape

and surrounding context govern the form and scale of

the development.

This approach is as much grounded in 'New

Urbanism' as any other New Urbanism in itself calls

on a rediscovery Of walkable neighbourhoods and

the priority of walking, cycling and public modes of

transport over private motor vehicles. The approach

thus allows streets to be taken back by communities

as social spaces, as opposed to domination by the

car

New Urbanism and its various off-shoots , appropriately

have their roots in the Garden City Movement of the

early 20th Century With the resurgence in interest

in Garden Cities, Towns, Suburbs and Villages and

the principles they advocate, the Government has

promoted the identification and delivery Of sites

across the country e*SCAPE Urbanists is working

on two nationally recognised Garden Villages, one in

Cheshire East and the other in Knowsley, Liverpool

These new Garden Cities, Towns, Suburbs and Villages

Will not be a slavish mirroring Of the previous centuries

Garden Settlements, but a contextual and site specific

reinterpretation of the Garden City approach, which

would pull together the best of the tradition, along

with lessons learnt from the last 10 to 15 years of

the 'Urban Renaissance' in the UK Thus creating

principles which enables an exciting, vibrant and new

settlement or neighbourhood to develop Such an

approach should advocate working with the grain of

the landscape in which it sits, create a place which

is not over-dense and places homes and facilities

Within a green environment In order to deliver a New

Garden Suburb we needed to understand:

211

conceived by Sir Ebenezer

Howard in 1898 and then

refined and applied to new

suburbs by Raymond Unwin

around 1909-1912

Unwin is clear that before any

design work is undertaken e_,

a full understanding of the

context, history, character

and site must be undertaken

to influence and guide development Unwin takes

Howard's somewhat rigid development forms

and creates more organic and site specific layout

responses, as is seen in his masterplan for Hampstead

Garden Suburb This site specific approach is also

seen at Welwyn Garden City (by De Soissons), where

the orientation of the main vista was aligned with three

ancient oaks

"TheGardenCity:Amoreharmonious

combination of city and country,

dwelling house and garden. '

is well-related to the existing settlement, contained

on all sides by the existing settlement edge (to the

west), the canal (to the north and east) and the A454,

Aldridge Road (to the south) A Garden Suburb style

development at this site would be a logical sustainable

urban extension, if sympathetically designed


2 12 The Town and Country

Planning Association (T CPA),

formerly the Garden Cities

Association has produced a

numberofpublicationsrecently

promoting the rediscovery of

the Garden City concept, in

terms Of spatial and layout

planning 'Nothing gained by

ETCHWORT

overcrowding' and 'Creating

Garden Cities and Suburbs

today' not only celebrate

Howard's and particularly Unwin's approach to new

settlement/suburb design, but re-publishes Unwin's

original pamphlet and then seeks to update and

modernise the underlying principles they advocate

2 13 This promotion of the Garden Settlement, as a

sustainable approach to development, has been taken

on board and encouraged by national government

at the highest levels and recognised in the Nationa

Planning Policy Framework (NPPF, paragraph 72,

bullet point c) It should be noted that those original

Garden City Design Principles still hold true and that

the challenges they faced then; meeting housing

shortages, generating jobs and creating beautiful and

inclusive places are still as relevant now, although they

are joined by globalised markets and climate change

2 14 Garden Cities, Towns and Villages provide the

opportunity to address sustainable transport, low

carbon housing, local food sourcing and some form

Of community governance Whilst the Garden Village

should create a new settlement, with its own unique

character and be identifiable as something different,

it should also be welcoming, connect out to the

wider area and be highly permeable and accessible

to residents Of the existing local settlements, a

sustainable resource for all

2.0 Creating a new Gateway & Garden Suburb

Precedent & Best Practice

2 15 The formulation of the design principles should not

be worked up using theories and hypotheses, but

grounded in the real world by exploring best practice

With this in mind the design team has undertaken

a review of UK based successful modern urban

developments, that are located in similar situations,

in order to see how their approaches could be used

to inform the best practice approach at Stencils Farm-

2 16 A short case study review has been undertaken Of the

proposed development at Deanslade/Lichfield South,

Lichfield and the currently being built developments at

Upton, Northampton and Poundbury, Dorset as three

successful , but very different Urban Extensions, which

align with Garden City/New Urbanist development

approach

2 17 Summarised case study information is provided in the

following paragraphs

Case Study 1: Deanslade/Lichfield South,

Lichfield

2 18 Although conjoining the existing southem urban edge

of Lichfield and therefore forming more of an urban

extension, taken together these two developments,

which sit adjacent to one another and which form

strategic allocations in Lichfield's current plan will,

when developed, comprise some 1 ,OOO homes

and associated community facilities employing key

principles from the garden settlement movement

2 19 The combined allocation serves as a particularly useful

example to draw on not only because Of its relative

proximity in geographical terms to Stencils Farm

(just 7 miles as the crow flies) but more importantly

because of the key similarities that exist between the

two sites; both in terms of physical context and design

approach

2.20 Physical Context: Principally, the main parallel to

be drawn between Deanslade/Lichfield South (for

ease hereafter referred to as Lichfield South) and

Stencils Farm is the fact that both sites occupy Green

Belt locations (or rather Lichfield South did before its

al location for residential development within Lichfield's

Local plan Strategy and consequential removal from

the Green Belt)

2 21 When preparing its current plan (2008-2029) Lichfield

2 22

District Council found itself in a similar position to that

which the BCA find themselves in at present, namely

the pressing requirement to release Green Belt land in

order to meet its objectively assessed housing need

In a similar vein to the conclusions that the BCA have

already reached, spatially, LDC concluded that one

of the most sustainable locations to accommodate

housing growth within the district was on the edge of

Lichfield, particularly its southern side which enjoys

the best access to exlsting infrastructure and services

2 23 Like the major conurbations with the BCA, Lichfield's

southern edge is however constrained by the

Green Belt and thus in order to locate new housing

development in this most sustainable location, it was

necessary to remove a substantial quantum Of land

(some 83 5ha) from it

2 24 This need to locate new housing development in the

most sustainable locations in the district was key to

justifying the exceptional circumstances which are

required for Green Belt boundary alteration

2 25 AS set out previously, beyond this key overarching

point Of equivalence, Lichfield South shares a number

of other similarities with Stencils Farm which serve

to reinforce the appropriateness of its allocation for

residential development within the Black County Local

Plan Review.


2 26 By extending to the south of the city, the Lichfield

South extension will, when developed, reduce the

physical separation that exists between Lichfield

and the village of Wall which lies to the south west

Whilst the prevention of settlements merging is a key

purpose of the Green Belt, of particular note however

is the fact that the contours Of the site rise markedly

at its southern end thus preventing any inter visibility

between the two settlements

2 27 Consequently, there will be no visual indication of an

erosion of the separation that presently exists The

contribution that the site currently makes towards

checking sprawl and preventing the merging Of

settlements will be maintained

2 28 The land at Stencils Farm is no different in this respect

The land rises towards its northern extent which means

that when viewed from the A454 Aldridge Road, this

change in topography prevents any views beyond the

site itself; rending any views Of Aldridge impossible

2 29 The same is true when looking south toward the site

from the 84154 which lies beyond the site to the north

on the southern edge of Aldridge Views of the site are

not possible by virtue of the existing topography

2 30 By consequence, whilst the development Of the land

by existing physical features

2 32 Beyond the existing built form which lies to its north and

east and the elevated landform to the south, Lichfield

South is contained by Knowle Lane to the southeast

and Claypit Lane to the west. Similarly, there is strong

containment of the land at Stencils Farm by the Daw

End Branch Canal to the north/north east and by the

A454 Aldridge Road to the south

2 33 Furthermore, the containment would be strengthened

at both sites by the introduction of significant

landscaping enhancements to make the boundaries

concerned unquestionably defensible

2 34 AS far as the Green Belt and its recognised purposes

are concerned therefore, it is clear from the strong

parallels drawn in the preceding paragraphs that the

removal and allocation of land at Stencils Farm would

be entirely in accordance with recent best and local

practice for a development of a similar scale that has

been thoroughly tested, notonly through the Local plan

Examination in Public Process but a so subsequently

through the High Court

2.35 Key Development Principles: Driving the design of

Lichfield South is a need to place emphasis on the

physical and social integration of new development

with existing neighbourhoods so encourage the

widespread use of sustainable travel modes by

existing and new households to access local facilities

and the city centre The importance of the landscape

setting is key a determinant of the urban form and

development composition In addition, the concept is

founded on the fundamental need for improved east-

west connection through the southern part of Lichfield

City, and to accommodate a development designed

and built according to the principles of sustainable

development and good urban design

Figure 02:02 DeansIade,'LichfieId Smith Case Study Extract from the Lichfield

plan Strategy (200B - 2028) (1 of 3)

Figure 02:03 Deansladen_ir.hfield South Case Study Extrac-:t from Taylor Wimpey

Design and Accesg Statement: Farm, Lichflald -Application

231

at Stencils Farm will reduce the distance between

Walsall and Aldridge, this will not be apparent from

the ground owing to the existing topography The

purpose the land currently serves in checking sprawl

and preventing the merging of any settlement will

therefore remain unchanged

In addition to these topographical features which, as

demonstrated serve to significantly lessen the impact

of built development on the purpose that the Green

Belt designation would otherwise serve, both sites

share a similar level of visual and tangible containment

Figure 02, 04 Deanslade/l_ichfæld South Case Study Extract Taylor Design and Access Statement; Oeanslade Farm,


2 36 The transition between town and country and the

successful management Of this is a key philosophy

of the overall design so as to ensure the successful

integration of new development within the landscape.

The premise is that a sensitive configuration of

development at the urban edge will create attractive

views to the city as well as Out Of the city, and should

support access to the open countryside

2 37 The development will include:

• Varying densities which respond to a clearly

identifiable road hierarchy For example, high density

land parcels follow the main boulevards with lower

densities towards the south to aid the transition Into

the rural landscape via the parkland areas Of public

open space

• Appropriate responses to the local context Design

inspiration for the various house types is drawn

from Lichfield's rich and varied local vernacular The

development proposes key character areas within

the site to create interest and aid its legibility whilst

maintaining a strong and consistent approach to

architecture throughout

• A landscape/landform led response

The

development Will work with the key landscape and

landform features, notably the rising topography to

the south and the route of the yet to be restored

Wyrley and Essington canal toward the northern

end of the site

• Ease of access through the site via a range of

sustainable transport methods The proposed

development is highly permeable so as to take

advantage of the site's relative proximity to Lichfield's

existing infrastructure and services

2.38 In summary: The proposals for Lichfield South employ

key design principles from the Garden Settlement

ethos, using relatively low densities, a highly legible and


permeable layout with a strong and easily understood

hierarchy of boulevards, secondary routes, green

routes, lanes, public spaces and landmark buildings

rooted in a landscape-led design, rich in new planting

2 39 It works with the key landscape and landform features

of the site not only to ensure that the design responds

successfully to its context but also to ensure that as

former Green Belt land, its impact is suitably low

Case Study 2: Upton, Northampton

2 40 Located on the western edge of Northampton, Upton

is perhaps more accurately described as an urban

extension, rather than an autonomous urban village

in the true sense _ Nevertheless, in terms Of the

overall design ethos, Upton encapsulates many of the

key principles that underpin the Garden Settlement

movement, including the commitment to mixed-

use, sustainability, a strong green infrastructure,

quality streets and spaces, the creation Of walkable

neighbourhoods and locally inspired character

2.41 Key Development Principles: The underlying

philosophy for Upton was to promote sustainable

urban growth and create a distinctive and enduring

environment, including:

• Awide range ofhouse and apartment types has been

carefully integrated into the perimeter blocks Along

the High Street, taller ground floors are required to

permit changes in use as population increases and

small business use emerges

• A minimum Of 22% affordable housing Will be

provided, pepper potted throughoutthedevelopment

• Every building in Upton was being built to the

BREEAM Ecohomes Excellent' standard, prior to

its demise-

• A sustainable urban drainage system is being

used to manage rainwater run-off and rainwater

harvesting technologies are being incorporated

into block and building design The SUDS network


Figure 02:05 Case Study Imagery (1 2)

will also promote local biodiversity by allowing new

wildlife habitats to be established and by creating

an ecological network linking Upton with the Upper

Nene River Valley

• The design Of Upton draws inspiration from the

Northamptonshire vernacular, including local urban

morphology, architecture and landscape design

Upton is divided into four distinct character areas,

each with a clearly defined role and relationship

within the overall urban hierarchy

• To reduce reliance on cars, public transport facilities

were put in place early on in the development

• The SuDS allows a network of green fingers to

permeate through the site, connecting streets and

spaces

• A legible structure Of streets and blocks ink Upton

to adjacent developments and amenities such as

the Upton Grange and Princess Marina Hospital

developments, Upton Country Park, a supermarket

and other facilities at nearby Sixfields

• The local population will support a mix Of uses

including a primary school, local shops, and live -work

units Other commercial office, retail and community

uses will form a local centre along Weedon Road

2.42 In Summary: Upton has a strong urban character,

with most properties positioned hard against the

back Of pavement Most houses lack front gardens

This may seem at odds with the Garden Settlement

ethos which promotes generous green space and

a marrying of town and country In Upton's case, a

strong network of wide street swales, street trees and

public open space help to soften the built form and

introduce natural elements to the public realm

2 43 Upton is a pre-recession urban extension, is of a

higher density than that proposed at Stencils Farm

and the strong urban forms and enclosure of the

streetscape would not necessarily directly relate to

that proposed at Stencils Farm However the strong

green infrastructure network with its integral SUDs

system, a single principle co-ordinating development

partner and its general development principles would

apply just as easily

Case Study 3: Poundbury, Dorset

2 44 Poundbury is a Duchy Of Cornwall urban extension

on the western outskirts Of Dorchester Whilst it is

seen as an extension to Dorchester, the masterplan

has created a mixed use settlement which includes

not only homes, but local and district centres, focused

around a series of squares, which includes shops,

public houses, restaurants, offices and light industry

2.45 Key Development Principles: This urban extension

was created to provide a vibrant new settlement

integrating a broad mix of uses The settlement is

based on a traditional form of architectural and urban

design approach which includes:

• A strong hierarchy Of avenues, streets, lanes and

public spaces

• Well overlooked streets with active frontages

enclosed by buildings

• Use of existing mature trees as settings to open

spaces

• Buildings are set to rear Of pavement in many

ocations

• Buildings reflect many historic eras of traditional

vernacular

• Ahighdensity approachwithinmanyoftheresidential

neighbourhoods with a lowering Of density Out to the

peripheral, suburban fringes

• High use of rear parking courts and narrow lanes,

especially in the earlier phases

• Parking is set at 2 3 spaces per dwelling

2.46 In Summary: A single land owner has enabled a

strong vision to be created and implemented


2 47 Early phases pushed the car into rear parking courts

which caused some issues with residents in terms

of access between vehicle and property, as well as

the desire to be able to see their vehicles from the

windows Of houses Later phases Of development,

whilst still utilising parking courts aso provided on

street parking bays

2 48 Overall, the scheme is a positive example of urban

design principles in action, with a strong sense of

enclosure, use Of shared space, good permeability

and a high quality use Of materials, detailing and

construction

Lessons Learnt for The Garden Village

2 49 All the settlements provide useful information to

inform the emerging masterplan at Stencils Farm

The lessons learnt are set-out below:

• Strong development lead with a single Vision in

order to deliver a settlement Of high quality

• Good, contextually led masterplanning is key

• Creation of a legible layout with strong communal

areas of public realm

• Good integration with the adjoining existing

settlement and landscape

• Strong, consistent approach to architecture which

provides variety and choice, but without creating a

riot of styles across the settlement

• Landscape and public realm is just as important as

the architecture

• Use existing landscape features to create a sense

Of place and maturity

2 50 Design alone will not create a community and needs

to be supported by a strong social strategy to establish

structures in the form of neighbourhood forums, along

with encouraging more social interaction through local

interest groups, hobbies and work parties etc


Figure 02:08 Poundbury Case Study Imagery (2 of 2'!

Figure 02:07 Poundbury Case Study Imagery of 2)

Creating A Strategic Gateway

2 51 Based on the above appreciation of the Garden

Settlement Movement and recent best practice as

described above, the site is well located to create

a new Garden Suburb as part Of the wider Walsall

conurbation But not only a suburb be new gateway

into the town as described below

2 52 Walsall has eight strategic routes into the town from

the surrounding settlements, as illustrated in Figure

02:05 The A454, Aldridge Road connects the large

settlement Of Aldridge with Walsall Stencils Farm

creates the ideal opportunity to create a strong and

positive gateway into the town from the north east

2 53 The 'Aldridge Gateway' would provide a positive,

welcoming and outward looking, finished edge to the

town from this approach

2 54 The new Green Belt boundary would be well protected

by the canal and the on-site ecological buffers to

create a well defined boundary and strong green gap

between Walsall and Aldridge

2 55 The Garden Suburb represents a very special

opportunity to showcase what Walsall can achieve in

a partnership between the public and private sectors

2 56 The residential-led mixed use development at Stencils

Farm will provide a strong, cohesive and strategically

logical opportunity for Walsall to meet the demands of

a growing population

Figure 02:09 Creating a Strategic Gateway – The Aldridge Gateway

A Vision for the Stencils Farm Garden

Suburb

2.57 Our Vision for Stencils Farm has sprung out of the

appreciation of the surrounding context and features

Of the site itself as set Out in detail is Chapter 4, with

the Vision itself explored at the start Of Chapter 5

However the panel to the right summaries that Vision:

2 58 This new neighbourhood will create a sympathetic

and high quality development set into a strong and

bold network of green spaces, wildlife corridors,

habitats and recreational footpaths/cycleways All

these elements form an integral part Of the Green

Infrastructure network, linking the site to the local

facilities, adjoining suburbs and countryside via the

already identified wildlife corridors which run through

the Whole borough of Walsall (see Figure 03:01 in the

following chapter)

2 59 The masterplanning team has carefully considered

all the opportunities and constraints to inform this

development framework, which demonstrates that

the site can comfortably accommodate a sustainable

neighbourhood ofaround 700 dwellings The proposals

will enable the provision Of a network Of public open

spaces for use by the existing and new members of

the community

2 60 The result will be a sympathetic, sustainable and

integrated Gateway neighbourhood on the north

eastern edge Of Walsall, within a logical Green Belt

release site, creating a strong addition to Walsall and

complementing the surrounding neighbourhoods

2 61 What also comes out of the understanding of Garden

Settlement and New Urbanists best practice is a set of

site-specific development principles Which are set-

Out over page, under a series Of over arching theme

headings


"Bloor Homes' Vision for Stencils Farm will create a new sustainable urban extension

on the north eastern edge of Walsall.

The new neighbourhood shall create anew high quality, welcoming and outward

looking gateway into the town and Will-be designed following the principles of a 21st

Century Garden Suburb

A network of green spaces, wildlife corridors, habitatS änd recreational footpaths/

cycle ways will be developed Within the proposed extensive 'Green-Infrastructure

network.

The Avenues, Streets, Greens, Mews and Squares shall be enclosed and overlooked

by the homes, schools ahd Shops, creating a heart and focus to the neighbourhood.

The neighbourhood will develop its own unique character and contain a choice and

variety of homes. The fringes-of the neighbourhood shall use a range of outward

facing detached properties,' using a rural materials palette to' create a softer and

more rural fringe, enabling it to blend and blur into the open countryside.

This organic approach works with the grain Qf- the existing landscape and

Sympathetically overlays development. It will quickl mature and become a part of

the setting and character of the wider town.

The Stencils Farm Garden Suburb Development Principles

1. Social

C reatean inc usive, diverse and eq ual neighbou rhood

Deveop a oca centre, community faci ities & socia

pub ic rea m for residents to meet & socia ise

• Homes deve oped inamixoftenures, sizes &locations

to offer something for everyone

• Deveop flexib e homes to enable fami ies to become

Ong-term members Of this new community

Encourage a self-managing and self-sufficient

suburb

Set up of a Neighbourhood Forum to ensure residents

have a ong-term stake in their community

• Food production sha be encouraged through the

provision Of community orchards & a otments

Create a healthy neighbourhood

• Encourage wa king & cyc ing through the provision of

safe & direct footpath/cyc eways

• Promote outdoor, energetic & natura istic play, socia

interaction & opportunities for self- earning

2. Characterful

Create a distinctive suburb

• Create a new gateway into Wasa which is, outward

ooking, green & we coming

• Create a high qua ity, unique & contextua y sensitive

design

• Createa oca centre with fa vibrant focus at the heart

of the new suburb

Encourage a creative suburb

• Encourage the communityto garden, p ant & maintain

the orchards & a otments

• Deveop unique site branding and

dentity through

community invo vernent

4. Movement

Create a connected neighbourhood

Ensure the neighbourhood is permeabe & egib e in

terms of ayout, to encourage ease of access

Create a pedestrian friendly suburb

• Create shared surface anes & spaces where the

pedestrian takes priority over the private car

Create an accessible suburb

Ensure a user groups are catered for in the detai ed

design of the pub ic realm, allowing easy access to

the streets, pub ic ream & open spaces by people

with disabi ities, fami ies and the e derly

5. Economic

Create an adaptable suburb

Deve op flexibe homes with wi-fi & superfast

broadband thus encouraging working from home

Promote an integrated suburb

Encourage the use of the suburb for recreation,

shopping, employment, a otment food production,

community events, forma and informa education by

the wider community & visitors

• Provide strong inks & connections between the

suburb & adjacent neighbourhoods through fast

& efficient public transport systems, footpaths &

cyc eways

ncorporate art into the fabric of the deve opment

process

Develop a timeless suburb

• Deve op adaptab e bui dings which can grow &evo ve

with advances in technology

• Explore opportunities to encourage changes of use

& flexib e ground floor spaces for a temative uses

3. Environmental

Create a biodiverse suburb

Work with the existing andscape & eco ogica

features and habitats at Stenci s Farm

• Deveop a Green Infrastructure network which

connects habitats together encouraging colonisation

by native anima & p ant ife from the surroundings

Interpret the history and heritage Of the suburb

• Draw on the site's history & heritage in terms of

interpretation, signage & pub ic art

Promote a water sensitive suburb

• Uti ise the existing topography, ditches & ponds to

deve op a b ue infrastructure network

Create a we -managed surface water system

encouraging the use of the SUDS network by wi d ife

Develop an energy efficient suburb

• Use advances in insu ation, air tightness & renewable

techno ogies, as well as passive systems to create

an energy conscious & efficient environment

Exp ore the opportunities for energy & heat generation

to create an integrated energy network

3.0 Planning Policy Background

3.0 Planning Policy Background

Housing Need

3 1 As has already been set out in the preceding section

of this document, there is a significant supply shortfall

within the Black Country for the plan period 2014

2036 This shortfall stands at some 20,813 homes

including the 3,000 that the BCA have committed to

take from Birmingham's unmet need

32 It should also be noted that the identified supply

includes 6,408 'potential' homes, a figure arrived at

through assumptions made about windfall deliveries

and increased densities In reality therefore, there

remains the likelihood of the actual shortfall being even

greater than 20,813 homes should these assumptions

fail to materialise

33 Through its Issues and Options document and

subsequently through the Black Country Urban

Capacity Review (May 2018), informed by the Greater

Birmingham Housing Market Area Growth Study (Feb

2018), there is an acknowledgement that in order to

provide for its full objectively assessed need over

the Review Plan period, there is the requirement to

assess and revise existing Green Belt boundaries in

the Core Strategy Review. Without such revisions the

BCA will not be able to deliver the identified shortfall

34 Local housing needs arise across the Black Country

and in all parts of Walsall Borough

Green Belt Policy

3 5 paragraph 136 Of the National planning policy

Framework, (hereafter the Framework) makes it clear

that Green Belt boundaries should only be altered

where exceptional circumstances are fully evidenced

and justified, through the preparation or updating

of plans Clearly, the evidence and justification for

boundary review is place and the vehlcle for doing so

is the Core Strategy Review

3 6 When reviewing Green Belt boundaries, the

3.7

Framework, at paragraph 138 is clear, that the need to

promote sustainable patterns Of development should

be taken into account Furthermore, plans should give

first consideration to land which is well served by public

transport Plans should also set out ways in which the

impact of removing land from the Green Belt can be

offset through compensatory improvements to the

environmental quality and accessibility Of remaining

Green Belt land

When defining new Green Belt boundaries, plans

should, amongst other things: define boundaries

clearly, using physical features that are readily

recognisable and likely to be permanent

With this in mind the land at Stenci s Farm presents an

excellent opportunity to deliver some of the identified

housing need in a highly sustainable location without

undermining the identified purposes which Green Belt

land should fulfi

As the presented master plan makes clear, the site

immediately adjoins the existing eastern edge Of

Walsall and is well contained by the Aldridge road to

the south the Daw End Branch Canal to the north/

north east- The presence of these robust features

helps to contain the site both visually and physically

and will ensure that a long-term defensible new Green

Belt boundary is established

that would clearly restrict the further expansion of

the built form in these directions Thus, there is no

potential for unrestricted sprawl as a consequence of

the site's development Accordingly, in terms of the

site's current performance against this purpose, it is

concluded that it does not score highly

b) to prevent neighbouring towns merging into

one another

Aldridge, the settlement which is closest to the eastern

side of Walsall lies just over a kilometre away to the

north east Whilst the development would bring the

eastern edge of Walsall closer to Aldridge, there is no

risk Of any settlement coalescence on the basis that

the Daw End Branch Canal would easily and physically

contain the development site along its northern/north-

eastern/eastern edges Beyond the canal there would

remain a significant quantum of open agricultural land

in excess of half a kilometre in depth which would

clearly maintain the separation between the two

settlements

c) to assist in safeguarding the countryside from

encroachment

At a basic level there will inevitably be some degree

Of countryside encroachment as a result Of almost all

Green Belt land release Nevertheless, the proposed

development would simply infill a logical gap that is, as

we have already demonstrated, well contained Thus,

the site at present does not perform a particularly

strong role in safeguarding the countryside from

encroachment but owing to the physical features which

have been identified will, once developed, present a

robust settlement edge that would be difficult to extend

beyond

d) to preserve the setting and special character of

historic towns

The Stencils Farm site is not part Of, or adjacent to

3 10 The site has been assessed against the recognised

Green Belt purposes which are enshrined within the

Framework at paragraph 134

a) to check the unrestricted sprawl Of large built-

up areas

The site is well contained to the East, South, North

and West by existing houses, the Aldridge road, and

the Daw End Branch Canal respectively All these

features provide permanent and robust boundaries

any Conservation Area and does not contain any

listed bui dings ts development would not have any

impact on any such area or other designated heritage

asset Accordingly, the site does not perform strongly

against this purpose

e) to assist in urban regeneration by encouraging

the recycling Of derelict and other urban land

3 Il The BCA's acknowledge that there will be scope to

provide for some housing within the urban area but as

the emerging evidence base already acknowledges,

there is insufficient capacity within the Black Country's

urban areas to accommodate the level of housing

growth that is required during the plan period 2014 to

2036 Accordingly, the inclusion Of this site within the

Green Belt serves no real purpose in assisting in urban

regeneration because edge of settlement Green Belt

release is required in order to meet identified housing

need The development Of the site will be Of no

consequence to the development or redevelopment

of any smaller windfall site within the urban area

Green Belt purposes, a summary

3 12 As is evident from the commentary above the land at

Stencils farm does not perform strongly against any of

the framework's stated green belt purposes The site

benefits from strong physical and visual containment by

robust features which would prevent further expansion

of Walsall to the North East, East, and South which in

turn would prevent any risk of settlement coalescence

with Aldridge Furthermore, the topography of the site

is such that when viewed from Aldridge road no long

distance views are possible that the site is viewed

very much in its immediate context.

3 13 Whilsttherewill be some lossofcountryside as there will

with any greenfield site, the land at Stencils farm does

not perform any particular function in safeguarding

the wider countryside from encroachment- That said

the physical boundaries which contain the t site do

perform this function but the development of the site

prejudice the ability for smaller windfall sites to come

forward within the urban area

3 15 For these reasons, the site represents an obvious

would not prejudice them in any way

candidate for release as part of the BCA's overarching

Green Belt review in order to facilitate the site

development to provide for a significant quantum of

homes in a highly sustainable location in order to

assist in meeting the identified housing need across

the Black Country housing market area

4,

3 14 The BCA's already acknowledge that Green Belt

release will be necessary to deliver the quantum of

homes that are required Within the housing market

area and thus the exclusion Of this land from the

Green Belt and its subsequent development will not

4,

Figure 03:01 Site Released Green Belt & Related Designations

4.0 Working with the site
4.0 Working with the Site

Introduction

4 1 This site has been intensively farmed for many years

and has been used primarily for arable crops with

some livestock grazing to the smaller peripheral field

parcels.

4 2 There are remnants of the former field patterns and

areas of ecological interest in the form of native

hedgerows, associated watercourses, wetland flushes

and tree stands These existing features will form the

backbone of the Green Infrastructure network and

shall inform the layout of the proposed neighbourhood

43 e*SCAPE follow the principles of 'landscape-led'

masterplanning, whereby the existing site features,

land form and general flow Of the landscape and

surrounding context govern the form and scale Of

the development Indeed this approach is as much

grounded in 'New Urbanism' as any other

44 New Urbanism in itself calls on a rediscovery of

walkable neighbourhoods and the priority of walking,

cycling and public modes Of transport over private

motor vehicles The approach thus allows streets to

be taken back by communities as social spaces, as

opposed to domination by the car New Urbanism in

tum has its roots in the Garden Cities, Towns, Villages

and Suburb movement Of the early 20th Century

4 5 Such an approach works with the grain Of the

townscape and landscape in which it sits, creates a

place which has a varied mix and density of housing

and places homes within a green environment The

following paragraphs provide the material to aid our

understanding, Of the site and its surroundings

Appreciating the Physical Context

4 6 IndemonstratingthatthesiteatStenciIsFarmrepresents

an appropriate and logical location for development,

Bloor Homes is also seeking to understand how the

site interacts with the town, surrounding settlements

and countryside, so that future development can be

integrated into the townscape and landscape setting

This initial appreciation Of these various levels Of

context which include both the wider area and site, is

set out below.

Regional/Sub•Regional Context

As illustrated in Figure 04:01 the site lies on the

north eastern edge Of Walsall, adjoining the existing

settlement edge to the west, contained by Daw End

Branch Canal to the north and east and Aldridge Road

to the south

The site sits within a good communications network

within the West Midlands in the heart of the Black

Country. The site immediately adjoins the A454

Aldridge Road which provides direct and easy access

into Walsall Town Centre which is less than 1 5 miles

from the site and on to the M6 which is less than 3

miles to the west of the site

4 10 Walsall itself is located just 8 miles north west Of

Birmingham and 6 miles east Of Wolverhampton

4 11 Jobs and employment opportunities are available

ocally with the Walsall Business Park within walking

distance to the east of the site, the Aldridge Fields

Business Park in Aldridge just a mile to the north east

and the various business and industrial parks to the

west within Walsall

4 12 Aldridge Road links the site to Walsall and the M6

to the east, as highlighted above, and north east to

Aldridge, Brownhills and the A5

4 13 The nearest train station is located in Walsall town

centre with trains to Birmingham, Wolverhampton,

Crewe, Shrewsbury and Rugeley

Local Context

4 14 As stated above, the site sits within a good

communications network within the West Midlands

lying just to the east of Walsall Town Centre within the

A454 Aldridge Road corridor

4 15 The site ies in the metropolitan borough Of Walsall

and adjoins the established residential suburb of

Longwood

4.16 Historically Walsall emerged as a market town in the

13th Century and evolved from a village of just 2,000

people in the 16th Century to an industrial town Of

86,000 by the 18th Century

4 17 The town's industries have changed throughout its

industrialisation from coal and limestone extraction,

to metal working, leathergoods and more recently

plastics, electronics, chemicals and aircraft parts

4 18 The site is well located in terms Of the current

employment opportunities, being in close proximity to

the Walsall Business Park, Aldridge Fields Business

Park in Aldridge and the various business and industrial

parks ocated in Walsall, as illustrated in Figure 04:02.

4 19 Walsall is home to various departments from the

University Of Wolverhampton which are located in

the town centre and there are a variety of primary

and secondary schools located locally to the site

In addition a new two-form entry primary school is

proposed on the site to offer additional places and

capacity to the wider community

4 20 The Dilke Public Houseand Restaurantliesimmediately

across the A454, Aldridge Road from the site, with the

Calderfields Golf and Country Club just slightly further

south A good number of other public houses, cafes

and restaurants are located in the surrounding towns

and settlements

4 21 As illustrated in Figure 04:02, Walsall Town Centre is

Figure 04:01 Sub-Regional Context

Figure 04:02 Local Context

located just 1 5 miles from the site and offers a range

Of services and facilities including shops, pharmacies,

medical services, art gallery, museums, hotels,

restaurants and cafes

4 22 The site has a series of bus stops located along its

frontage with the A454, as illustrated in Figure 04:03

over page The services include the number 6, 7,

7A, 7S and 40 providing connections to Walsall Town

Centre, Aldridge, Sutton Coalfield and Castlefort and

the various stops in between

4 23 In planning terms the site currently lies within the

Green Belt as illustrated in Figure 04:02 but is well

contained by the existing settlement edge, canal and

Aldridge Road

4 24 As is clearly indicated by Figure 04:02, even if the site

is developed the remaining gap between Aldridge and

Walsall will be substantial at more than 600 metres

width to the site boundary In addition, the intention is

to provide a substantial linear eco-park along the site

frontage with the canal which will increase the width of

the separation to over 750m before any development

will occur

4 25 In summary therefore development on the site:

• would form part of a new gateway to Walsall•

• would create a strong green infrastructure network

and green corridor along the Daw End Branch Canal;

• create a new sustainable urban extension; and

• is enclosed by existing residential uses, the cana

and Aldridge Road which represents enduring

boundaries, which means there is no potential for

further expansion to the east

4 26 The proposed neighbourhood will be a residential

led mixed use urban extension, with a clearly defined

heart and a strong and active community

Site Constraints & Opportunities

Introduction

3 27 As stated previously, Bloor Homes believe in

developing proposals which complement the character

of the local area, working with the natural grain and

flow of the land and utilising existing natural and man-

made features, which will give our evolving designs

an immediate sense Of place and maturity

3 28 An important part of the masterplanning process is

to understand the site and surrounding context in

detail Desktop and physical assessments have been

undertaken by a mu ti-disciplinary team of consultants

to inform the development Of the opportunities and

constraints plan, which is il lustrated in Figure 04:03 over

page. A summary of that work which has informed the

formulation of the development framework is provided

below- In summary, no technical barriers preventing

the development Of the site have been identified

3 29 The site is bounded by the A454 Aldridge Road

to the south which is separated from the site by an

intermittent native hedgerow, woodland stands and

intermittent trees which provide some screening of

the site from the road

3 30 TO the east and north east the site abuts the Daw End

Branch Canal before the canal swings north away

from the site

3 31 To the north west the site adjoins open fields with the

Park Lime Pits Local Nature Reserve visible beyond

them

3 32 The eastern boundary consists Of the former Stencils

Farm and has an extant planning permission for

residential development This area and the adjoining

established residential properties will require a

sensitive treatment within the proposals for the site

Landscape & Visual Appraisal

Landscape Character

4 33 The site is located within the Barr Beacon and Aldridge

Fields Character Area (WL09) as documented by the

Black Country Historic Landscape Characterisation

document funded by English Heritage for the four

Black Country Authorities, including WalsalL The

document summarises the area as, "This area is the

most rural landscape in Walsall, with field systems

covering more than two thirds of its surface (although

recreational land is also important) Four fifths (80%)

of the area dates to before 1900 It is bounded on

almost all sides by settlement, and in the north-east

and south-east by the boundaries with Staffordshire

and Birmingham respectively"

4 34 The site generally accords with the more detailed

descriptions under the heading of Modern Character

and highlights that the area is characterised by

agricultural land and dispersed farms It acknowledges

that important recreational areas around Barr Beacon

are within the character area and this is located to the

south of the proposed development site There are

also three golf courses that were laid out in the 20th

century in the area such as Druids Heath in the north

Of the character area, the Great Barr in the south and

one adjacent to Walsall Arboretum in the west.

4 35 Farmland in the area is almost entirely enclosed field

systems and t is likely that the earliest of these were

created in the late medieval and early post medieval

periods through the piecemeal enclosure Of the open

fields which once covered most Of this area There

is some evidence of ridge and furrow earthworks

surviving, however some of these fields have been

subject to boundary loss, especially during the

20th century TO the east lie field systems enclosed

during the late 18th/ early 19th century, which exhibit

straight roads and boundaries typical of parliamentary

enclosure

figure 04:03 Site Constraints & Opportunities

4 36 Like the fields systems, the associated farms date from

many different periods The earliest have medieval

origins, although the oldest surviving farm buildings

date to around the early 18th century Others have

been rebuilt between the 18th and 20th centuries but

have much earlier origins

4 37 Two small clusters of housing lie in the centre of the

area One is a distinctive estate of large houses in

woodland at Bourne Vale, dating to the inter/ post

war period It was built on the site Of a landscaped

park belonging to Bourne Vale House. The Other is

a number of detached houses from a similar period

located on the Longwood and Erdington Roads south

of Aldridge

4 38 Also, south Of Aldridge, small areas Of woodland

survive - originating from at least the 18th or 19th

centuries Some of these are areas of former limestone

quarrying. A further survival is the heath land at Barr

Beacon, which is the only area of what had once

formed part of Cannock Forest to survive the planned

enclosures Of the 18th/ 19th century

4 39 The area Of proposed development is located at Land

at Stencils Farm, Aldridge Road, WalsaIL It is on the

north eastern settlement edge of Walsall within the

Birmingham Green Belt designation

4 40 The site which currently comprises agricultural land

split into a series Of fields, extends to approximately

37 8 hectares and is irregular in form

4 41 The land gently rises from the northern and southern

edges to an elevated central area The Park Lime Pits

Nature Reserve and Country Park bounds the site to

the north/north west whilst the Daw End Branch canal

defines the north/north east edges

4 42 The southern edge of the site is contained by the A454

Aldridge Road, which for almost the full length of the

site's southern edge is dual carriageway and includes

a traffic island which provides access to Calderfields

Photograph 01 • ViewNORth East from Aldridge Road roundabout across site

02: View North West from Aldridge Road looking

Photograph 03; View West from Lo

Photograph 04/05/06 on page 34

Golf Club and the Dilke pub/restaurant which are to

the south

4 43 The boundaries are mostly delineated by native

hedgerows with mature trees in groups or as single

specimens Within the boundaries the majority Of land

cover is taken up with arable fields bound by partly

removed hedges One of the hedge alignments to

the south is designated as a Site of Local Importance

for Nature Conservation An area of semi-improved

grassland is located to the south west and an area Of

wetland is adjacent to the northern boundary

4 44 The topography of the proposed development area

gently rises from the east to west from approximately

135m AOD to 150m AOD There is a Public Rights

of Way (FP Wa159) that travels across the site that

links Beacon Way to Aldridge Road on the southern

boundary. A Grade 2 listed bridge is within close

proximity (but outside of the site) to the north and

provides pedestrian access across the Daw End

Branch Canal

4 45 PGLA Landscape Architects have prepared a

Landscape and Visual Impact Assessment and

identified the landscape to be Medium High sensitivity

to account for the location ofthe proposed development

site within the Green Belt The assessment of the

potential effects on the landscape concludes that there

wil be a moderate major change in the landscape fabric

of the existing site as the proposed development and

associated infrastructure are introduced, however,

there is potential for any identified adverse effects

being further reduced over time as the planting and

landscape framework Within the site matures

4 46 The setting Of the site will benefit from the introduced

planting to infill the gaps in the hedgerows, particularly

on the southern and northern boundaries The proposed

development is likely to have an imperceptible

effect on the broad landscape character However,

the landscape proposals are also considered to

be potentially beneficial as they reflect the species

of the adjacent landscape and are consistent with

the Landscape Character description for the Black

Country

Visual Amenity

4 47 The site is located on mixed arable and pastoral

farmland with gently rolling landform to either side Of

a central ridge The the landscape is adjacent to the

eastern edge of the urban area of Walsall

4 48 Sensitive visual receptors are identified as being

localised to the western and northern edges accounting

for the interface with the existing residential area Of

Walsall and the Daw End Branch Canal which forms

a well vegetated and defensible boundary to the

development site The southern boundary is adjacent

to Aldridge Road

4 49 There is one public footpath (Wa159) that crosses

the proposed development site and travels north to

south linking Aldridge Road to the Beacon Way and

the B4154 just the south of Aldridge to the north of the

site There will be an obvious change in view to these

receptors as residential housing is introduced but the

landscape strategy outlines the mitigation measures

that will be introduced as part Of the development to

reduce any potential adverse effects on the visua

amenity of these receptors

4 50 Generally, the proposed development site is visually

the existing countryside The landscape strategy

will ensure that appropriate planting is introduced to

provide mitigation for any identified adverse effects

4 52 The visual assessment that has been carried out has

demonstrated that the proposed development will

have some general effects on the immediate visual

amenity along Aldridge Road and the Beacon Way,

however, views into the site are mostly localised to the

immediate vicinity of the site boundaries

4 53 The residential amenity Of the properties on Aldridge

Road, Mellish Drive and Stencils Road will undergo

varying degrees of change However, as the proposed

landscape structure planting and the proposals seek

to reinforce the screening, the residual effects are

deemed to moderate to negligible

4 54 The users Of the public footpath networks will

experience some moderate major effects to the visua

amenity at time of completion and the residual effects

are likely to reduce to minor moderate as the proposed

planting matures The long to medium view range

footpath network will experience negligible residual

effects due to the existing settlements, landform and

vegetation within the countryside

4 55 A substantial degree of visual separation will be

maintained from the south of Aldridge to the northern

built edge of the development due to intervening

vegetation and this will be further enhanced by

the separation provided by the planting within the

introduced linear park immediately south of the canal

on the development side

456 Generally, it is not considered that any long term

significant adverse effects will pervade in respect of

the likely impacts on the landscape character and

visual amenity

4 57 Although any major development on a green field

site will result in some landscape change, the LVIA

concludes that 'the development is likely to have

451

well contained when viewed from further afield Views

from the west and south are screened by the existing

Walsall settlement and from the north and east by

Aldridge and the vegetation on the 84154 roadside

and within the hedgerows in the landscape and cana

corridor-

t is likely that some immediate views are achievable

into the site from Aldridge Road and to some degree

from Walsall Road to the east, but these wil be sporadic

and limited due to the landform and vegetation within
[Photographs 7-12]
an imperceptible effect on the broad landscape

character' and whilst there 'will be some general

effects on the immediate visual amenity along

Aldridge Road and Beacon Way, views into the

site are mostly localised to the immediate vicinity

of the site boundaries.'

Existing Vegetation & Trees

4 58 A remnant field pattern of native hedgerows sub-

divides the site into a number of field compartments,

as illustrated opposite Most of the hedgerows are

very gappy and heavilyflailed However, the hedgerow

which forms the Site Of Local Importance for Nature

Conservation (linear) as illustrated in Figure 04:03, as

the designation suggests is physically of a better form

and creates an important feature in the landscape of

the the site currently All hedgerows shall be integrated

into the development where possible as part of the

green infrastructure network

4 59 A number of mature native trees are located either

within the hedgerows or fields and create a setting for

the site and wider landscape

4 60 The trees and hedgerows combine to filter views of

the site from the wider area and all shall be retained

where possible with only shorts breaks being created

through the existing hedgerows to allow access

between the field compartments

Drainage & Flood Risk

4 61 The site has been subject to a preliminary flood risk

assessment and consideration of the surface water

drainage discharge options Infiltration potential

and foul water discharge solutions have also been

considered

Fluvial Sources

4 62 Several watercourses are situated within reasonable

proximity ofthe site Notably the Daw end branch canal

is the largest river in the vicinity and it flows along

the eastern boundary of the site A further small water

course channel is shown to flow from the larger of the

two lakes that are situated within the park lime pits

local nature reserve which lies some 0 4 km beyond

the north west boundary Of the site

4 63 The entire development site is located within flood

Zone 1 based on the EA's mapping and thus has a

less than 1 in 1000 annual probability of river or sea

flooding in any year. Thus, it has the lowest probability

of flooding as defined in national planning policy

4 64 Whilst the site also ies in close proximity to the

Daw End Branch Canal, the management Of this

watercourses is such that it presents an extremely low

risk of flooding

4 65 Furthermore, the topography of the site is such that it

increases as progress is made away from the existing

watercourses which consequently provides additiona

flood resi ience

4 66 Accordingly, it is asserted that there is an extremely

low risk of flooding from both natural and artificial

fluvial sources

Pluvial Sources

4 67 In terms of surface water flooding, the Environment

Agency's maps indicate that the majority Of the site is

in an area classified to have a very low risk Of surface

water There are a limited number of areas

within the site that are affected by surface water

flooding, it should be noted that all accumulations/

flow paths are shown to flow away from the site in

accordance with the local topography Thus in terms

Of establishing an overall risk Of flooding from surface

water sources, it is concluded that the risk is a low

one

4 68 Nevertheless, preliminary mitigation strategies have

been explored in order to deal with any residual

risk Firstly it is recommended that developed areas

of the site are prioritised on elevated land and

situated away from any local drainage ditches Site

boundaries, where surface water flooding may occur

would be best suited to areas of public open space

which could also include the provislon Of sustainable

drainage features Secondly, it is proposed that the

development will include a positive surface water

drainage system that will intercept the majority of run-

off generated within the site itself This will minimise

the risk to new buildings in addition to reducing the risk

to others across the wider area The overall effect will

be to provide a significant reduction in surface water

flow rates post development through the utilisation of

this sustainable drainage system

4 69 In addition to potential sources of fluvial and pluvial

flooding, the drainage assessment also considers

the development site's infiltration drainage potentia

Desktop research reveals that the ground conditions

are however such that infiltration based drainage

is unlikely to be suitable Nevertheless, infiltration

testing will of course be undertaken to further explore

the potential for drainage by this mechanism as the

development site progresses through the plan making

process

4 70 In terms of foul water disposal, initial investigations

suggest that a pumping station will be required to

convey flows to public foul sewers which are assumed

to be present within the Aldridge Road to the south Of

the site

4 71 Accordingly, the preliminary drainage and flooding

assessment concludes that the site is at low risk

of flooding from both fluvial and pluvial sources

and that there are no particular constraints which

indicate that subject to a suitable sustainable

drainage strategy, any sources of flooding could

not be satisfactorily mitigated.

Ecology

4 72 Preliminary ecological assessment of the site has

been undertaken In the main, the site comprises two

grassland fields in arable use which are of relatively

limited ecological value The field in the south west

corner of the site is less intensively managed however

and does present the potential to support reptiles

Their presence would be confirmed by further survey

work

4 73 Ordnance Survey mapping also indicates that a pond

is located in this south west area too but initial survey

work indicates that it is likely to only hold water during

very heavy rainfall events There is an absence Of any

wetland vegetation here and there are no records of

any Great Crested Newts (GCN) within the local area.

Nevertheless, should this pond hold any water during

the GCN breeding season, further survey work should

be undertaken

4 74 Confirmed wetland in the northern part Of the site

holds the greatest ecological value This presents an

opportunity for retention and enhancement as part of

the development proposals

4 75 The field margins support a range of box cut

hedgerows and thick tree belts containing a number

Of mature specimens These margins provide foraging

opportunities for bats and accordingly, further survey

work will be undertaken to establish activity and

mitigation as necessary further survey work will be

undertaken to confirm the extent and importance of

this sett and any others

4 76 In summary, through further survey work and

appropriate mitigation the existing ecological value

Of the site can not only be safeguarded but there

are numerous opportunities for enhancements

across a wide range of flora and fauna

Heritage & Archaeology

4 77 The development site has been subject to a

comprehensive desktop heritage assessment

undertaken by Orion Heritage which, in accordance

with the Framework draws together all available

archaeological, historic, topographic and land-use

information to clarify the heritage significance and

archaeological potential Of the site

4 78 There are no designated archaeological assets

within the site or indeed within the wider area which

surrounds the site such that their significance would

be impacted by the proposed development

4 79 Whilst there are designated heritage assets to

southwest Of the site, namely the registered Park

and Garden of the Arboretum and the Arboretum

Conservation Area, the site does not form part of

the setting of either of these designated heritage

assets and furthermore does not contribute to their

significance

4 80 The Daw End Branch of the Wyrley and Essington

canal which contains the site to the north east/east is a

non-designated heritage asset As has already been

set out within this document, it significance will not be

unduly impacted as a result Of the development rather

it presence has informed the masterplanning Of the

site, increasing the opportunities which are available

to the public to enjoy it by improving the accessibility

to it from the public realm and ultimately safeguarding

its setting by virtue of the development of a eco-park

adjacent to it along the site's north eastern/eastern

boundary

4 81 Although no physical archaeological investigation

of the site has taken place, desktop research has

revealed that there may be the remains of a World

War Il camp within the site and further archaeological

investigation will be undertaken as the plan making

process continues

4 82 Nevertheless, on the basis of the historical

information that is available, Bloor Homes heritage

consultant concludes that there 'are unlikely to be

any archaeological assets within the site of such

significance that would preclude or constrain

development or adversely affect the deliverability

Of the site.'

public Rights Of Way

3 83 A Public Right Of Way cross the site roughly from north

to south as illustrated in Figure 04:03 and connects the

site up to the fringes of Aldridge and the tow path of

the Daw End Branch Canal The majority of the route

will be retained on its current alignment and within a

green corridor-

3 84 Additional connections to the public right Of way

and the canal tow path will be created through the

proposed extensive green infrastructure network to

ensure the site is permeable and well connected to

the surrounding areas

Access & Movement

4 85 The development site's immediate proximity to the

A454 Aldridge Road to the south, provides obvious

and easily accessible means Of connection to the

existing highway network To this end, Waterman, the

appointed transport consultant concludes that 'a safe

and technically sound solution, which achieves

the necessary visibility splays can be delivered.

The site will integrate directly into the existing

footpath network.' Further, there are not considered

to be any particular concerns in relation to the capacity

of the existing network to accommodate the trips that

the proposed development would generate

4 86 More specifically, the access strategy would include

the provision Of two vehicular accesses from Aldridge

Road, the first comprising an additional arm from the

existing roundabout, the second a new a priority T

junction further to the east

4 87 Not only is the ability for the site to connect to the

existing transport network excellent, the site also

enjoys excellent sustainability credentials A total Of


five bus services serve the immediate area providing

access to various areas within Walsall as well as

Aldridge and Sutton Coldfield The two nearest bus

stops to the site are approximately 120m and 260 m

away from site to the south and east respectively

4 88 Furthermore, Walsall has been identified as a Sprint

Corridor' destination from Birmingham city centre

along the A45 It is anticipated that this service

will be operational by 2022 in order to support the

Commonwealth Games and will incorporate some

20 stops in each direction with the journey time

being around 40 minutes with priority given to 'Sprint'

services at traffic signals

4 89 The site also enjoys close proximity to Walsall railway

station which is approximately 2 % km away- There are

direct services to Birmingham New Street, Rugeley

Trent Valley and Wolverhampton on a frequent basis

4 90 The site is evidently well located therefore to allow

easy access to public transport options thus reducing

reliance on private motor vehicle use

4 91 The transport assessment has also analysed the site's

accessibility to various amenities and facilities within

its proximity including those relating to education,

healthcare, employment, leisure and retail

4 92 There are 9 infant and primary schools and 4

secondary schools within 3 km of the development

site It should also be noted that the development is

likely to incorporate a primary school Of its own in order

to cater for the educational needs that a development

of this scale will give rise to

4 93 In terms of health care, the most accessible primary

health care facility is just some 3 1Km from the

development site

4 94 There are retail/leisure facilities and employment

opportunities in abundance within Walsall itself

as well as within the centres of Birmingham and

Wolverhampton which are clearly within sustainable

travel ling distance

Residential Amenity

4 95 Existing residents who front or back onto the site will be

considered in the design and layout of the proposals-

Landscape buffers shall be used to create a stand-

Off from the sensitive boundaries and built from Will

be set back to ensure minimum overlooking distances

are exceeded

Wider Green Infrastructure Network

4 96 The internal green infrastructure network as illustrated

in Figure 04:03 shall be retained, as will its connections

out to the wider area

4 97 This network shall form the structure Of the proposed

layout and provide not only a backdrop to the proposed

development, but also links between surrounding

wildlife habitats and the site to ensure good connectivity

is maintained in the form of wildlife corridors into and

through the proposed development

Photograph 14

5.0 Creating a New Neighbourhood

Figure 05:01 Parameters Masterplan

51

A Vision for Land at Stencils Farm

Outofthis contextual appreciation of place and analysis

of the site springs our Vision The development of this

site will create a sustainable urban extension on the

north eastern edge Of Walsall_ The development shall

integrate and become part of the existing settlement

pattern of the town, whilst also being bounded,

enclosed and softened by the retained hedgerows,

associated trees and new complimentary native

planting

The development shall create a new high quality,

welcoming and outward looking gateway into the

town This new neighbourhood will be designed

following the principles of a 21st Century Garden

Suburb, developing a new neighbourhood which

creates a series Of high quality green spaces These

green spaces, along with wildlife corridors, ecological

habitats and recreational footpaths/cycleways will

be developed within an over arching and extensive

Green Infrastructure network, linking the site to the

local facilities, Wider settlement and countryside, as

well as buffering the site from the wider Green Belt

This new Garden Suburb will be focussed around

the Open Spaces, Mews and Squares and shall

be enclosed and overlooked by a mix of homes,

school and shops, creating a heart and focus to the

neighbourhood, utilising existing features such as the

trees and hedgerows as focal features within them

The neighbourhood will develop its own unique

character and contain a choice and variety of homes.

The fringes of the neighbourhood shall use a range

of outward facing properties, using a rural materials

palette to create a softer and more rural fringe,

enabling it to blend and blur into the open countryside

This approach works with the existing landscape,

sympathetically overlaying development which will

become a part of the character of the wider town

An evolving masterplanning process...

Developing a visionary and unique masterplan, if

done correctly, is an iterative process Initial ideas

develop out of the site's own context, constraints

and opportunities, as touched upon in the previous

chapter

That initial process provides a logical structure and

framework for the masterplan and also, as further

work is undertaken and discussions are held with

stakeholders on ecology, movement, landscape, the

appreciation Of the local character and vernacular, our

understanding develops of the historical evolution and

development of the surrounding settlement Additional

layers of detail can then be added in terms of layout,

access, hierarchy of streets and public realm, detailing

Of the built form, matenals and landscape.

Creating a Place

n order to deliver the Vision, the masterplan must

take account of the site's context and constraints and

turn them into opportunities for use in developing the

proposals. The parameters masterplan illustrated here

in Figure 05:01 is the resut Of that process These

opportunities emerged out Of the earlier contextual

and constraints work and provided the foundation for

the masterplan The following paragraphs describe

each building block

use and Quantum

The masterplan illustrates residential led development

complimenting the surrounding established use mix,

set within a network Of Green nfrastructure The

site in total is circa 37 80 hectares and will include

some 19 34 hectares of residential development, a

Two Form Entry School (2 0 hectares), Local Centre

(0 64 hectares) and 15 82 hectares of Green and Blue

Infrastructure which will include woodlands, wetlands

and grasslands, incorporating naturalistic play areas,

orchards/allotments, cycle routes and nature trails

5 10 This new neighbourhood would contain a range of

511

housing densities, offering choice and variety in terms

of locations and size of homes Densities would vary

from the fringes at circa 18 homes per hectare up to

55 homes per hectare at its heart This varied density

would roughly equate to a net average of 36 homes

per hectare, or a gross density of around 20 homes

per hectare

Layout and Movement

The layout has emerged from the earlier constraints

and opportunities work as set-out in Chapter 4

Figure 05:01 illustrates how the trees, wetlands and

topography have been used to provide a starting point

for developing a layout for the sites These drivers

have been used to establish a route hierarchy that

forms the basis of the design The primary element


Figure 05:02 Illustrative Masterplan


is the Main Avenue which would be flanked by street

trees and creates a bold green avenue from the main

gateway right through the centre of the site

5 12 Running from the Main Avenue there is a Secondary

Avenue which could be used as a looping bus route

into the site connecting the Main Avenue out to the

proposed primary school and provides a secondary

access back onto Aldridge Road

5 13 A number of Streets and Lanes feed off the avenues

and form the movement network based around

traditional Streets, shared surface Lanes and Mews

style spaces Where these routes intersect; raised

thresholds, public squares or landscape features will

be introduced to aid legibility and reduce traffic speeds-

The layout is also designed to ensure pedestrian and

cyce permeability There are clear opportunities

to link into surrounding footpaths, towpaths, open

spaces and other routes, thus ensuring that maximum

permeability and integration is achieved

Scale, Mix and Massing

5 14 It is proposed that approximately 700 homes can be

accommodated on the site The proposals have the

potential to provide a range and choice Of housing

from one and two bedroom apartments to larger more

aspirational 4 and 5 bed detached housing

5 15 The form of the adjoining neighbourhood suggests

principally 2 storey (between 8 to 10 metres to

ridgeline) development would be appropriate

However, in order to create interest in the streetscape

and roofscape appropriate increases in scale could be

used at principle junctions, within mews and around

key green spaces to aid legibility and enclosure

Landscape Strategy

5 16 The development of the layout for this site has taken

the existing green infrastructure into account to provide

a landscape led mixed use development set within a

substantial landscape framework

5 17 There are significant opportunities for new tree

planting and landscaping within the site, and infill

planting especially on the western interface with the

existing settlement edge Of Walsall and the southern

boundary adjacent to Aldridge Road The hedgerow

adjacent to Aldridge Road will be enhanced with infi

planting and groups of native trees Furthermore, it

is proposed that a substantial tract of public open

space in the form of a Linear Eco-Park is located to

the north and west Of the site and school playing fields

surrounded by woodland to the south eastern section

of the site This will provide a substantial landscape

buffer offering visual separation from the landscape to

the north of the Daw End Branch Canal

.1

Impression of the Main Avenue looking North

5 18 The overall elements of the landscape strategy for the

site can be summarised as follows:

• Retention of the existing elements that make up the

site's green infrastructure, such as trees and hedges

and integrating these into the development, giving

the scheme an immediate sense of maturity;

• Ensuring the gaps in the existing hedge adjacent to

the boundaries and Aldridge Road are in-filled with

native trees and hedge planting- Evergreen species

Of holly should be included in the mix to provide

effective screening through the winter months;

• Ornamental and native hedge planting to be planted

in and around the proposed development to soften

the adverse effects of the built form


Aerial impression looking North West across the site from Longwood Bridge

5 19 A range of trees to be introduced to reflect the street

hierarchy including the central avenues, crescents,

squares and mews Native trees should be planted in

the Linear Eco-park and general perimeters including

areas Of public open space and school

5 20 The landscape strategy has been taken into account

when considering the mitigation for the identified

potential adverse landscape and visual effects arising

at the operational stage of the proposed development

and these have been reflected when considering the

overall residual effects

Public Realm and Hard Landscape

5 21 The hard landscape materials palette also reflects the

spatial hierarchy and patterns of movement through

the development. Avenues and Village Streets will be

designed as traditional roads, with the Lanes, Mews

and Squares designed as more intimate, human scale

spaces where pedestrian movement takes priority

over motorised vehicles

From Concept to Masterplan

5 22 Demonstrating this staged approach to developing the

masterplan clearly illustrates our thought processes

from first principles in terms of appreciating the local

context, design philosophy and the utilisation of the

site's own unique features to guide the development

Of the masterplan structure

The Illustrative Masterplan

A Legible Hierarchy

5 23 The hierarchy Of routes, as touched upon previously

is expanded on here and illustrated in Figure 05:02

opposite In effect, the development should be legible

and permeable; a visitor should be able to find their way

around the development intuitively by understanding

the importance Of the streets and spaces through

which they are moving

5 25 The Main & Secondary Avenues are at the top of the

route hierarchy The Main Avenue provides the main

access in the form of a broad tree lined linear green

space into the residential areas from the gateway and

also provides a green setting for the existing Public

Right Of Way as it crosses the site

5 26 The Secondary Avenue provides a link to the school

and a potential route for a diverted bus service into

the site In addition, it also provides access to the

proposed new primary school

Impression of the Crescent Icoking West

5 24 A movement and street hierarchy has been developed

and is set out below in the order of importance:

• The Main & Secondary Avenues

• The Squares, Mews & Crescents

• The Streets & Lanes

• The Shared Drives

5 27 The built form is set back from the road, allowing

sufficient room for the planting of street trees These

add scale to the streetscape and reinforce the green

character Of the development

5 28 The Squares, Mews and Crescents are at the heart

of the development and are fronted and enclosed by

the homes which surround them, with corner buildings

rotated to focus views onto the central spaces

Designed as a piece of public realm or green space,

rather than a traditional road, they provide a focus

within the development for residents and other users

5 29 The Streets and Lanes are the secondary access

routes, linking the Avenues into the heart of the

residential areas The Streets and Lanes will be a mix

Of traditional roads and shared surface areas The

scale is a more domestic feel, as the built form is set

slightly closer to the road and street tree planting will

incorporate smaller growing species Gardens will be

enclosed by native hedgerows

5 30 The Shared Drives are the lastelementin the hierarchy

Of access routes They are domestic in nature,

designed as a simple shared surface route which

provides access to only a small number of properties

along its length and often connects onward into

pedestrian/cycleways at its end Traditional upstand

kerbs and raised pavements are also avoided to

create a more seamless transitional space between

the residential properties and the landscape beyond

This approach also assists with the SuDS strategy by

facilitating the movement of surface water flows from

the roads onto grassed transition strips and from there

to swales and the wider drainage system

Secured by Design

5 31 The layout responds to Secure by Design principles in

terms Of maximising the opportunities for overlooking

of the streetscape, public realm and open spaces

from habitable rooms The streets and spaces are

designed to be legible in terms of movement and their

public, semi-private or private nature Pedestrian/

Cycle routes are safe, secure, overlooked and direct

to ensure they reflect the aspirations for the reduction

Of the occurrence and perception Of crime

Sustainable Urban Drainage Strategy (SuDS)

5 32 The SUDS is part Of the Blue and Green Infrastructure

network and has six site specific objectives:

• To efficiently drain the site whilst not causing flooding

down stream,

• To create suitable habitat for amphibians,

invertebrates, birds, mammals, native aquatic and

marginal plant life,

• Create ecological corridors across the site to enable

wildlife to move more freely and native plants to

spread and colonise the wider area,

• Create an aesthetically pleasing setting for

development,

• Promote the site as a sustainab e place to live and

work,and,

• Use SUDs features at property boundaries as part

of the approach to Secure by Design

In Summary

5 33 In essence the Illustrative Masterplan takes the

constraints, Vision and parameters and demonstrates

that the proposals will create an integrated extension

to the settlement, set into the existing landscape,

creating a high quality addition to the town, offering

much need homes and choice to the local community

534 As illustrated in Figure 05:04 the Stencils Farm

proposals will have a minimal effect on the purpose

of the retained Green Belt between the proposed

Sustainable Urban Extension and Aldridge to the north

east, with a gap of 700 metres between Aldridge's

settlement fringe and the first homes on the site set

behind the proposed ecological buffer


Figure 05:04 Retained Green Belt Wedge


6.0 Summary

The BCA have an urgent need to identify strategic sites

to deliver a significant number of dwellings outside of

the existing Black Country Urban Area There is an

acknowledged need to release land from the Green

Belt to achieve this and at the time Of writing, Green

Belt Review across the Black Country is ongoing to

assist in the site selection process

The land at Stencils Farm is well placed to assist

in meeting this need and this Vision Document has

demonstrated through detailed Landscape and VISual

Impact assessment work and carefully considered

landscaping, that the site can be released from

the Green Belt without compromising the strategic

purposes of including land within it

Indeed, the development of the site, representing a

logical extension Of the existlng urban edge on the

eastern side Of Walsall along a major arterial route

which serves the city, echoes many of the historical

development patterns that are seen across the

Midlands region

The Site could deliver a significant quantum Of housing

to meet the BCA's need and for its size, it is in the

relatively unique position of being under the contro

of just one land owner which will facilitate its efficient

and rapid delivery This will be in partnership with just

one housebuilder possessing a strong track record

for developing quality homes, neighbourhoods and

ultimately communities

A safe and suitable access solution can be delivered

from the A454 Aldridge Road to the south comprising

two separate access points, one from the existing

traffic island, the other from a proposed priority T

junction to the east The site enjoys excel lent proximity

to public transport links and is well catered for in terms

of the number of existing services which operate in

the locality

Aerial impression looking North West across the site from Longwood Bridge


6.6

6.7

Having been thoroughly tested, the site is confirmed

as being at an extremely low risk of flooding from both

fluvial and pluvial sources Nevertheless, the technical

work carried Out to date indicates that there are an

absence Of constraints which would mean that subject

to a suitable sustainable drainage strategy, any sources

of flooding could be satisfactorily mitigated

Preliminary assessments have been undertaken in

respect of technical matters such as archaeology

and ecology and subject to suitable mitigation, these

assessments confirm that the site is wholly suitable for

development

The various constraints and opportunities that have

been assessed have been used to inform an indicative

masterplan which follows the principles Of the garden

suburb movement to deliver some 700 homes, significant

new areas of public open space, green infrastructure

network, a primary school and local centre

Bloor Homes are committed to working collaboratively

with Walsall Metropolitan Borough Council, the other

BCA and other local stakeholders to bring forward this

site for allocation in the Black Country Plan as a high

quality gateway into Walsall from the north east

"Bloor Homes' Vision for Stencils Farm will

create a new sustainable urban extension on

the north eastern edge of Walsall

The new neighbourhood shall create a new

high quality, welcoming and outward looking

gateway into the town and will be designed

following the principles of a 21st Century

Garden Suburb

A network of green spaces, wildlife corridors,

habitats and recreational footpaths/

cycleways will be developed within the

proposed extensive Green Infrastructure

network

The Avenues, Streets, Greens, Mews and

Squares shall be enclosed and overlooked

by the homes, schools and shops, creating a

heart and focus to the neighbourhood

The neighbourhood will develop its own

unique character and contain a choice

and variety of homes. The fringes of the

neighbourhood shall use a range of outward

facing detached properties, using a rural

materials palette to create a softer and more

rural fringe, enabling it to blend and blur into

the open countryside

This organic approach works with the grain

of the existing landscape and sympathetically

overlays development. It will quickly mature

and become a part of the setting and

character of the wider town '

------------------ VISION DOCUMENT ENDS -------------------

[Attachment: Landscape Sensitivity Review]

LANDSCAPE SENSITIVITY REVIEW

PREPARED FOR BLOOR HOMES MIDLANDS

LAND AT STENCIL'S FARM, WALSALL

OCTOBER 2021

PREPARED BY

PGLA

1.1.

1.2.

1.3.

1.5,

INTRODUCTION

PGLA Landscape Architects have by Bloor Homes Mid ands to review the Black Country

Landscape Sensitivity Assessment (BCLSA) prepared by LUC September 2019. n particular, we have been

asked to ascertain whether the applied sensitivity of Moderate-High is an accurate representation of the

parcel of Land at Stencil's Farm, Aldridge Road, Walsall, identified as SA-1X119-WAL / SA-0066-WAL in the

Black Country Plan Assessment Report and is located Within parcel BL32 in the LUC Landscape Sensitivity

We have reviewed the BCLSA assessment methodology and note the following caveats and qualifications

that have influenced the assessor to reach their conclusions on sensitivity to residential development for the

various land parcels.

The purposes of the study and assessment methodology states the following qualifications in the introduction:

• I 6 The study concentrates on understanding the sensitivities to development and does not address potential

landscape capacity in terms of the quantity of built development, as this is a further stage of assessment

that is dependent on a much wider range of considerations other than landscape and visual effects (such as

highways impact. effects, archaeological constraints and Other and

factors) and consideration of cumulative development, landscape objectives and thresholds of acceptable

_ 7 The Study highlights like/y landscape and sensitivities Within each assessment area and provides a

broad landscape character based assessment rather than a 'e gel assessment as might be required for a

planning application.•

Furthermore in 3; paragraph 3.3, Page 7;

"Judging landscape character sensitivity requires professional judgement about the degree to which the

landscape in question is robust, in that it is able to Change Without adverse imp-acts on

Character, This involves making about whether or not Significant Characteristic elements Of the

landscape will be liable to and whether important aesthetic aspects of character be liable to

This is further qualified in Tab e (Page

"Note that the weran rating based in professional judgement and in some cases one criterion may

be sufficient to result in a judgement Of high sensitivity

Therefore, it is clear that final judgements have been made based on intuition guided by the assessors

subjective experiential rationalisation, Va and reasoning and this is Obviously subjective and open to

variation from one assessor to another.

The methodology section (Paragraph 3.5: Page 7) also states that

"This landscape Sensitivity Assessment is a strategic-level study which considers the landscape and visual

1.9.

1.10.

1.8.

1.9.

1.10.

sensitivity of each area to the principle of built development, without knowing the specific size or exact

location of development (as this would be detailed at the planning application level)."

And when describing the purpose of the study (Paragraph 1.7):

"The study highlights likely landscape and visual sensitivities within each assessment area and provides a

broad landscape character based assessment rather than a site level assessment as might be required for a

planning application."

Although both desk and field study is important and will contribute to an accurate judgement being made

on sensitivity there is an apparent flaw in the process whereby large parcels of land that possess varying

andscape qualities are grouped together and the value judgements for the higher levels of sensitivity have

been applied as a blanket grade to areas which obviously should be of a lower sensitivity.

The criteria selection is based on the attributes of the landscape most likely to be affected by development

and considered both 'landscape' and 'visual' aspects of sensitivity. The criteria are:

• Scale (the scale of the landscape);

Landform (the topographical complexity of the landscape);

Landscape pattern and time depth (the complexity of landscape pattern and the extent to which the

landscape has 'time depth' — a sense of being a historic landscape);

• Natural character (the presence of natural or semi-natural features that are important to landscape

character);

• Built character (the extent that built character contributes to landscape character);


Recreational value (the value of the area for recreation in which experience ofthe landscape is important);

Perceptual aspects (qualities such as rurality, traditional land uses with few modern, human influences,

sense of remoteness or tranquility);

• Settlement setting (the extent to which the area relates or contributes to the form and pattern of

existing adjacent settlement, and the character of the adjacent settlement edge);

• Visual prominence (visual prominence of the area and the character of skylines); and

nter-visibility (the degree of inter-visibility with surrounding designated landscapes and the ro e the

area plays in contributing to valued views).

[Table Headings Sensitivity /Definition]

High / The landscape has strong character and qualities with notable features which are high y

sensitive to change as a result Of introducing built development


Moderate-

High, Moderate / The landscape has some distinctive characteristics and valued qualities, with some

sensitivity to change as a result Of introducing built development


Low-moderate, Low / The landscape lacks distinct character and qualities and has few notable features, or is

robust with regard to introducing built development


1.1 1.

1.12.

1.13.

1.14.

1.15.

A three-point rating from 'low' to 'high' landscape sensitivity is used to illustrate levels of landscape sensitivity

for each individual criteria - i.e. how sensitive the character and quality of the landscape would be to change.

The overall levels of sensitivity were recorded on a five-point scale (low, low-moderate, moderate, moderate-

high and high, the guideline definitions of sensitivity levels are as follows:

The parcel BL32 Walsall is approximately 228.83 ha in total and the Stencils Farm site is approximately 37.8ha

and represents only about 14% of the total parcel. Therefore, it is likely that within such a large parcel there

will be multiple attributes that have varying degrees of sensitivity, for example the natural characteristics

may change within the parcel and contain many attributes such as SLINCs that contribute to sensitivity levels

within confined areas of the parcel. The three point criteria therefore will require a generalisation in order

to reach a judgement on the parcel where in reality there may be a granularity within the landscape that is

difficult to express within a three point criterion.

Therefore, the flaw in assessing the accuracy of the sensitivity within each parcel is the blanket grade of the

highest sensitivity being applied to the whole parcel whereby a further degree of granularity would likely

lead to a refinement of grades resulting in low sensitivity areas being identified alongside higher sensitivity

areas.

This is certainly evident when considering Parcel BL32 (Figure 1, Landscape Sensitivity Assessment - Walsall

Borough) where at a localised level it is difficult to see how the parcel can be considered as having a Moderate-

High landscape and visual sensitivity in places where its is adjacent to the settlement edge and runs along

major routes such as the A545and the A461 whilst being assessed as being on a par with the landscape and

visual sensitivities in other areas within the parcel such as the area around Rushall Hall Scheduled Monument,

Park Lime Pots Local Nature Reserve, Daw End Railway Cutting SSSI and the canal corridor.

1.16.

1.17.

However, it is worth noting that this study should be considered as a starting point and further assessment

on the particular site will be required when considering future planning applications:

"Whilst landscape sensitivity assessment results provide an initial indication of landscape sensitivity, it should

not be interpreted as a definitive statement on the suitability of individual sites for a particular development

or land use change. It is not a replacement for detailed studies for specific siting and design and all proposals

will need to be assessed on their own merits." (Paragraph 3.27; Pagel 4).

The following is a more detailed analysis of what the likely sensitivities of the areas within and surrounding

the Stencils Farm site would be if subjected to a site specific landscape and visual appraisal .

2. LAND AT STENCILS FARM WITHIN WALSALL BL32 ANALYSIS AND REVIEW

2.1.

2.2.

The site (SA-0019-WAL / SA-0066-WAL) - Land at Stencil's Farm, sits within Parcel BL32 Walsall and the

sensitivity of the landscape and the visual amenity is deemed to be Moderate - High according to the BCLSA.

However, when the narrative and accompanying plans are analysed in detail it is apparent that the sensitivity

of the landscape covered by BL32 is variable and the area within the Stencils Farm site boundary is not




2.3.

2.4.

2.5.

2.6.

considered to be as high as other areas within the wider parcel, which also shows varying degrees of sensitivity.

Within the parcel there are areas which demonstrate higher levels of sensitivity such as the Daw End Railway

Cutting SSSI , Park Lime Potts Nature Reserve, and the setting of the Rushall Hall Scheduled Monument and

Conservation Area. These are demonstrated in Figure 2. Therefore, the Stencils Farm site has been assigned

a higher landscape sensitivity purely on its location within a wider parcel that happens to have some higher

sensitive areas as described above.

As suggested in the BCLSA, and highlighted in paragraph 1.12 above, further analysis needs to be undertaken

regarding the sites suitability for development. The accompanying Vision document, Landscape and Visua

Appraisal (LVA), LVA Addendum and Planning Statement provide further supporting analysis regarding the

sites suitability.

Even within the Stencils Farm site there are varying degrees of sensitivity, from large expanses of species

poor agricultural land adjacent to the settlement edge to localised hedgerows with the SLINC designation.

Further analysis of the site will ensure that any development is located in the appropriate place.

The Site Assessment Report states the site has the Moderate-High Landscape Sensitivity to residential

development. It states that "Large scale development would disrupt the small scale field pattern which contributes

to the settlement setting of Walsall, Aldridge and Rushall." However, the site is primarily made up of a large

scale fie d pattern, with the smaller more intimate fields being located within the wider parcel, in particular

in the area to the east of Daw End Branch Canal which is beyond the site boundary.

2.7.

2.8.

2.9.

2.10.

2.11.

The landform is varied within the site with some undulating landform that falls towards the canal from the

north and east and towards the A454 to the south, and although there is an evident incline this does not

appear to be overly dramatic or a particular distinct landscape feature on the site but consideration will be

given to mitigate any visual sensitivity effects within the development of the masterplan.

The boundaries to the fields are vegetated with hedgerow and trees in varying conditions. There are sections

of hedgerow that have been designated as a SLINC, and there are proposals to extend the designation to

include an area in the southern eastern potion of the site in order to protect further hedgerows and established

habitats along the ecological corridor. These will be retained and left undeveloped as part of the proposals,

however there will enhancements to the green infrastructure which provide opportunities to further extend

the wildlife corridors and increase biodiversity levels.

The western boundary lies adjacent to the settlement edge of Walsall and is bound to the south by the A454

which have low levels of sensitivity, as do the expanses of species poor agricultural land which also have low

sensitivity.

The Daw End Branch Canal Corridor / Beacon Way National Trail adjacent to the site, the existing wetland to

the north of the site and the hedgerows designated as Sites of Local Importance for Nature Conservation

(SLINC) have a higher landscape sensitivity and are localised beyond the site boundary.

n light of the above analysis and review it is more likely that the overall sensitivity of the landscape within

the Stencils Farm Stencils Farm site will be moderate.
2.12.

Figure IA illustrates how this will be appear in the Walsall plan produced by LUC should the CPA accept this

proposal for amendment.

3. CONCLUSION

3.1.

3.2.

3.3.

3.4.

3.5.

t is apparent that the lack of granularity within the parcels of the BCLSA combined with the methodology is

providing an assessment with distorted broad brush and skewed gradings regarding landscape and visual

sensitivity.

This is not a result of error as it is acknowledged up front in the document that "Whilst landscape sensitivity

assessment results provide an initial indication of landscape sensitivity, it should not be interpreted as a definitive

statement on the suitability of individual sites for a particular development or land use change. It is not a

replacement for detailed studies for specific siting and design and all proposals will need to be assessed on their

own merits."

Therefore the assessment should be seen as a starting point and further analysis should be applied within

the parcels as it becomes apparent that there are areas of lesser sensitivity that would not be susceptible to

residential development.

The sensitivity grading is therefore not reflective of the more fine granular nature of the wider character area

which means it usefulness and effectiveness as a tool to inform or strongly influence an assessment for a

specific site such as Land at Stencil's Farm is obviously flawed and will not provide the local authority with an

accurate and helpful evidence base for making decisions on site allocations.

Furthermore, the study is effectively sterilising areas of potential development which are of a lower sensitivity


3.6.

3.7.

which goes against the principles of the Landscape institute Guidelines: "The approach advocated in GLVlA3 is

based on the commonly adopted premise that development should be more readily accepted in the least sensitive

areas and should avoid areas that are highly valued for their scenic, nature conservation, historic, recreational and

perceptual qualities such as tranquility and remoteness, particularly those areas safeguarded by international or

national designations and those where the cumulative effects of existing and consented schemes limit further

development."(Ref: Paragraph 4; Page 3 of assessment methodology & summary).

This suggests that within the parcels consideration should also be given to identify lesser sensitive areas and

in this case the Land at Stencil's Farm.

The above acknowledges that more detail studies are required for understanding the particular sensitivities

for individual sites and therefore it is not appropriate for the higher level study to be used solely as a document

for judging the landscape and visual sensitivities as described and referred to in the Draft Black Country Plan

Site Assessment Report August 2021.



FIGURE 1 and IA

Landscape Sensitivity Assessment Plan - Walsall Borough (PGLA adapted)

[Page 7-9]


FIGURE 2

Parcel BL32 - Plan demonstrating key landscape attributes with the parcel

[Pages 10-11]


FIGURE 3
Landscape Site Appraisal

[Pages 12-13]

--------- LANDSCAPE SENSITIVITY REVIEW ENDS ------

[Attachment: Visual Appraisal Addendum]

































LANDSCAPE + VISUAL APPRAISAL ADDENDUM
LAND AT STENCIL'S FARM I ALDRIDGE ROAD I WALSALL



Prepared for BLOOR HOMES MIDLANDS OCTOBER 2021
STE1804_LVA02

FINAL REPORT













CONTENTS


PAGE

01 INTRODUCTION 03

02 LANDSCAPE BASELINE SUMMARY 03

03 EXISTING SITE AND PROPOSALS 04

04 POTENTIAL LANDSCAPE AND VISUAL EFFECTS 05

05 LANDSCAPE STRATEGY AND MITIGATION 10

06 RESIDUAL EFFECTS 11

06 SUMMARY AND CONCLUSIONS 13

FIGURES 15






















































LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 2
1. INTRODUCTION

1.1. PGLA Landscape Architects have been commissioned by Bloor Homes Midlands to provide an Addendum to the Landscape and Visual Appraisal in support of the representations to the Draft Black Country Plan 2039 (Regulation 18) Consultation.

1.2. This Addendum will analyse the potential effects that a proposed residential development at Land at Stencil's
Farm, Aldridge Road, Walsall, may have on the surrounding landscape and visual amenity.

1.3. This study will consider the potential effects in regard to a proposal to secure this site a residential allocation in the emerging Black Country Core Strategy Review. The proposal will be for the delivery of approximately
350 market and affordable homes with a range of housing sizes and tenures complete with new areas of public open space set within an existing landscape framework.

1.4. PGLA prepared a Landscape and Visual Appraisal (LVA) for Bloor Homes Midlands in December 2018 for the delivery of approximately 700 homes, primary school and new local center with new areas of public open space. The methodology and baseline conditions set out in the PGLA (LVA) are still current and will be used for this assessment of the landscape and visual effects for a proposed development at Stencil's Farm for 350 homes.

1.5. Since the initial LVA was completed LUC prepared the Black Country Landscape Sensitivity Assessment, September 2019. The Assessment found that the site was part of a BL32, a large parcel that lies to the east of the settlement edge of Walsall and that parcel BL32 has a moderate-high level of sensitivity.

1.6. However, the assessment states that:

"Whilst landscape sensitivity assessment results provide an initial indication oflandscape sensitivity, it should not be interpreted as a definitive statement on the suitability of individual sites for a particular development or land use change. It is not a replacement for detailed studies for specific siting and design and all proposals will need to be assessed on their own merits." (Paragraph 3.27; Page 14).

1.7. And that

"The study concentrates on understanding the sensitivities to development and does not address potential landscape capacity in terms of the quantity of built development, as this is a further stage of assessment that is dependent on a much wider range of considerations other than landscape and visual effects (such as highways impact, ecological effects, archaeological constraints and other environmental and sustainability factors) and consideration of cumulative development, landscape objectives and thresholds of acceptable change." (Paragraph 1.16)

1.8. Therefore this appraisal considers the landscape and visual effects on the proposed site at Land at Stencil's Farm as suggested within the LUC assessment in order to assess the site on its own merits and its ability to accommodate development rather than a generic assessment on a wider scale.

2. LANDSCAPE BASELINE SUMMARY

2.1. The site at Stencil's Farm, Walsall is located within the National Character Area (NCA) 67: Cannock Chase and Cank Wood and within the Barr Beacon & Aldridge Fields Character Area (WL09) as stated in the Black Country Historic Landscape Characterisation.

2.2. At a local level, the Designing Walsall SPD Character Assessment states that the site falls within the area noted as 'green belt land' but is adjacent to Character Type Central Suburbs and Character Area 8: Mellish Road.

2.3. The site does not fall within any landscape or environmental designations such as nature reserves, SSSl's or ancient woodland. However to the north of site lies the Daw End Railway Cutting 5551 and Park Lime Pits Local Nature Reserve lies to the north west of the site and a hedgerow within the site has a SLINC designation.

2.4. The site does not contain any listed buildings, scheduled monuments and is not within a designated




LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 3
conservation area. The Wyrley and Essington Canal Daw End Branch Riddion Bridge lies to the north of the site.

2.5. The site is located within Walsall Council and this assessment has taken into account the landscape related policies and documentation relating to landscape character and the visual amenity.

3. EXISTING SITE AND PROPOSED DEVELOPMENT EXISTING SITE
3.1. The proposed site is located at Land at Stencil's Farm, Aldridge Road, Walsall. It is on the north eastern settlement edge of Walsall and the approximate centre of the site is located at National Grid Reference SP
03447 99475.

3.2. The site which currently comprises agricultural land split into a series of fields, extends to approximately 37.8 hectares and is irregular in form with large scale field patterns. The land gently rises from the northern and southern edges to an elevated central area. The Park Lime Pits Nature Reserve and Country Park bounds the site to the north/north west whilst the Daw End Branch canal defines the north/north east edges.

3.3. The southern edge of the site is contained by the A454 Aldridge Road, which for almost the full length of the site's southern edge is dual carriageway and includes a traffic island which provides access to Calderfields Golf Club and the Di Ike pub/restaurant which are to the south. Vehicular access is currently taken from A454, Aldridge Road, Walsall.

3.4. The boundaries are mostly delineated by native hedgerows with mature trees in groups or as single specimens. Within the boundaries the majority of land cover is taken up with arable fields bound by partly removed hedges. One of the hedge alignments to the south is designated as a Site of Local Importance for Nature Conservation (SLINC). There is an area of semi-improved grassland located to the south west and is currently recommended to receive a SLINC designation and there is an area of wetland adjacent to the northern boundary.

3.5. The topography gently rises from the east to west from approximately 135m AOD to 150m AOD.

3.6. There is a Public Rights of Way (FP Wal59) that travels across the site that links Beacon Way to Aldridge Road on the southern boundary.

3.7. The site is not subject to designations such as conservation areas or SSSl's. A Grade 2 listed bridge is within close proximity (but outside of the site) to the north and provides pedestrian access across the Daw End Branch Canal.

PROPOSED DEVELOPMENT

3.8. The proposals aim to deliver circa 350 new homes as part of a mixed use development. The area of development will be concentrated to the western portion of the site and the land to the east that runs adjacent to Daw Bank Branch Canal will be retained as agricultural land (which equates to approximately
15.27 ha of the site area).

3.9. The development of this site will create a sustainable urban extension on the north eastern edge of Walsall.
The development shall integrate and become part of the existing settlement pattern of the town, whilst also being bounded, enclosed and softened by the retained hedgerows, associated trees and new complimentary native planting.

3.10. The development shall create a new high quality and outward looking gateway into the town. This new neighbourhood will be designed to create a series of high quality green spaces. These green spaces, along with wildlife corridors, ecological habitats and recreational footpaths/cycleways will be developed within an over arching and extensive Green Infrastructure network, linking the site to the local facilities, wider settlement and countryside, as well as buffering the site from the wider Green Belt.

3.11. The fringes of the neighbourhood shall use a range of outward facing properties, using a rural materials





LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 4
palette to create a softer and more appropriate rural fringe, enabling it to blend and integrate into the open countryside.

3.12. This organic approach works with the grain of the existing landscape and sympathetically overlays development. It will quickly mature and become a part of the setting and character of the wider town.



4. POTENTIAL LANDSCAPE AND VISUAL EFFECTS

4.1. This section assesses the potential effects that the proposed development may have on the landscape character as described in the baseline in Section 2 above. The nature of the receptor, (sensitivity), and the nature of the effect, (magnitude of change) have been considered, however, as this report is a landscape appraisal rather than a full LVIA only the potential significance of effects have been stated as stated in the Guidelines for Landscape and Visual Impact Assessments, Third Edition 2013 (GLVIA3) (Para 3.3 and Table3.1 ).

4.2. GLVIA3, suggests that potential landscape effects should be measured at three levels;

i) effects on the site;

ii) effects on the setting of the site; and

iii) effects on the broader landscape context.

4.3. It also offers guidance on measuring effects during the Operational Stage i.e. at point of completion; and also residual effects such as long term effects after a certain time period. In this case we have measured the effects of the development after ten yea rs.

4.4. Mitigation measures have also been considered and recorded as part of the appraisal to explain how the introduction of certain landscape treatments can help reduce the overall effect of any potential adverse effects.

4.5. The nature and magnitude of landscape and visual effects will change during the construction and development process. Some impacts may be severe, but short term, whereas others are minor impacts with residual effects, which may be of a permanent nature. In addition, some impacts could be mitigated by landscape and other measures, which will have benefits in the longer term. Potential impacts that may occur during the stages of the proposed development are summarised below.

4.6. Short term impacts are those that occur during the construction period. These are considered as follows:

• Site access, delivery and traffic movements;

• Earthworks and materials stockpiles;

• Construction equipment and plant;

• Utilities, including water and lighting;

• Temporary parking;

• Site compound and accommodation;

• Additional noise; and

• Additional mud to roads.

4.7. Construction impacts can be mitigated through use of good practice in construction management and through immediate restoration of areas such as site compounds used during the construction phase of the project. The residual impacts of construction will be very limited and overall are considered to be negligible.

4.8. Medium term impacts are those that occur on completion of the works:

• Presence of built structures

• New or modified access road, and

• New landscape planting.



LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 5
4.9. Long term effects are considered following the completion of the works, and can be considered as residual effects. These are similar to the effects on completion but may be partially or wholly mitigated by maturing proposed landscape infrastructure, site management and other development proposals.

LANDSCAPE EFFECTS

Potential Effects on the Physical Fabric of the Site

Operational Stage

4.10. This section assesses the potential landscape effects of the impact caused by the proposed development.
The assessment has been made based on the operational phase only as it is difficult to fully anticipate what the construction phasing of this project will be at this stage. However, in the initial instance it is usual that there will be short term temporary adverse effects during the construction stage. This will be closely regulated by a Construction Management Plan with controlled times and vehicular movements. The site is likely to be temporarily secured along the boundaries of the site with timber hoarding to reduce noise and adverse visual effects.

4.11. In general terms, changes to the landscape fabric will only occur within the application boundary for the proposed development. The impact of the proposed development on the site will cause long term effects on the landscape fabric through the removal of the existing agricultural fields which will be replaced with residential development, retail facilities, areas of public open space and associated infrastructure.

4.12. The site generally accords with the key characteristics of the Landscape Character descriptions described in the Landscape baseline (PGLA LVA December 2018), however the site falls outside the local character area descriptions for Walsall. The sensitivity of the site is deemed to be medium to account for the poor species agricultural land, location adjacent to the existing settlement edge, large scale irregular field pattern and takes account of the current hedgerow and recommended SLINC designation.

4.13. The degree of change is considered to be medium/major due to the obvious change to the fabric and cover of the landscape by the introduction of the proposed development. The design of the layout has focussed on keeping the development area close to the existing settlement edge of Walsall and retaining the agricultural fields are adjacent to the Daw End Branch Canal, introducing an eco park to the north of the site to provide a buffer to the adjacent Daw End Branch Canal and retain ecological beneficial attributes associated with the site.

4.14. The design intent is to retain the landscape features within the site where appropriate including the majority of boundary hedgerows and trees and wetland areas to the north of the site. The proposals seek to incorporate the existing landscape features and protect and enhance the more ecological sensitive features and retain large areas of agricultural land.

4.15. Therefore, the potential overall effect on the site are likely to be moderate major.

4.16. This accounts for the small scale loss of part of the hedgerow along Aldridge Road to allow for access and a change in the fabric and cover of part of the landscape within the site boundary from open fields to a residential development and large areas of POS and associated infrastructure with newly introduced planting.

4.17. The change will be permanent and deemed to be adverse initially, due to the dominating effects of the infrastructure and introduced built form.

Residual Effects

4.18. The proposal demonstrates that additional planting within the site and the substantial landscape buffer incorporated into Eco Park and in the areas of POS provide potential for mitigation to the adverse effects arising at the operational phase. These will not have matured sufficiently at the early stages after construction but after a period of time the introduced landscape elements will mature to soften the effects of the built development within the site and offer enhanced and positive benefits to offset some of the initial adverse effects of the development. It will create a softer settlement edge to Walsall and interface with the green belt. The materials of the development will be of an appropriate high quality and therefore offer the potential to





LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 6
provide an integration of the scheme into the wider landscape. Therefore, the nature of effects is likely to be
moderate leading to potential overall residual effects of moderate beneficial.

Potential Effects on the Landscape Setting of the Site

Operational Stage

4.19. At time of completion the noticeable effects on the setting of the development site will have taken place at the location of the newly introduced roundabout on the southern boundary adjacent to Aldridge Road. The remainder of the setting on the perimeters will remain intact and the hedgerows and trees will be retained to provide an immediate setting to the proposed development. The character of Aldridge Road is likely to undergo change with the visibility of the houses becoming apparent and this is assessed further in the Visual Effects Section.

4.20. The sensitivity to change of the setting is deemed to be low on Aldridge Road due to the urbanised character of the carriageway and small section that will be affected. The sensitivity of the western and northern boundaries adjacent to the Daw End Canal and proximity to the nature reserve is considered to be medium.

4.21. The nature of effects is likely to be minor as the majority of the perimeter vegetation will be retained and enhanced with additional landscape planting. The planting will help to extend the existing and retained wildlife and ecological corridors present within the site and the wider landscape, enhancing the overall biodiversity levels on site.

4.22. The potential significance of effects on the setting of the site are likely to be moderate adverse.

Residual Effects

4.23. The appraisal recognises that there will be a degree of change to the setting which will include the introduction of built form that contributes to the overall character combined with the introduction of further structure planting to the perimeters and within the areas of public open space to offset and reduce the adverse effects identified at the operational stage.

4.24. Therefore, the residual effects are likely to be minor beneficial.

Potential Effects on Broad Landscape Context

Operational Stage

4.25. This section describes the effects on the local landscape character area Barr Beacon and Aldridge Fields WL09
Character Area.

4.26. The nature of receptor (sensitivity) of this character area has been assessed as medium as it describes a general rural landscape bound by settlement. The site is not located within any nationally recognised landscape or cultural designations. The general quality of the wider landscape is agricultural with recreational and leisure facilities.

4.27. The public rights of way networks are relatively extensive and include National Cycle Routes, bridleway and national walking routes such as the Beacon Way.

4.28. The nature of effects (magnitude of change) has been assessed as minor. The proposed development will have no adverse effect on the broader character area. Change in views experienced by users of the rights of way within the immediate vicinity of the site and the character areas are assessed in the Visual Amenity section later in this document.

4.29. The proposed development will be introducing a number of new hedgerow plants and trees as part of the overall design and therefore the adverse effects are considered to be reduced by the beneficial effects that the planting and other landscape interventions will introduce.

4.30. The potential likely significance effects on this LCA has been assessed as minor moderate due to the associated landscape interventions which will improve the current condition and status of the landscape




LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 7
characters as described in Section 2 above.

Residual Effects

4.31. The overall landscape character area will benefit from the maturity of the introduced landscape which will help to integrate the mixed use development into the landscape and potentially enhance the ecological and biodiversity of the green infrastructure in and around the development site. The nature of effects (magnitude of change) has been assessed as imperceptible.

4.32. Therefore, the potential significance of effects are likely to be negligible due to the maturing of the proposed landscape planting.

VISUAL EFFECTS

4.33. This section considers the potential visual effects of the impact caused by the proposed development. The appraisal has been made based on the operational phase only as it is difficult to fully anticipate what the phasing and construction operations of this project will be at this stage.

4.34. The appraisal was carried out during Autumn when the deciduous trees and vegetation, on and surrounding the site, were starting to lose their leaves. The screening effect of the deciduous trees, hedgerows and understorey shrubs will therefore increase during the summer months and decrease during the winter months.

4.35. The potential landscape and visual effects noted in this document are those experienced during the operational phase of the development as well as the long term residual effects.

4.36. Figure X: Viewpoints Location Plan, illustrates the locations of the considered and identified visual receptors.

4.37. Viewpoints were selected on the basis of which locations provide the clearest views of the site and are also the most accessible to the public. Visual receptors have been analysed for the likely visual effects on the landscape and residential amenity from a relatively close range and from within the immediate setting. Medium to long-range views were tested within the area through site visits but many views towards the development are screened by the prominent built form that surrounds it and extensive vegetation within the vicinity and surrounding the site. This was verified by field study.

4.38. The ZTV (within the previous PGLA LVA) suggests that some views may be achieved from an extensive area around the site but these were discounted in the field due to the screening effects of extensive blocks of woodland and farm buildings. Likewise, views from the many of the surrounding footpaths are verified as non-existent.

Visual Receptors

4.39. The visual receptors are represented by viewpoints that consider the likely effects on the nearby settlements and residential amenity; recreational areas such as public footpaths, national trails and parks. Consideration has also been given to transport routes such as roads.

Settlements and Residential Amenity Receptors:

4.40. Within the vicinity of the site residential receptors include a relatively small number of dwellings on Mellish Road, Aldridge Road and Stencils Road to the south west of the site. There are a number of individual dwellings and farmsteads to the north of the proposed development, such as College Farm and Berryfields Farm, but these will have little to no visual connectivity with the site due to the existing landform and vegetation within the countryside. Likewise, the housing on the south western edge of Aldridge has limited inter-visibility with the proposed development site due the existing rolling landform and roadside hedgerows aligning the B4154. It may be possible to see the north western edge of the proposed development from the upper storey windows of dwellings facing Bosty Lane from some locations.








LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 8
Recreational Receptors

4.41. The site is visible from some parts of the Public Rights of Way (PRoW) network within the vicinity of the site primarily FP Wal 55, 56, 58, 59 and the Beacon Way. FP Aid 22 runs to the north of the Riddian Bridge and connects to Bosty Lane. The majority of the proposed site is visually contained by the mature planting along both banks of the Daws End Branch Canal, but it is likely that the upper storeys of the new housing in the northern parcels will be visible above and between the vegetation from a small number of locations on the footpath when looking southwards.

4.42. Views to the site from the public footpaths Wal55; 56 and 58 to the north west of the site are limited or non• existent due to the intervening hedgerows and dense block of woodland in the landscape. Likewise, views are limited or non-existent from the Beacon Way to the south east of the site and from the recreational sports ground to the north of Hayhead Wood.

4.43. The recreational receptors are represented by viewpoints 1-9.

Cultural Receptors

4.44. There are no listed buildings or scheduled monuments within the site boundary. However, Riddian Bridge is Grade 2 listed and crosses the canal to the north of the site. This receptor is represented by Viewpoint 6. There are also a number of listed buildings within the vicinity, and these are clustered to the west around Rushall Hall but have no visual connection with the development.

Transport and Road Receptors

4.45. These receptors include those using major and minor roads in the vicinity that experience some visibility of the site. In this case the only road in close proximity to the site are Aldridge Road and Mellish Road to the south and the side roads of Burton Farm Road, Mellish Drive and Stencills Road. Walsall Road travels towards Aldridge from the site to the east and Bosty Lane (B4154) travels along the south western edge of Aldridge to the north. Travelling receptors are considered to be low in terms of sensitivity to development.

Predicted effects on residential receptors

Operational Stage

4.46. The sensitivity of the residential receptors is deemed to be medium high due to the proximity of the existing built development of the settlement and major road infrastructure but also accounting for the status of the adjacent Green Belt.

4.47. Residential properties located on the western end of Aldridge Road directly opposite the south western parcel will experience a moderate degree of change in view at the operational stage. However, the new housing will be seen behind the Aldridge Road carriageway and landscape buffers and areas of POS and in context with the existing buildings on the north side of the road. The likely effects is moderate for these houses.

4.48. Houses in the immediate vicinity on Burton Farm Road, Mellish Drive and Stencills Road are likely to experience very limited visibility of the proposed development from some of the upper back rooms that looks eastwards towards the site boundary. The magnitude of change is likely to be minor.

4.49. It is likely that some of the houses on Bosty Lane will experience some views of the northern parcels of the proposed development from the upper storey windows, but the magnitude of change is likely to be minor. This will lead to moderate minor effect.

4.50. Other dwellings in the vicinity such as farmsteads on College Farm and Berryfields Farm will have limited or no direct views of the proposed development and it is anticipated that the magnitude of change will be imperceptible. Therefore, the likely significance of effects will be negligible.

Predicted Effects on Recreational Receptors





LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 9
Operational Stage

4.51. Public footpath Wal59 travels across the middle of the site in a general north to south direction and connects Aldridge Road with the Daw End Branch Canal and the Beacon Way. It is represented by Viewpoint 3. The sensitivity of the footpath to change for residential development is deemed to be Medium to account for the general landscape character features.

4.52. The alignment of the footpath will be maintained and incorporated into the green avenues and green infrastructure within the development proposals, but the long-range views of fields will be replaced by residential development. The likely magnitude of change is moderate major leading to the likely effects being moderate major.

4.53. The Beacon Way travels along the north eastern boundary to the site on the alignment of the Daw End Branch Canal. The sensitivity of the Beacon Way is considered to be high to account for its status as a national trail. The footpath and Beacon Way are represented by Viewpoints 4-9.

4.54. Viewpoint 4 demonstrates that there will be little visibility of the proposed development to the north west of the site, whilst Viewpoint 5-7 demonstrate there will be varying degrees of visibility in the vicinity of Riddian Bridge. However, most of the built form of the development will be set back into the site and the immediate agricultural fields adjacent to the canal will be retained as existing. Likewise, Viewpoints 8-9 will experience some visibility of the development, but it will be beyond a landscape buffer and seen as an advancement of the settlement edge. The magnitude of change will be minor to account for the existing vegetation of the canal side providing screening and the set back of the built form. The likely significance of effects is therefore moderate.

4.55. Viewpoints 1-2 represent public footpaths FP 55 and 56 and demonstrate that only a portion of the western parcels are likely to be visible from very limited locations due to the distance to the site and the extensive hedgerow vegetation and blocks of woodland within the landscape. The sensitivity of these footpaths is medium and the magnitude of change will be minor. The likely significance of effects is moderate minor.

Predicted Effects on Cultural Receptors

4.56. The are no predicted effects on the general heritage receptors from a landscape or visual perspective apart from what has been described above for the visual effects on Riddian Bridge. Please refer to the Heritage Assessment for information regarding further heritage related effects on the listed buildings, structures and scheduled monuments.

Predicted Effects on Travelling Receptors

Operational Stage

4.57. Viewpoints 1 and 9-14 generally illustrate the range of visibility that can be achieved from the roads when travelling nearby and it is clear that any experience of the proposed development will be in the form of glimpsed views of the built form of the development from gaps in the roadside vegetation on the south of the proposed development site. The sensitivity of the transport receptors is deemed to be low due to the speed of travel and the focus of drivers to the road. The most obvious location where change will occur is at the access point, and the magnitude of change will be moderate. The landform rises towards a ridge from the southern boundary and therefore only the edge of the southern parcels of development will be visible from Aldridge Road in areas where the vegetation is sparse in the hedgerows. The landscape strategy outlined in the next section proposes that the existing hedgerows and perimeter planting should be gap• filled and reinforced to provide screening in these locations.

4.58. Views from roads further north and east such as Bosty Lane and Walsall Road are limited to non-existent due the intervening landform and vegetation within the countryside. The likely effects on these transport receptors are likely to be negligible.

5. LANDSCAPE STRATEGY AND MITIGATION

5.1. The development of the layout for this site has taken the existing green infrastructure into account to provide a residential led mixed use development set within a substantial landscape structure.




LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 10
5.2. There are significant opportunities for new tree planting and landscaping within the site, and infill planting especially on the southern and northern perimeters.

5.3. The overall elements of the landscape strategy for the site can be summarised as follows

• Retention of the existing elements that make up the site's green infrastructure, such as tree and hedges and integrating these into the development, giving the scheme an immediate sense of maturity;

• Ensuring the gaps in the existing hedge adjacent to Aldridge Road and the Daw End Branch Canal are in-filled with native trees and hedge planting. Evergreen species of holly should be included in the mix to provide effective screening through the winter months;

• Ornamental and native hedge planting to be planted in and around the proposed development to soften the effects of the built form.

5.4. A range of trees to be introduced to reflect the street hierarchy including the central avenue and crescents.
Native trees should be planted in the Daw End Branch Linear Eco-Park as well as all other areas public open space.

5.5. The landscape strategy has been taken into account when considering the mitigation for the identified potential adverse landscape and visual effects arising at the operational stage of the proposed development and these have been reflected when considering the residual effects below

6. VISUAL RESIDUAL EFFECTS

6.1. Mitigation measures can be introduced to assist with the offsetting or reducing of any identified adverse effects and this includes introducing a robust landscape strategy and framework into the development including perimeter structure planting and linear parks. The buildings should be of such a quality to provide an attractive interface between the settlement and the wider landscape. The development should be reflective of the local vernacular in terms of materials and styles for the buildings and the landscape should be consistent with the overall character of the area.

6.2. The residual effects on the landscape character have been described above.

6.3. In time the planting will mature providing a substantial screen to the development from the general visual receptors and the potential significance of effects identified at the operational stage could be reduced to as described below:

Predicted Residual Effects on Residential Receptors

Residual Stage

6.4. The sensitivity of the residential receptors is deemed to be medium due to the proximity of the existing built development of the settlement and major road infrastructure.

6.5. Residential properties located on the western end of Aldridge Road directly opposite the south western parcel will initially experience a medium degree of change in view at the operational stage. However, the new housing will be seen behind the Aldridge Road carriageway and in context with the existing buildings on the north side of the road. The proposed tree and hedge planting to the southern boundary will mature over time and therefore the likely residual effects is minor for these houses.

6.6. Houses in the immediate vicinity on Burton Farm Road, Mellish Drive and Stencills Road are likely to experience very limited visibility of the proposed development from some of the upper back rooms that looks eastwards towards the site boundary. The magnitude of change is likely to be imperceptible when the landscape planting matures leading to minor residual effects.

6.7. It is likely that some of the houses on Bosty Lane will initially experience some views of the northern parcels of the proposed development from the upper storey windows, but the magnitude of change is likely to be Imperceptible when the planting in the linear and eco parks on the northern boundary of the development matures in time. This will lead to negligible residual effects.





LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 11
6.8. Other dwellings in the vicinity such as farmsteads on College Farm and Berryfields Farm will have limited or no direct views of the proposed development and it is anticipated that the magnitude of change will be minor or imperceptible. Therefore, the likely residual effects will be negligible.

Predicted Residual Effects on Recreational Receptors

Residual Stage

6.9. Public footpath Wal 59 travels across the middle of the site in a general north to south direction and connects Aldridge Road with the Daw End Branch Canal and the Beacon Way. The sensitivity of the footpath to change for residential development is deemed to be medium high to account for the general landscape character features.

6.10. The alignment of the footpath will be maintained and incorporated into the green avenues and green infrastructure within the development proposals and these will mature over time to provide a very robust landscape structure within the heart of the development. The likely magnitude of change is moderate minor leading to the likely residual effects being moderate.

6.11. The Beacon Way travels along the north eastern boundary to the site on the alignment of the Daw End Branch Canal. The sensitivity of the Beacon Way is considered to be high to account for its status as a national trail.

6.12. Most of the built form of the development will be set back into the site with large landscape buffers along the boundaries and within the site. This will mature in time and the magnitude of change will be minor to account for the existing vegetation of the canal side and within the site maturing providing filtered screening to the built form. The residual effects is likely to be moderate where the development can be seen.

6.13. Viewpoints 1-2 represent public footpaths FP 55 and 56 and demonstrate that only a portion of the western parcel are likely to be visible from very limited locations due to the distance to the site and the extensive hedgerow vegetation and blocks of woodland within the landscape. The sensitivity of these footpaths is medium high and the magnitude of change will be minor to imperceptible. The likely residual effects is Moderate Minor.

Predicted Effects on Cultural Receptors

Residual Stage

6.14. The are no predicted residual effects on the general heritage receptors from a landscape or visual perspective apart from what has been described above for the visual effects on Riddian Bridge. Please refer to the Heritage Assessment for information regarding further heritage related effects on the listed buildings, structures and scheduled monuments.

Predicted Residual Effects on Transport Receptors

Residual Stage

6.15. The sensitivity of the transport receptors is deemed to be low. The most obvious location where change will occur is at the points of access, including a new roundabout off Aldridge Road, and the magnitude of change will be moderate minor when the associated landscape planting matures over time and integrates the roundabout into the development and Aldridge Road. The landscape strategy proposes that the existing hedgerows and perimeter planting should be gap-filled and reinforced to provide screening in these locations and these will mature to integrate the development into the locality and provide localised screening and filtered views of the development. The residual effects are likely to minor.

6.16. Views from roads further north and east such as Bosty Lane and Walsall Road are limited to non-existent due the intervening landform and vegetation within the countryside. The likely residual effects on these transport receptors are likely to be negligible.






LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 12
7. SUMMARY & CONCLUSIONS

7.1. The site of the application is located at Land at Stencil's Farm in Walsall. The approximate centre of the site is located at National Grid Reference SP 03447 99475. The site currently comprises of agricultural land used for arable farming and is on the eastern settlement edge of Walsall. The Daw End Branch Canal runs along the northern and eastern site boundary with Aldridge Road running along the southern boundary.

7.2. The land gently rises from the northern and southern edges to an elevated central area. The Park Lime Pits Nature Reserve and Country Park bounds the site to the north/north west whilst the Daw End Branch Canal defines the north/north east edges.

7.3. The southern edge of the site is contained by the A454 Aldridge Road, which for almost the full length of the site's southern edge is dual carriageway and includes a traffic island which provides access to Calderfields Golf Club and the Di Ike Arms pub/restaurant which are to the south.

7.4. The boundaries are mostly delineated by native hedgerows with mature trees in groups or as single specimens. Within the boundaries the majority of land cover is taken up with arable fields bound by partly removed hedges. One of the hedge alignments to the south is designated as a SLINC. An area of semi• improved grassland is located to the south west and an area of wetland is adjacent to the northern boundary.

7.5. Vehicular access is currently taken from A454, Aldridge Road, Walsall. The proposals seek to retain access from Aldridge Road at the existing roundabout to Di Ike Pub and Calderfields Golf and County Club.

7.6. There is one Public Rights of Way (Wal59) on the site and there are numerous public footpaths within the vicinity of site including National Trail Beacon Way which runs around the north and east of the site.

7.7. The Proposed Development aims to provide a residential development for circa 350 homes and mixed use area set within a strong landscape framework that comprises of:

• the retention of the existing elements that make up the site's green infrastructure, such as tree and hedges and integrating these into the development, giving the scheme an immediate sense of maturity;

• Ensuring the gaps in the existing hedge adjacent to Aldridge Road and the Daw End Branch Canal are in-filled with native trees and hedge planting. Evergreen species of holly should be included in the mix to provide effective screening through the winter months;

• Ornamental and native hedge planting to be planted in and around the proposed development to soften the effects of the built form;

• A range of trees to be introduced to reflect the street hierarchy including the central avenue and crescents. Native trees should be planted in the Eco-Park as well as all other areas public open space.

7.8. The proposed development as described will be set within a strong retained and enhanced landscape framework and will seek to introduce additional structure planting and screening.

7.9. The assessment of the potential effects on the landscape concludes that there will be a moderate major change in the landscape fabric of the existing site as the proposed development and associated infrastructure are introduced. There is potential for any identified adverse effects being reduced over time as the planting and landscape framework within the site matures.

7.10. The setting of the site will benefit from the introduced planting to infill the gaps in the hedgerows, particularly on the southern and northern boundaries. The proposed development is likely to have an imperceptible effect on the broad landscape character. However, the landscape proposals are considered to be potentially beneficial as they reflect the species of the adjacent landscape and are consistent with the Landscape Character description for the Black Country.

7.11. The visual assessment that has been carried out has demonstrated that the proposed development will have some general effects on the immediate visual amenity along Aldridge Road and the Beacon Way, however, views into the site are mostly localised to the immediate vicinity of the site boundaries.

7.12. The residential amenity of the properties on Aldridge Road, Mellish Drive and Stencills Road will undergo

LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 13
varying degrees of change. However as the proposed landscape structure planting and the proposals seek to reinforce the screening, the residual effects are deemed to be moderate to negligible.

7.13. Further north properties on the south western edge of Aldridge will experience little to no visibility of the proposed development from principal rooms facing Bosty Lane but limited and glimpsed views of the site may be achieved from upper storey rooms.

7.14. The users of the public footpath networks will experience some moderate effects to the visual amenity at time of completion and the residual effects are likely to reduce to minor moderate as the proposed planting matures. The long to medium view range footpath network will experience negligible residual effects due to the existing settlements, landform and vegetation within the countryside.

7.15. In conclusion, the long term residual effects of the development are not likely to exceed moderate in terms of significance to the overall landscape and visual amenity. Potential adverse effects that have been identified to be present at the operational stage, especially on the site and its setting will be reduced and offset by the mitigation provided in the potential planting scheme described within the landscape strategy.

7.16. Therefore, the findings of this report demonstrate that the site is able to accommodate the proposed development without causing undue harm to the landscape character and visual amenity of the site and surrounding countryside and footpath network.

LANDSCAP.E AND VISUAL AP.P.RAISAL ADDENDUM 14

FIGURES

---------- VISUAL APPRAISAL ADDENDUM ENDS ---------

[Attachment: Development Options]

Land at Stencils Farm, Walsall
Development Options
October 2021
BLOOR HOMES Cerda Waterman Orion, pgla Landscape Architecture, e*SCAPE urbanists

Contents
Executive Summary
01: Introduction Page 06
02: Planning Policy Background Page 10
03: Working with the Site Page 12
04: Options for Creating a New Neighbourhood Page 24

 
Executive Summary
Purpose

This Development Options document has been prepared on behalf of Bloor Homes by a professional, multi-disciplinary team in support of the land at Stencils Farm, Walsall.

In recognition of the work which has been undertaken by the respective Black Country Authorities to review the Black Country Core Strategy and with it the acknowledged need to release a significant quantum of land from the Green Belt in order to deliver additional houses within the Black Country, this document re-emphasises the suitability of the land at Stencils Farm for residential development.

The primary purpose of this document is to demonstrate the site is suitable to be released from the Green Belt having regard to the purpose it serves and by consequence that the site is suitable and available to deliver a significant quantum of homes to meet the need which is identified across the Black Country. The site at Stencils Farm represents a logical and sustainable extension to Walsall on its eastern edge, contiguous with the existing settlement boundary and within close proximity to existing services, employment opportunities and public transport links.

Previously, Bloor Homes had submitted a Vision document setting out proposals for the potential development at Stencil’s Farm. Since then a Landscape Sensitivity Assessment (LSA) by LUC has contributed to the current draft strategic housing site allocations evidence base. We have reviewed those findings, offered our thoughts on the high level nature of that assessment, whilst also exploring an option to take account of LUC’s assessment; providing an alternative option which will still aid in meeting local housing needs.

This development options document therefore offers proposals for Stencils Farm that range in housing numbers from circa 370 homes to 700 homes, both options contain a strong green infrastructure network offering a positive contribution to the wider landscape setting of the site, canal corridor and wider rural landscape.

The following sections of this document set out the site specific approach to creating a sustainable and deliverable residential led development at Stencils Farm. Ultimately, it is a development which works with the existing landscape form, reintroduces some of the historic smaller grain field boundaries, takes full account of the site’s existing features and is therefore truly responsive to its context.

Through this process we will demonstrate Bloor Homes, credentials as a developer that is sympathetic to the environment in which they work and that the site at Stencils Farm represents a logical, sustainable and deliverable one which it is entirely appropriate to release from the Green Belt.

Bloor Homes looks forward to continuing a constructive dialogue with the BCA and is committed to promoting the land at Stencils Farm through future stages of the Core Strategy Review process.

Headline Benefits

Key benefits of the proposed scheme include the delivery of:

• approximately 370 to 700 market and affordable homes with a range of housing sizes and tenures to help meet the demand for new housing in the area;
• new areas of public open space;
• a new two form entry primary school (Option 1)
• a new Local Centre/Mixed use zone;
• a development which respects the adjoining neighbours in terms of providing landscape buffers between existing and proposed homes,
• a sensitive, high quality green infrastructure network that maintains and improves the wildlife corridors and biodiversity in the area, whilst maintaining/ reinstating much of the existing planting, hedgerows and trees; and
• a development which works with the existing constraints to ensure that the purposes of the retained Green Belt are strengthened, not diminished by creating this new sustainable urban extension.

1.0 Introduction
Homes at Stencils Farm

1.1 The Black Country Authorities (BCA,s) have published their Draft Plan in the form of the Draft Black Country Plan 2018-2039, with this Regulation 18 consultation open between 16th August and 11th October 2021.

1.2 The plan identifies an overall housing need of 76,076 across the BCA’s Councils. There is therefore an acknowledged significant supply shortfall for the plan period of a minimum of 36,819 new homes based on the most up to date Black Country Urban Capacity Review Update (2021 ), which increases to 38,469 taking account of a need to consider a reduction in the windfall numbers. This figure is likely to increase further as the evidence supporting the plan continues to be tested.

1.3 Given the urban areas within the Black Country are, for the most part, contained by the West Midlands Green Belt. The Draft Plan confirms that exceptional circumstances have been demonstrated in order to remove areas of Green Belt in order to meet both housing and employment needs.

1.4 As a consequence, the Draft Plan proposed to allocate a number of Green Belt sites, acknowledging this need and that the release of Green Belt sites needs to play a significant role in meeting the BCAs housing requirement over the Review plan period.

1.5 Bloor Homes are confident that this site, which adjoins the eastern edge of Walsall and is contiguous with the existing residential development is a logical, highly sustainable and therefore obvious candidate for site allocation in the Draft Black Country Plan.

The Opportunity

1.6 Previously Bloor Homes had submitted a Vision document setting out proposals for the potential development at Stencil’s Farm.

1.7 Based on the findings of the recent Landscape Sensitivity Assessment (LSA) by LUC which contributed to the current draft strategic housing site allocations we have reviewed those findings, offered our thoughts on the high level nature of that assessment, whilst also exploring an option to take account of LUC’s assessment; providing an alternative option which will still aid in meeting local housing needs.

1.8 This development options document therefore offers proposals for Stencils Farm that range in housing numbers from circa 370 homes to 700 homes both contain a strong green infrastructure network offering a positive contribution to the wider landscape setting of the site, canal corridor and wider rural landscape.

1.9 The site which currently comprises arable land is split into a series of large fields and extends to approximately 37 .8 hectares. The land gently rises from the northern, eastern and southern edges to an elevated central area. The greater part of the western boundary abuts existing residential development, fields abut the remainder of the site to the west/north west whilst the Daw End Branch canal defines the north/north east edges. The southern edge of the site is contained by the A454 Aldridge Road, which for almost the full length of the site’s southern edge is dual carriageway.

1.10 Bloor Homes currently controls the land as illustrated in the Site Location Plan (Figure 01 :01) and is committed to the delivery of a high-quality, contextually responsive and comprehensive residential-led scheme providing much needed new housing and community facilities for the local area.

Creating A Strategic Gateway

1.11 Based on the previous work as set out in the Vision Document relating to 21st Century Garden Towns and Villages, the site is well located to create a new Garden Suburb as part of the wider Walsall conurbation. But not only a suburb but also a new gateway into the town, as described below.

1.12 Walsall has eight strategic routes into the town from the surrounding settlements, as illustrated in Figure 02:05. The A454, Aldridge Road connects the large settlement of Aldridge with Walsall. Stencils Farm creates the ideal opportunity to create a strong and positive gateway into the town from the north east.

1.13 The ,Aldridge Gateway, would provide a positive, welcoming and outward looking, finished edge to the town from this approach.

1.14 The new Green Belt boundary would be well protected by the canal and the on-site ecological buffers to create a well defined boundary and strong green gap between Walsall and Aldridge.

1.15 The Garden Suburb represents a very special opportunity to showcase what Walsall can achieve in a partnership between the public and private sectors.

1.16 The residential-led mixed use development at Stencils Farm will provide a strong, cohesive and strategically logical opportunity for Walsall to meet the demands of a growing population.

A Vision for the Stencils Farm

1.17 Our Vision for Stencils Farm sprang out of the appreciation of the surrounding context and features of the site itself, the panel to the right summaries that Vision which is still relevant to both options.

2.18 This new neighbourhood will create a sympathetic and high quality development set into a strong and bold network of green spaces, wildlife corridors, habitats and recreational footpaths/cycleways. All these elements form an integral part of the Green Infrastructure network, linking the site to the local facilities, adjoining suburbs and countryside via the already identified wildlife corridors which run through the whole borough of Walsall.

2.19 The masterplanning team has carefully considered all the opportunities and constraints to inform the options, which demonstrates that the site can comfortably accommodate a sustainable neighbourhood of between 350 to 700 dwellings. The proposals will enable the provision of a network of public open spaces for use by the existing and new members of the community.

2.20 The result will be a sympathetic, sustainable and integrated Gateway neighbourhood on the north eastern edge of Walsall, within a logical Green Belt release site, creating a strong addition to Walsall and complementing the surrounding neighbourhoods and green spaces.
 

"Bloor Homes' Vision for Stencils Farm will create a new sustainable urban extension on

the north eastern edge of Walsall.

The new neighbourhood shall create a new high quality, welcoming and outward looking

gateway into the town and will be designed following the principles of a 21st Century

Garden Suburb.

A network of green spaces, wildlife corridors, habitats and recreational footpaths/

cycleways will be developed within the proposed extensive Green Infrastructure network.

The Avenues, Streets, Greens, Mews and Squares shall be enclosed and overlooked by the

homes, schools and shops, creating a heart and focus to the neighbourhood.

The neighbourhood will develop its own unique character and contain a choice and variety

of homes. The fringes of the neighbourhood shall use a range of outward facing detached

properties, using a rural materials palette to create a softer and more rural fringe, enabling

it to blend and blur into the open countryside.

This organic approach works with the grain of the existing landscape and sympathetically

overlays development. It will quickly mature and become a part of the setting and character

of the wider town."







2.0 Planning Policy Background
Housing Need

2.1 As has already been set out in the preceding section 2.6 of this document, there is a significant supply shortfall within the Black Country for the plan period.

2.2 It is important to highlight that the housing need identified utilising the standard method only provides a minimum starting point for establishing housing need. It is likely that the minimum need identified would increase when factors such as affordability are taken into account.

2.3 The need to embrace a review of the existing Green Belt boundaries has been undertaken in the Draft Plan and this site in our opinion would be an appropriate site to remove from the Green Belt which performs better within the undertaken site assessments than other sites which have been allocated. Indeed, this site is considered appropriate for development and should be allocated in the plan aiding the BCA in meeting more of its need within its administrative area.

Green Belt Policy

2.4 Evidenced and justified exceptional circumstances exist in order for the Green Belt boundaries within the Black Country, and changes to the boundaries are proposed within the plan.

2.5 When reviewing Green Belt boundaries, the Framework, at paragraph 138 is clear, that the need to promote sustainable patterns of development should be taken into account. Furthermore, plans should give first consideration to land which is well served by public transport. Plans should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.

2.6 When defining new Green Belt boundaries, plans should, amongst other things: define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.

2.7 With this in mind the land at Stencils Farm presents an excellent opportunity to deliver some of the identified housing need in a highly sustainable location without undermining the identified purposes which Green Belt land should fulfil.

2.8 As the revised presented master plan makes clear, the site immediately adjoins the existing eastern edge of Walsall where the development is concentrated, the site is well contained by the Aldridge road to the south. The canal corridor and areas between the site and the Nature Reserve will remain unchanged due to the generous buffer of POS on its eastern and western edge. The presence of these robust features and the creation of a defensible corridor along the canal corridor helps to contain the site both visually and physically and will ensure that a long-term defensible new Green Belt boundary is established.

2.9 The site has been assessed against the recognized Green Belt purposes which are enshrined within the Framework at paragraph 134.

a) to check the unrestricted sprawl of large built up areas

The site is well contained to the East, South, North and West by existing houses, the Aldridge road, with landscape buffers to the Daw End Branch Canal respectively. All these features provide permanent and robust boundaries that would clearly restrict the further expansion of the built form in these directions. Thus, there is no potential for unrestricted sprawl as a consequence of the site’s development. Accordingly, in terms of the site’s current performance against this purpose, it is concluded that it does not score highly.

b) to prevent neighbouring towns merging into one another

Aldridge, the settlement which is closest to the eastern side of Walsall lies just over a kilometre away to the north east. Whilst the development would bring the eastern edge of Walsall closer to Aldridge, there is no risk of any settlement coalescence on the basis that the proposed landscape buffers and Daw End Branch Canal would easily and physically contain the development site along its northern/northeastern/ eastern edges. Beyond the canal there would remain a significant quantum of open agricultural land in excess of half a kilometre in depth which would clearly maintain the separation between the two settlements.

c) to assist in safeguarding the countryside from encroachment

At a basic level there will inevitably be some degree of countryside encroachment as a result of almost all Green Belt land release. Nevertheless, the proposed development would simply infill a logical gap that is, as we have already demonstrated, well contained. Thus, the site at present does not perform a particularly strong role in safeguarding the countryside from encroachment but owing to the physical features which have been identified will, once developed, present a robust settlement edge that would be difficult to extend beyond.

d) to preserve the setting and special character of historic towns

The Stencils Farm site is not part of, or adjacent to any Conservation Area and does not contain any listed buildings. Its development would not have any impact on any such area or other designated heritage asset. Accordingly, the site does not perform strongly against this purpose

e) to assist in urban regeneration by encouraging the recycling of derelict and other urban land

The BCA’s acknowledge that there will be scope to provide for some housing within the urban area but as the emerging evidence base already acknowledges, there is insufficient capacity within the Black Country’s urban areas to accommodate the level of housing growth that is required during the plan period. Accordingly, the inclusion of this site within the Green Belt serves no real purpose in assisting in urban regeneration because edge of settlement Green Belt release is required in order to meet identified housing need. The development of the site will be of no consequence to the development or redevelopment of any smaller windfall site within the urban area.
 
Green Belt purposes, a summary

2.10 As is evident from the commentary above the land at Stencils farm does not perform strongly against any of the framework’s stated green belt purposes. The , site benefits from appropriate containment by robust features which would prevent further expansion of Walsall to the North East, East, and South which in turn would prevent any risk of settlement coalescence with Aldridge. Furthermore, the topography of the site is such that when viewed from Aldridge road no long distance views are possible that the site is viewed very much in its immediate context.

2.11 Whilst there will be some loss of countryside as there will with any greenfield site, the land at Stencils farm does not perform any particular function in safeguarding the wider countryside from encroachment.

2.12 The BCA’s acknowledge that Green Belt release will be necessary to deliver the quantum of homes that are required within the housing market area and thus the exclusion of this land from the Green Belt and its subsequent development will not prejudice the ability for smaller windfall sites to come forward within the urban area.
2.13 For these reasons, the site represents an obvious candidate for release as part of the BCA’s overarching Green Belt review in order to facilitate the site development to provide for a significant quantum of homes in a highly sustainable location in order to assist in meeting the identified housing need across the Black Country

3.0 Working with the Site

Introduction

3.1 This site has been intensively farmed for many years and has been used primarily for arable crops with the original field patterns lost as the fields were enlarged. Some smaller fields and their associated hedgerows have been retained for livestock grazing on the peripheries of the site.

3.2 There are remnants of the former field patterns and areas of ecological interest in the form of native hedgerows, associated watercourses, wetland flushes and tree stands. These existing features will form the backbone of the Green Infrastructure network and shall inform the layout of the proposed neighbourhood.

3.3 e*SCAPE follow the principles of ,landscape-led, masterplanning, whereby the existing site features, land form and general flow of the landscape and surrounding context govern the form and scale of the development. Indeed this approach is as much grounded in ,New urbanism, as any other.

3.4 New urbanism in itself calls on a rediscovery of walkable neighbourhoods and the priority of walking, cycling and public modes of transport over private motor vehicles. The approach thus allows streets to be taken back by communities as social spaces, as opposed to domination by the car. New urbanism in turn has its roots in the Garden Cities, Towns, Villages and Suburb movement of the early 20th Century.

3.5 Such an approach works with the grain of the townscape and landscape in which it sits, creates a place which has a varied mix and density of housing and places homes within a green environment. The following paragraphs provide the material to aid our understanding, of the site and its surroundings.

Appreciating the Physical Context

3.6 In demonstrating that Stencils Farm represents an appropriate and logical location for development, Bloor Homes is also seeking to understand how the site interacts with the town, surrounding settlements and countryside, so that future development can be integrated into the townscape and landscape setting.

3.7 This appreciation of these levels of context which include both the local area and site, is set out below.

Local Context

3.8 The site sits within a good communications network within the West Midlands lying just to the east of Walsall Town Centre within the A454 Aldridge Road corridor.

3.9 The site lies in the metropolitan borough of Walsall and adjoins the established residential suburb of Longwood.

3.10 Historically Walsall emerged as a market town in the 13th Century and evolved from a village of just 2,000 people in the 16th Century to an industrial town of 86,000 by the 18th Century.

3.11 The town’s industries have changed throughout its industrialisation from coal and limestone extraction, to metal working, leather goods and more recently plastics, electronics, chemicals and aircraft parts.

3.12 The site is well located in terms of the current employment opportunities, being in close proximity to the Walsall Business Park, Aldridge Fields Business Park in Aldridge and the various business and industrial parks located in Walsall, as illustrated in Figure 03:01.

3.13 Walsall is home to various departments from the university of Wolverhampton which are located in the town centre and there are a variety of primary and secondary schools located locally to the site. In addition a new primary school is proposed on the proposed allocation site to the south offering additional places and capacity to the wider community.

3.14 The Di Ike Public House and Restaurant lies immediately across the A454, Aldridge Road from the site, with the Calderfields Golf and Country Club just slightly further south. A good number of other public houses, cafes and restaurants are located in the surrounding towns and settlements.

3.15 Walsall Town Centre is located just 1.5 miles from the site and offers a range of services and facilities including shops, pharmacies, medical services, art gallery, museums, hotels, restaurants and cafes.

3.16 The site has a series of bus stops located along its frontage with the A454, as illustrated in Figure 03:02 over page. The services include the number 6, 7,
7A, 7S and 40 providing connections to Walsall Town
Centre, Aldridge, Sutton Coalfield and Castlefort and the various stops in between.

3.17 In planning terms the site currently lies within the Green Belt as illustrated in Figure 03:02 but is well contained by the existing settlement edge, canal and Aldridge Road.

3.18 As is clearly indicated by Figure 04:02, even if the site is developed the remaining gap between Aldridge and Walsall will be substantial at more than 575 metres width to the site boundary. In addition, the intention is to provide a substantial eco-park along the site frontage with the canal which will increase the width of the separation to between 700 to 750m before any development will occur, depending on option.

3.19 In summary therefore both development options on the site:

• would form part of a new gateway to Walsall;
• would create a strong green infrastructure network and green corridor along the Daw End Branch Canal;
• create a new sustainable urban extension; and
• is enclosed by existing residential uses, the canal and Aldridge Road which represents enduring boundaries, which means there is no potential for further expansion to the east.

3.20 The proposed neighbourhood will be a residential led mixed use urban extension, with a clearly defined heart and a strong and active community.

Site Constraints & Opportunities

Introduction

3.21 As stated previously, Bloor Homes believe in developing proposals which complement the character of the local area, working with the natural grain and flow of the land and utilising existing natural and man• made features, which will give our evolving designs an immediate sense of place and maturity.

3.22 An important part of the masterplanning process is to understand the site and surrounding context in detail. Desktop and physical assessments have been undertaken by a multi-disciplinary team of consultants to inform the development of the opportunities and constraints plan, which is illustrated in Figure 04:03 over page. A summary of that work which has informed the formulation of the development framework is provided below. In summary, no technical barriers preventing the development of the site have been identified.

3.23 The site is bounded by the A454 Aldridge Road to the south which is separated from the site by an intermittent native hedgerow, woodland stands and intermittent trees which provide some screening of the site from the road.

3.24 To the east and north east the site abuts the Daw End Branch Canal before the canal swings north away from the site.

3.25 To the north west the site adjoins open fields with the Park Lime Pits Local Nature Reserve visible beyond them.

3.26 The eastern boundary consists of the former Stencils Farm and has an extant planning permission for residential development. This area and the adjoining established residential properties will require a sensitive treatment within the proposals for the site.
Landscape & Visual Appraisal

Landscape Character

3.27 The site is located within the Barr Beacon and Aldridge Fields Character Area (WL09) as documented by the Black Country Historic Landscape Characterisation document funded by English Heritage for the four Black Country Authorities, including Walsall. The document summarises the area as, "This area is the most rural landscape in Walsall, with field systems covering more than two thirds of its surface (although recreational land is also important). Four fifths (80%) of the area dates to before 1900. It is bounded on almost all sides by settlement, and in the north-east and south-east by the boundaries with Staffordshire and Birmingham respectively."

3.28 The site generally accords with the more detailed descriptions under the heading of Modern Character and highlights that the area is characterised by agricultural land and dispersed farms. It acknowledges that important recreational areas around Barr Beacon are within the character area and this is located to the south of the proposed development site. There are also three golf courses that were laid out in the 20th century in the area such as Druids Heath in the north of the character area, the Great Barr in the south and one adjacent to Walsall Arboretum in the west.

3.29 Farmland in the area is almost entirely enclosed field systems and t is likely that the earliest of these were created in the late medieval and early post medieval periods through the piecemeal enclosure of the open fields which once covered most of this area. There is some evidence of ridge and furrow earthworks surviving, however some of these fields have been subject to boundary loss, especially during the 20th century. To the east lie field systems enclosed during the late 18th/ early 19th century, which exhibit straight roads and boundaries typical of parliamentary enclosure.

3.30 Like the fields systems, the associated farms date from many different periods. The earliest have medieval origins, although the oldest surviving farm buildings date to around the early 18th century. Others have been rebuilt between the 18th and 20th centuries but have much earlier origins.

3.31 Two small clusters of housing lie in the centre of the area. One is a distinctive estate of large houses in woodland at Bourne Vale, dating to the inter/ post war period. It was built on the site of a landscaped park belonging to Bourne Vale House. The other is a number of detached houses from a similar period located on the Longwood and Erdington Roads south of Aldridge.

3.32 Also, south of Aldridge, small areas of woodland survive - originating from at least the 18th or 19th centuries. Some of these are areas of former limestone quarrying. A further survival is the heath land at Barr Beacon, which is the only area of what had once formed part of Cannock Forest to survive the planned enclosures of the 18th/19th century.

3.33 The area of proposed development is located at Land at Stencils Farm, Aldridge Road, Walsall. It is on the north eastern settlement edge of Walsall within the Birmingham Green Belt designation.

3.34 The site which currently comprises agricultural land split into a series of fields, extends to approximately 37.8 hectares and is irregular in form.

3.35 The land gently rises from the northern and southern edges to an elevated central area. The Park Lime Pits Nature Reserve and Country Park bounds the site to the north/north west whilst the Daw End Branch canal defines the north/north east edges.
3.36 The southern edge of the site is contained by the A454 Aldridge Road, which for almost the full length of the site’s southern edge is dual carriageway and includes a traffic island which provides access to Calderfields Golf Club and the Dilke pub/restaurant which are to the south.

3.37 The boundaries are mostly delineated by native hedgerows with mature trees in groups or as single specimens. Within the boundaries the majority of land cover is taken up with arable fields bound by partly rem oved hedges. One of the hedge alignments to the south is designated as a Site of Local Importance for Nature Conservation. An area of semi-improved grassland is located to the south west and an area of wetland is adjacent to the northern boundary .

3.38 The topography of the proposed development area gently rises from the east to west from approximately 135m AOD to 150m AOD. There is a Public Rights of Way (FP Wal59) that travels across the site that links Beacon Way to Aldridge Road on the southern boundary. A Grade 2 listed bridge is within close proximity (but outside of the site) to the north and provides pedestrian access across the Daw End Branch Canal.

3.39 PGLA Landscape Architects have prepared a Landscape and Visual Appraisal (LVA) for Option 1 and provided an updated Landscape and Visual Appraisal Addendum to take account of the potential effects of Option 2. The studies have identified the landscape to be Medium sensitivity which is based on an assumption that the site will need to be released from the Green Belt to be developed.

3.40 The assessment of the potential effects on the landscape concludes that there will be a moderate major change in the landscape fabric of the existing site as the proposed developments and associated infrastructure are introduced, however, there is potential for any identified adverse effects being further reduced over time as the planting and landscape framework within the site matures.

3.41 The setting of the site will benefit from the introduced planting to infill the gaps in the hedgerows, particularly on the southern and northern boundaries. The proposed development is likely to have an imperceptible effect on the broad landscape character. However, the landscape proposals are also considered to be potentially beneficial as they reflect the species of the adjacent landscape and are consistent with the Landscape Character description for the Black Country.

Visual Amenity

3.42 The site is located on mixed arable and pastoral farmland with gently rolling landform to either side of a central ridge. The landscape is adjacent to the eastern edge of the urban area of Walsall.

3.43 Sensitive visual receptors are identified as being localised to the western and northern edges accounting for the interface with the existing residential area of Walsall and the Daw End Branch Canal which forms a well vegetated and defensible boundary to the development site. The southern boundary is adjacent to Aldridge Road.

3.44 There is one public footpath (Wal59) that crosses the proposed development site and travels north to south linking Aldridge Road to the Beacon Way and the B4154 just the south of Aldridge to the north of the site. There will be an obvious change in view to these receptors as residential housing is introduced but the landscape strategy outlines the mitigation measures that will be introduced as part of the two development options to reduce any potential adverse effects on the visual amenity of these receptors.

3.45 Generally, the proposed development site is visually well contained when viewed from further afield. Views from the west and south are screened by the existing Walsall settlement and from the north and east by Aldridge and the vegetation on the B4154 roadside and within the hedgerows in the landscape and canal corridor.

3.46 It is likely that some immediate views are achievable into the site from Aldridge Road and to some degree from Walsall Road to the east, but these will be sporadic and limited due to the landform and vegetation within the existing countryside. The landscape strategy will ensure that appropriate planting is introduced to provide mitigation for any identified adverse effects.

3.47 The visual assessment that has been carried out has demonstrated that the proposed development will have some general effects on the immediate visual amenity along Aldridge Road and the Beacon Way, however, views into the site are mostly localised to the immediate vicinity of the site boundaries.

3.48 The residential amenity of the properties on Aldridge Road, Mellish Drive and Stencils Road will undergo varying degrees of change. However, as the proposed landscape structure planting and the proposals seek to reinforce the screening, the residual effects are deemed to moderate to negligible.

3.49 The users of the public footpath networks will experience some moderate major effects to the visual amenity at time of completion and the residual effects are likely to reduce to minor moderate as the proposed planting matures. The long to medium view range footpath network will experience negligible residual effects due to the existing settlements, landform and vegetation within the countryside.

3.50 A substantial degree of visual separation will be maintained from the south of Aldridge to the northern built edge of the development due to intervening vegetation and this will be further enhanced by the separation provided by the planting within the introduced linear park immediately south of the canal on the development side.

3.51 Generally, it is not considered that any long term significant adverse effects will pervade in respect of the likely impacts on the landscape character and visual amenity.

3.52 Although any major development on a green field site will result in some landscape change, the LVA and LVA Addendum concludes that ,the development is likely to have an imperceptible effect on the broad landscape character, and whilst there ,will be some general effects on the immediate visual amenity along Aldridge Road and Beacon Way, views into the site are mostly localised to the immediate vicinity of the site boundaries.,

Existing Vegetation & Trees

3.53 A remnant field pattern of native hedgerows sub• divides the site into a number of field compartments, as illustrated opposite. Most of the hedgerows are very gappy and heavily flailed. However, the hedgerow which forms the Site of Local Importance for Nature Conservation (linear) as illustrated in Figure 04:03, as the designation suggests is physically of a better form and creates an important feature in the landscape of the site currently. All hedgerows shall be integrated into the development where possible as part of the green infrastructure network.

3.54 A number of mature native trees are located either within the hedgerows or fields and create a setting for the site and wider landscape.

3.55 The trees and hedgerows combine to filter views of the site from the wider area and all shall be retained where possible with only shorts breaks being created through the existing hedgerows to allow access between the field compartments.

Drainage & Flood Risk

3.56 The site has been subject to a preliminary flood risk assessment and consideration of the surface water drainage discharge options. Infiltration potential and foul water discharge solutions have also been considered.

Fluvial Sources

3.57 Several watercourses are situated within reasonable proximity of the site. Notably the Daw end branch canal is the largest river in the vicinity and it flows along the eastern boundary of the site. A further small water course channel is shown to flow from the larger of the two lakes that are situated within the park lime pits local nature reserve which lies some 0.4 km beyond the north west boundary of the site.

3.58 The entire development site is located within flood Zone 1 based on the EA’s mapping and thus has a less than 1 in 1000 annual probability of river or sea flooding in any year. Thus, it has the lowest probability of flooding as defined in national planning policy.

3.59 Whilst the site also lies in close proximity to the Daw End Branch Canal, the management of this watercourses is such that it presents an extremely low risk of flooding.

3.60 Furthermore, the topography of the site is such that it increases as progress is made away from the existing watercourses which consequently provides additional flood resilience.

3.61 Accordingly, it is asserted that there is an extremely low risk of flooding from both natural and artificial fluvial sources.
Pluvial Sources

3.62 In terms of surface water flooding, the Environment Agency’s maps indicate that the majority of the site is in an area classified to have a very low risk of surface water flooding. There are a limited number of areas within the site that are affected by surface water flooding, it should be noted that all accumulations/ flow paths are shown to flow away from the site in accordance with the local topography. Thus in terms of establishing an overall risk of flooding from surface water sources, it is concluded that the risk is a low one.

3.63 Nevertheless, preliminary mitigation strategies have been explored in order to deal with any residual risk. Firstly it is recommended that developed areas of the site are prioritised on elevated land and situated away from any local drainage ditches. Site boundaries, where surface water flooding may occur would be best suited to areas of public open space which could also include the provision of sustainable drainage features. Secondly, it is proposed that the development will include a positive surface water drainage system that will intercept the majority of run• off generated within the site itself. This will minimise the risk to new buildings in addition to reducing the risk to others across the wider area. The overall effect will be to provide a significant reduction in surface water flow rates post development through the utilisation of this sustainable drainage system.

3.64 In addition to potential sources of fluvial and pluvial flooding, the drainage assessment also considers the development site’s infiltration drainage potential. Desktop research reveals that the ground conditions are however such that infiltration based drainage is unlikely to be suitable. Nevertheless, infiltration testing will of course be undertaken to further explore the potential for drainage by this mechanism as the development site progresses through the plan making process.

3.65 In terms of foul water disposal, initial investigations suggest that a pumping station will be required to convey flows to public foul sewers which are assumed to be present within the Aldridge Road to the south of the site.

3.66 Accordingly, the preliminary drainage and flooding assessment concludes that the site is at low risk of flooding from both fluvial and pluvial sources and that there are no particular constraints which indicate that subject to a suitable sustainable drainage strategy, any sources of flooding could not be satisfactorily mitigated.

Ecology

3.67 Preliminary ecological assessment of the site has been undertaken. In the main, the site comprises two grassland fields in arable use which are of relatively limited ecological value. The field in the south west corner of the site is less intensively managed however and does present the potential to support reptiles. Their presence would be confirmed by further survey work.

3.68 Ordnance Survey mapping also indicates that a pond is located in this south west area too but initial survey work indicates that it is likely to only hold water during very heavy rainfall events. There is an absence of any wetland vegetation here and there are no records of any Great Crested Newts (GCN) within the local area. Nevertheless, should this pond hold any water during the GCN breeding season, further survey work should be undertaken.

3.69 Confirmed wetland in the northern part of the site holds the greatest ecological value. This presents an opportunity for retention and enhancement as part of the development proposals.

3.70 The field margins support a range of box cut hedgerows and thick tree belts containing a number of mature specimens. These margins provide foraging opportunities for bats and accordingly, further survey work will be undertaken to establish activity and mitigation as necessary. further survey work will be undertaken to confirm the extent and importance of this sett and any others.

3.71 In summary, through further survey work and appropriate mitigation the existing ecological value of the site can not only be safeguarded but there are numerous opportunities for enhancements across a wide range of flora and fauna.

Heritage & Archaeology

3.72 The development site has been subject to a comprehensive desktop heritage assessment undertaken by Orion Heritage which, in accordance with the Framework draws together all available archaeological, historic, topographic and land-use information to clarify the heritage significance and archaeological potential of the site.

3.73 There are no designated archaeological assets within the site or indeed within the wider area which surrounds the site such that their significance would be impacted by the proposed development.

3. 74 Whilst there are designated heritage assets to southwest of the site, namely the registered Park and Garden of the Arboretum and the Arboretum Conservation Area, the site does not form part of the setting of either of these designated heritage assets and furthermore does not contribute to their significance.

3.75 The Daw End Branch of the Wyrley and Essington canal which contains the site to the north east/east is a non-designated heritage asset. As has already been set out within this document, it significance will not be unduly impacted as a result of the development rather it presence has informed the masterplanning of the site, increasing the opportunities which are available to the public to enjoy it by improving the accessibility to it from the public realm and ultimately safeguarding its setting by virtue of the development of a eco-park adjacent to it along the site’s north eastern/eastern boundary.

3.76 Although no physical archaeological investigation of the site has taken place, desktop research has revealed that there may be the remains of a World War II camp within the site and further archaeological investigation will be undertaken as the plan making process continues.

3. 77 Nevertheless, on the basis of the historical information that is available, Bloor Homes heritage consultant concludes that there ,are unlikely to be any archaeological assets within the site of such significance that would preclude or constrain development or adversely affect the deliverability of the site.,

Public Rights of Way

3. 78 A Public Right of Way cross the site roughly from north to south as illustrated in Figure 04:03 and connects the site up to the fringes of Aldridge and the tow path of the Daw End Branch Canal. The majority of the route will be retained on its current alignment and within a green corridor.

3.79 Additional connections to the public right of way and the canal tow path will be created through the proposed extensive green infrastructure network to ensure the site is permeable and well connected to the surrounding areas.

Access & Movement

3.80 The development site’s immediate proximity to the A454 Aldridge Road to the south, provides obvious and easily accessible means of connection to the existing highway network. To this end, Waterman, the appointed transport consultant concludes that ,a safe and technically sound solution, which achieves the necessary visibility splays can be delivered. The site will integrate directly into the existing footpath network. Further, there are not considered to be any particular concerns in relation to the capacity of the existing network to accommodate the trips that the proposed development would generate.

3.81 More specifically, the access strategy would include the provision of two vehicular accesses from Aldridge Road, the first comprising an additional arm from the existing roundabout, the second a new a priority T junction further to the east.

3.82 Not only is the ability for the site to connect to the existing transport network excellent, the site also enjoys excellent sustainability credentials. A total of five bus services serve the immediate area providing access to various areas within Walsall as well as Aldridge and Sutton Coldfield. The two nearest bus stops to the site are approximately 120m and 260 m away from site to the south and east respectively.

3.83 Furthermore, Walsall has been identified as a ‘Sprint Corridor’ destination from Birmingham city centre along the A45. It is anticipated that this service will be operational by 2022 in order to support the Commonwealth Games and will incorporate some
20 stops in each direction with the journey time being around 40 minutes with priority given to ,Sprint, services at traffic signals.

3.84 The site also enjoys close proximity to Walsall railway station which is approximately 2 ½ km away. There are direct services to Birmingham New Street, Rugeley Trent Valley and Wolverhampton on a frequent basis.

3.85 The site is evidently well located therefore to allow easy access to public transport options thus reducing reliance on private motor vehicle use.

3.86 The transport assessment has also analysed the site’s accessibility to various amenities and facilities within its proximity including those relating to education, healthcare, employment, leisure and retail.

3.87 There are 9 infant and primary schools and 4 secondary schools within 3 km of the development site. It should also be noted that the development is likely to incorporate a primary school of its own in order to cater for the educational needs that a development of this scale will give rise to.

3.88 In terms of health care, the most accessible primary health care facility is just some 3.1 Km from the development site.

3.89 There are retail/leisure facilities and employment opportunities in abundance within Walsall itself as well as within the centres of Birmingham and Wolverhampton which are clearly within sustainable travelling distance.

Residential Amenity

3.90 Existing residents who front or back onto the site will be considered in the design and layout of the proposals. Landscape buffers shall be used to create a stand• off from the sensitive boundaries and built from will be set back to ensure minimum overlooking distances are exceeded.

Wider Green Infrastructure Network

3.91 The internal green infrastructure network and Sites of Local Importance for Nature Conservation (SINC’s) as illustrated in Figure 03:02 shall be retained, as will the connections out to the wider area.

3.92 This network shall form the structure of the proposed layout and provide not only a backdrop to the proposed development, but also links between surrounding wildlife habitats and the site to ensure good connectivity is maintained in the form of wildlife corridors into and through the proposed development.

4.0 Options for Creating a New Neighbourhood

A Vision for Land at Stencils Farm

4.1 Out of this contextual appreciation of place and analysis of the site springs our Vision. The development of this site will create a sustainable urban extension on the north eastern edge of Walsall. The development shall integrate and become part of the existing settlement pattern of the town, whilst also being bounded, enclosed and softened by the retained and reinstated hedgerows, associated trees and new complimentary native planting.

4.2 The development shall create a new high quality, welcoming and outward looking gateway into the town. This new neighbourhood will be designed following the principles of a 21st Century Garden Suburb, developing a new neighbourhood which creates a series of high quality green spaces. These green spaces, along with wildlife corridors, ecological habitats and recreational footpaths/cycleways will be developed within an over arching and extensive Green Infrastructure network, linking the site to the local facilities, wider settlement and countryside, as well as buffering the site from the wider Green Belt.

4.3 This new Garden Suburb will be focussed around the Open Spaces, Mews and Squares and shall be enclosed and overlooked by new homes, shops and offices, creating a heart and focus to the neighbourhood, utilising existing features such as the trees and hedgerows as focal features within them.

4.4 The neighbourhood will develop its own unique character and contain a choice and variety of homes. The fringes of the neighbourhood shall use a range of outward facing properties, using a rural materials palette to create a softer and more rural fringe, enabling it to blend and blur into the open countryside.

4.5 This approach works with the existing landscape, sympathetically overlaying development which will become a part of the character of the wider town.

An evolving masterplanning process

4.6 Developing a visionary and unique masterplan, if done correctly, is an iterative process. Initial ideas develop out of the site’s own context, constraints and opportunities, as touched upon in the previous chapter.

4.7 That initial process provides a logical structure and framework for the masterplan and also, as further work is undertaken and discussions are held with stakeholders on ecology, movement, landscape, the appreciation of the local character and vernacular, our understanding develops of the historical evolution and development of the surrounding settlement. Additional layers of detail can then be added in terms of layout, access, hierarchy of streets and public realm, detailing of the built form, materials and landscape.

4.8 That original locally contextual and site focused analysis still holds true for the site, but in order to offer an alternative option which takes account of LuC’s findings in their much more broad brush and less site focused LVIA we have developed an alternative and lower key option.

Optioneering

4.9 As stated previously we still strongly believe that the originally conceived option illustrated in Figure 04:01 works in sympathy with the site and its constraints, as well as the wider local context

4.10 However, the work related to the emerging Black Country Local Plan and specifically LuC’s Landscape and Visual Impact Assessment has meant that we have developed an alternative option which takes account of those broader findings to create development that responds to the potential issues identified in their study, as illustrated in Figure 04:02 over page.

4.11 Whilst we have disputed the fact that our site is not typical of the wider Parcel used in LuC’s analysis Bloor Homes wanted to demonstrate that they are open to alternative proposals in order to bring their site forward as an allocation.

4.12 The primary differences between the two options are set out below.

4.13 Option 1 deliveries circa 700 homes across the whole site, whereas Option 2 delivers 370 homes on just over half the original site area.

4.14 Option 2 introduces open spaces (the Village Greens) in key locations on the ridge line to reduce the impact of built development when viewed from the surrounding rural landscape.

4.15 Option 2 also pulls the housing back from the lowers slopes to the north, creating a wider landscape and ecology buffer to the SINC, providing naturalistic open space for enjoyment by the local community and also minimising the inter-visibility of the homes from the canal.

4.16 Options 2 also takes account of the recently designated Stencils Farm SINC on Aldridge Road and reinstates historic hedgerow boundaries within the site.

Creating a Place

4.17 In order to deliver the Vision, the masterplan must take account of the site’s context and constraints and turn them into opportunities for use in developing the proposals. The parameters masterplan options illustrated here in Figures 04:01 and 04:02 are both as a result of that process.

4.18 Option 1, as stated previously, emerged out of a site specific analysis of the constraints, whereas Option 2 not only developed out of that work but also took account of the broader_brush and less specific assessment undertaken by LuC. The following paragraphs describe each element within the options, many are common to both masterplans.

Use and Quantum

4.19 Both options illustrates residential_led development complimenting the surrounding established use mix, set within a Green Infrastructure network. The site in total is circa 37.80 hectares.

4.20 Option 1 includes:

• some 19.34 hectares of residential development,
• a Two Form Entry School (2.0 hectares),
• Local Centre (0.64 hectares), and
• 15.82 hectares of Green and Blue Infrastructure which will include woodlands, wetlands and grasslands, incorporating naturalistic play areas, orchards/allotments, cycle routes and nature trails.

4.21 Option 2 includes:

• 9.40 hectares of residential development,
• 15.27 hectares of land retained in agriculture,
• a mixed_use parcel (0.62 hectares), and
• 12.51 hectares of Green and Blue Infrastructure which will include woodlands, reinstated hedgerows, wetlands and grasslands, incorporating naturalistic play areas, orchards/allotments, cycle routes and nature trails.

4.22 Both new neighbourhoods would also contain a range of housing densities, offering choice and variety in terms of locations and size of homes. Densities would vary from the fringes at circa 18 homes per hectare up to 55 homes per hectare at its heart. This varied density would roughly equate to a net average of between 36 to 39 homes per hectare, or a gross density of around 17 to 20 homes per hectare.

Layout and Movement

4.23 Both layouts have emerged from the earlier constraints and opportunities work as set_out in Chapter 3. Figure 04:01 and 04:02 illustrates how the trees, wetlands and topography have been used to provide a starting point for developing each layout. These drivers have been used to establish a route hierarchy that forms the basis of the design. The primary element on both options is the Main Avenue which would be flanked by street trees and creates a bold green avenue from the main gateway right through the centre of the site.

4.24 In Option 1 and running from the Main Avenue there is a Secondary Avenue which could be used as a looping bus route into the site connecting the Main Avenue out to the proposed primary school and providing a secondary access back onto Aldridge Road.

4.25 In both options Streets and Lanes feed off the avenue and form the movement network based around traditional Streets, shared surface Lanes and Mews style spaces. Where these routes intersect. Raised thresholds, public squares or landscape features will be introduced to aid legibility and reduce traffic speeds. The layout is also designed to ensure pedestrian and cycle permeability. There are clear opportunities to link into surrounding footpaths, towpaths, open spaces and other routes, thus ensuring that maximum permeability and integration is achieved.

Scale, Mix and Massing

4.26 Depending on the chosen option It is proposed that approximately between 350 to 700 homes can be accommodated on the site. The proposals have the potential to provide a range and choice of housing from one and two bedroom apartments to larger more aspirational 4 and 5 bed detached housing.

4.27 The form of the adjoining neighbourhood suggests principally 2 storey (between 8 to 10 metres to ridgeline) development would be appropriate. However, in order to create interest in the streetscape and roofscape appropriate increases in scale could be used at principle junctions, within mews and around key green spaces to aid legibility and enclosure.

Landscape Strategy

4.28 The development of the layout for this site has taken the existing green infrastructure into account to provide a landscape led mixed use development set within a substantial landscape framework.

4.29 There are significant opportunities for new tree planting and landscaping within the site, and infill planting especially on the western interface with the existing settlement edge of Walsall and the southern boundary adjacent to Aldridge Road. The hedgerow adjacent to Aldridge Road will be enhanced with infill planting and groups of native trees. Furthermore, it is proposed that a substantial tract of public open space in the form of a Linear Eco_Park is located to the north and west of the site and school playing fields surrounded by woodland to the south eastern section of the site. This will provide a substantial landscape buffer offering visual separation from the landscape to the north of the Daw End Branch Canal.

4.30 The overall elements of the landscape strategy for the site can be summarised as follows:

• Retention of the existing elements that make up the site’s green infrastructure, such as trees and hedges and integrating these into the development, giving the scheme an immediate sense of maturity.
• Ensuring the gaps in the existing hedge adjacent to the boundaries and Aldridge Road are in_filled with native trees and hedge planting. Evergreen species of holly should be included in the mix to provide effective screening through the winter months.
• Ornamental and native hedge planting to be planted in and around the proposed development to soften the adverse effects of the built form.

5.31 A range of trees to be introduced to reflect the street hierarchy including the central avenues, crescents, squares and mews. Native trees should be planted in the Linear Eco_Park and general perimeters including areas of public open space and school.

5.32 The landscape strategy has been taken into account when considering the mitigation for the identified potential adverse landscape and visual effects arising at the operational stage of the proposed development and these have been reflected when considering the overall residual effects.

Public Realm and Hard Landscape

5.33 The hard landscape materials palette also reflects the spatial hierarchy and patterns of movement through the development. Avenues and Village Streets will be designed as traditional roads, with the Lanes, Mews and Squares designed as more intimate, human scale spaces where pedestrian movement takes priority over motorised vehicles.

From Concept to Masterplan

5.34 Demonstrating this staged approach to developing the masterplan clearly illustrates our thought processes from first principles in terms of appreciating the local context, design philosophy and the utilisation of the sites own unique features to guide the development of the masterplan structure in both options.

5.35 In essence both options demonstrate that the proposals will create an integrated extension to the settlement, set into the existing landscape, creating a high quality addition to the town, offering much need homes and choice to the local community. The options also provide a choice in terms of the quantum of development the surrounding area has the capacity to accommodate.

5.36 As illustrated in Figure 05:04a & b the Stencils Farm proposals will have a minimal effect on the purpose of the retained Green Belt between the proposed Sustainable urban Extension and Aldridge to the north east, with a gap of 700 (Option 1) to 750 metres (Option 2) between Aldridge’s settlement fringe and the first homes on the site set behind the proposed ecological buffers.


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